AUTHENTICATED ,
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INFORMATION ^
ARE “SUPERWEEDS” AN OUTGROWTH OF USDA
BIOTECH POLICY? (PART II)
HEARING
BEFORE THE
SUBCOMMITTEE ON DOMESTIC POLICY
OF THE
COMMITTEE ON OA^RSIGHT
AND GOA^RNMENT REFORM
HOUSE OF REPRESENTATDH]S
ONE HUNDRED ELEVENTH CONGRESS
SECOND SESSION
SEPTEMBER 30, 2010
Serial No. 111-160
Printed for the use of the Committee on Oversight and Government Reform
Available via the World Wide Web: http://www.fdsys.gov
http://www.oversight.house.gov
ARE “SUPERWEEDS” AN OUTGROWTH OF USDA
BIOTECH POLICY? (PART II)
HEARING
BEFORE THE
SUBCOMMITTEE ON DOMESTIC POLICY
OF THE
COMMITTEE ON OA^RSIGHT
AND GOA^RNMENT REFORM
HOUSE OF REPRESENTATDH]S
ONE HUNDRED ELEVENTH CONGRESS
SECOND SESSION
SEPTEMBER 30, 2010
Serial No. 111-160
Printed for the use of the Committee on Oversight and Government Reform
Available via the World Wide Web: http://www.fdsys.gov
http://www.oversight.house.gov
U.S. GOVERNMENT PRINTING OFFICE
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COMMITTEE ON OVERSIGHT AND GOVERNMENT REFORM
EDOLPHUS TOWNS. New York. Chairman
PAUL E. KANJORSKI, Pennsylvania
CAROLYN B. MALONEY. New York
ELIJAH E. CUMMINGS, Maryland
DENNIS J. KUCINICH, Ohio
JOHN F. TIERNEY, Massachusetts
WM. LACY CLAY, Missouri
DIANE E. WATSON, California
STEPHEN F. LYNCH, Massachusetts
JIM COOPER, Tennessee
GERALD E. CONNOLLY, Virginia
MIKE QUIGLEY, Illinois
MARCY KAPTUR, Ohio
ELEANOR HOLMES NORTON. District of
Columbia
PATRICK J. KENNEDY, Rhode Island
DANNY K. DAVIS, Illinois
CHRIS VAN HOLLEN, Maryland
HENRY CUELLAR. Texas
PAUL W. HODES, New Hampshire
CHRISTOPHER S. MURPHY. Connecticut
PETER WELCH, Vermont
BILL FOSTER, Illinois
JACKIE SPEIER, California
STEVE DRIEHAUS, Ohio
JUDY CHU, California
DARRELL E. ISSA, California
DAN BURTON, Indiana
JOHN L. MICA, Florida
JOHN J. DUNCAN, jR., Tennessee
MICHAEL R. TURNER, Ohio
LYNN A. WESTMORELAND, Georgia
PATRICK T. McHENRY, North Carolina
BRIAN P. BILBRAY, California
JIM JORDAN, Ohio
JEFF FLAKE, Arizona
JEFF FORTENBERRY, Nebraska
JASON CHAFFETZ, Utah
AARON SCHOCK, Illinois
BLAINE LUETKEMEYER, Missouri
ANH “JOSEPH” CAO, Louisiana
BILL SHUSTER, Pennsylvania
Ron Stroman, Staff Director
Michael McCarthy, Deputy Staff Director
Carla Hultberg, Chief Clerk
Larry Brady, Minority Staff Director
Subcommittee on Domestic Policy
DENNIS J. KUCINICH, Ohio, Chairman
ELIJAH E. CUMMINGS, Maryland
JOHN F. TIERNEY, Massachusetts
DIANE E. WATSON, California
JIM COOPER, Tennessee
PATRICK J. KENNEDY, Rhode Island
PETER WELCH, Vermont
BILL FOSTER, Illinois
MARCY KAPTUR. Ohio
Jaron R.
JIM JORDAN, Ohio
DAN BURTON, Indiana
MICHAEL R. TURNER, Ohio
JEFF FORTENBERRY, Nebraska
AARON SCHOCK. Illinois
Bourke, Staff Director
(II)
CONTENTS
Page
Hearing held on September 30, 2010 1
Statement of:
Smith, Steve, director of agriculture. Red Gold Tomato; Phil Miller, vice
president, global regulatory, Monsanto Co.; Bill Freese, science advisor,
Center for Food Safety; and Jay Vroom, CEO, Croplife America 44
Freese, Bill 60
Miller, Phil 52
Smith, Steve 4
Vroom, Jay 72
Wright, Ann, Deputy Under Secretary, U.S. Department of Agriculture;
Sid Abel, Assistant Deputy Administrator, Biotechnology Regulatory
Service, Animal and Plant Health Inspection Service, U.S. Department
of Agriculture; and Jim Jones, Deputy Assistant Administrator, Office
of Chemical Safety and Pollution Prevention, U.S. Environmental Pro-
tection Agency 7
Jones, Jim 16
Wright, Ann 7
Letters, statements, etc., submitted for the record by:
Freese, Bill, science advisor. Center for Food Safety, prepared statement
of 62
Jones, Jim, Deputy Assistant Administrator, Office of Chemical Safety
and Pollution Prevention, U.S. Environmental Protection Agency, pre-
pared statement of 18
Kucinich, Hon. Dennis J., a Representative in Congress from the State
of Ohio:
Fourth declaration of Cindy Smith 32
Prepared statement of 4
Miller, Phil, vice president, global regulatory, Monsanto Co., prepared
statement of 54
Smith, Steve, director of agriculture. Red Gold Tomato, prepared state-
ment of 46
Vroom, Jay, CEO, Croplife America:
Prepared statement of 80
Report of CropLife Foundation 77
Study dated June 2010 94
Various photos 73
Wright, Ann, Deputy Under Secretary, U.S. Department of Agriculture,
prepared statement of 10
(III)
ARE “SUPERWEEDS” AN OUTGROWTH OF
USDA BIOTECH POLICY? (PART H)
THURSDAY, SEPTEMBER 30, 2010
House of Representatives,
SUBCOMMITTEE ON DOMESTIC POLICY,
Committee on Oversight and Government Reform,
Washington, DC.
The subcommittee met, pursuant to notice, at 2:04 p.m., in room
2203, Rayburn House Office Building, Hon. Dennis J. Kucinich
(chairman of the subcommittee) presiding.
Present: Representatives Kucinich, Watson, and Towns.
Staff present: Jaron R. Bourke, staff director; and Justin Baker,
clerk/policy analyst.
Mr. Kucinich. Good afternoon. The subcommittee will come to
order. I want to note that usually we’re joined by many Members
of Congress, but late last night they had a get-out-of-dodge mo-
ment. And most Members are now back in their home constituency,
a place that I intend to be in a few hours. But I am very pleased
that all of you are here for this important hearing. The Subcommit-
tee on Domestic Policy on the Committee on Oversight and Govern-
ment Reform is now in order.
Today’s hearing is the second day of the first hearing held by
Congress to examine the environmental impact of the evolution of
herbicide-resistant weeds in fields growing genetically engineered
herbicide resistant crops. But for years, farmers have struggled
with the impact. Across the Midwest and south, farmers growing
Roundup Ready soy, corn and cotton have been encountering more
and more kinds of weeds that Roundup herbicide cannot control.
That weed resistance costs farmers money and causes them to
resort to more and more toxic pesticides. Please look at the mon-
itors for an excerpt from an ABC News segment that ran last year.
Staff, play that segment.
[Video shown.]
Mr. Kucinich. Thank you. What responsibility for preventing
and lessening the environmental impact of Roundup-resistant
weeds and the consequent impact on farmers does the Federal Gov-
ernment have? Today we will hear from government regulators and
others on that question. Now without objection. I’m going to con-
tinue with an opening statement of 5 minutes, any Member or wit-
ness who wishes to submit a written statement or extraneous ma-
terials for the record will have 5 legislative days to do so, without
objection.
( 1 )
2
And in our previous hearing in July, we heard from weed sci-
entists that Roundup-resistant weeds have infested between 4 and
11 million acres of prime farmland in the southeast and Midwest.
Mr. Chairman, welcome. This is the chairman of the full commit-
tee, Mr. Towns. Thank you for being here.
While a phenomenon of natural selection for herbicide resist-
ant — resistance is not new, the acceleration in a number of resist-
ant weed species, and especially the infested acreage, is new. And
it’s been caused by the commercialization of multiple Roundup-re-
sistant crop systems. In only the last decade, eight or nine species
of weeds have rapidly evolved resistance to Roundup in herbicide
resistant crop fields. Indeed, Roundup resistance in weeds has been
known since the year 2000 when Roundup-resistant horseweed, a
weed species that had not been previously resistant to Roundup,
was discovered in Roundup-Ready crop fields in Delaware.
While scientists have validated what farmers were discovering in
their fields, the Nation’s lead regulator of genetically engineered
crops, the U.S. Department of Agriculture, has been looking the
other way. Every time a pesticide company petitioned the USDA to
deregulate a new herbicide-tolerant variety of crop, USDA deter-
mined that the introduction of the new crop would have “No signifi-
cant impact” on the farming environment. But recently the Depart-
ment’s indifference to the indirect consequences of their deregula-
tion of Roundup-resistant crops has caught the attention of two
Federal District Court judges. They independently struck down the
USDA’s deregulation of Roundup-Ready alfalfa, and Roundup-
Ready sugar beets.
They found USDA to have unreasonably and arbitrarily dismiss
the environmental consequences of deregulating genetically engi-
neered crops. In one instance, the judge found that USDA could
produce no written record that it had ever considered the impact
on farmers. Nevertheless, Roundup-resistant weeds are hurting
farmers. They are imposing $1 billion in additional weed control
costs. They threaten cotton growing so profoundly that they’ve been
compared to the boll weevil.
And the solution may be worse than the problem. To combat
Roundup-resistant weed proliferation, the pesticide industry rec-
ommends to farmers that they use more and more toxic pesticides
on newly engineered crops that will be tolerant of those more toxic
pesticides. That will surely lead to more environmental pollution,
and, as we shall see, the collateral damage of crop destruction, and
even more costs to farmers.
In today’s hearing, we will show that the USDA’s passivity lies
in stark contrast to the EPA’s active approach in preventing pest
resistance to genetically engineered crops it regulates. We will
show that the USDA’s legal authority is no less broad than EPA’s
legal authority. However, USDA views its broad authority much
too narrowly, while EPA used its broad authority appropriately.
Which approach has the better track record? Passive and self-
constrained, USDA’s approach has plainly allowed the proliferation
of herbicide-resistant weeds. In contrast, EPA’s record of preven-
tion is a relative success.
Perhaps we are at a crossroads for USDA’s policy of passivity to-
ward superweeds, having been reversed by two Federal judges with
3
scores of farmers needing relief from the cost and consequences of
superweeds. And with a new administration determining policy at
the Department, it may finally be the time there for the Depart-
ment of Agriculture to reexamine its approach to the deregulation
of the genetically engineered crops, and to make a change in policy.
It should be a change that would help prevent the proliferation
of herbicide resistant weeds. It should be a change that would pre-
serve efficacy of a relatively benign herbicide. It should be a change
that would deescalate the trend to more and more toxic pesticides.
It should be a change that would pass muster with Federal courts.
It should be a change that would protect the long-term interest of
farmers, consumers and the natural environment.
The chair recognizes the distinguished chair of the full commit-
tee, Mr. Towns of New York. I appreciate your being here, Mr.
Towns, and I appreciate the leadership that you provide on the full
committee.
[The prepared statement of Hon. Dennis J. Kucinich follows:]
4
Opening Statement of
Dennis J. Kucinich
Chairman
Domestic Policy Subcommittee
Oversight and Government Reform Committee
Hearing on
“Are ‘Superweeds’ an Outgrowth of USDA Biotech Policy? (Part II)”
September 30, 2010
In our previous hearing in My, we heard from weed scientists that Roundup resistant
weeds have infested between 4 and 1 1 million acres of prime farmland in the Southeast
and Midwest. While the phenomenon of natural selection for herbicide resistance is not
new, the acceleration in the number of resistant weed species and especially the infested
acreage is new, and it has been caused by the commercialization of multiple Roundup
resistant crop systems. In only the last decade, eight or nine species of weeds have
rapidly evolved resistance to Roundup in herbicide-resistant crop fields. Indeed,
Roundup resistance in weeds has been known since 2000, when Roundup resistant
horseweed, a weed species that had not been previously resistant to Roundup, was
discovered in Roundup Ready crop fields in Delaware.
While scientists have validated what farmers were discovering in their fields, the nation’s
lead regulator of genetically engineered crops, the U.S. Department of Agriculture, has
been looking the other way. Every time a pesticide company petitioned USDA to
deregulate a new herbicide tolerant variety of crop, USDA determined that the
introduction of the new crop would have “no significant impact” on the farming
environment. But recently, the Department’s indifference to the indirect consequences of
their deregulation of Roundup resistant crops has caught the attention of two federal
district court judges. They independently struck down USDA’s deregulation of Roundup
Ready Alfalfa and Roundup Ready Sugar beets. They found USDA to have
unreasonably and arbitrarily dismissed the environmental consequences of deregulating
genetically engineered crops. In one instance, the judge found that USDA could produce
no written record that it had ever even considered the impact on farmers.
Nevertheless, Roundup resistant weeds are hurting farmers. They are imposing a billion
dollars in additional weed control costs. They threaten cotton growing so profoundly that
they have been compared to the boll weevil. And the solution may be worse than the
problem. To combat Roundup resistant weed proliferation, the pesticide industry
recommends to farmers that they use more and more toxic pesticides, on newly
engineered crops that will be tolerant of those more toxic pesticides. That will surely
5
lead to more pollution and, as we shall see, the collateral damage of crop destruction and
even more costs on farmers.
In today’s hearing, we will show that USDA’s passivity lies in stark contrast to EPA’s
active approach in preventing pest resistance to genetically engineered crops it regulates.
We will show that USDA’s legal authority is no less broad than EPA’s legal authority.
However, USDA views its broad authority much too narrowly, while EPA views its
broad authority appropriately.
Which approach has a better track record? Passive and self-constrained, USDA’s
approach has plainly allowed the proliferation of herbicide resistant weeds. In contrast,
EPA’s record of prevention is a relative success.
Perhaps we are at a crossroads for USDA’s policy of passivity toward
superweeds. Having been reversed by two federal courts, with scores of farmers needing
relief from the costs and consequences of superweeds, and with a new administration
determining policy at the Department, it may finally be time for the Department of
Agriculture to reexamine its approach to the regulation of genetically engineered crops
and to make a change in policy.
It should be a change that would help prevent the proliferation of herbicide
resistant weeds.
It should be a change that would preserve efficacy of a relatively benign
herbicide.
It should be a change that would de-escalate the trend to more and more toxic
pesticides.
It should be a change that would pass muster with federal courts.
It should be a change that would protect the long term interests of farmers,
consumers and the natural environment.
6
Mr. Towns. I want to thank you, first of all, for holding this
hearing. I want to thank the witnesses for being here. And I know
that you realize the importance of it because the Congress is not
even in session, and of course this hearing is still taking place be-
cause of the importance of it. And of course, I want to just thank
my colleague for moving forward with it because, let’s face it, this
is a very, very important hearing and I think that sometimes we
forget all about it in terms of how important it is in terms of farm-
ing and something that we sort of pushed aside.
I think it was Mr. Louis Perry, a cotton grower in Georgia whose
family has been farming since 1830, told a reporter that herbicide
resistant pigweed posed a lethal threat to cotton farming in Geor-
gia. I mean, it talks about in terms of how important it is, so if
we don’t whip this thing, it’s going to be like the boll weevil as it
was pointed out. Of course, we have to make certain that we stay
on top of it and stay focused.
I want to thank the gentleman who comes from an urban area
that understands how important this is and spending time and fo-
cusing on it. So I want to let you know that from the full committee
standpoint, we stand ready to support you in every way, but I’m
happy to know that you’re getting the message out, because it’s im-
portant that we do so.
So again, thank you for taking time to be here even when the
House is not in session, because you felt it was important to con-
tinue without cancellation and I want to salute you for that. Thank
you and I yield back.
Mr. Kucinich. Thank you very much for being here, Mr. Chair-
man. I want you to know that — well, it’s true that I’m in a pri-
marily urban area. There are a few small farms in the southern
part of my district. But I became aware of this, in part, through
meeting with farmers across the country during the time that I
was campaigning nationally for the Democratic nomination. So I
have had the chance to actually be on farms, talk to farmers about
their concerns about the issues that are raised in this hearing
today.
There are no additional opening statements, so our subcommittee
is going to receive testimony from the witnesses before us today.
I would like to start by introducing our panel. The Honorable Ann
Wright, Deputy Under Secretary for marketing and regulatory pro-
grams at the U.S. Department of Agriculture. Previously, she
served as senior policy advisor to Senate Majority Leader Harry
Reid, on Agriculture Committee matters. Before joining the staff of
Senator Reid, she was a lobbyist for Consumer’s Union on energy
and trade issues. Previously she worked with farmers and non-
profit organizations at the Sustainable Agriculture Coalition in
Washington, DC, and served as a policy advisor on agriculture
issues for Senator Paul Wellstone of Minnesota and Senator Paul
Simon of Illinois.
Mr. Sid Abel, is the assistant deputy administrator for bio-
technology regulatory service with the U.S. Department of Agri-
culture’s Animal and Plant Health Inspection Service. In this role,
he helps provide oversight of risk-based introductions of regulated
genetically engineered biotechnology crops, as well as conducting
7
and providing oversight of broad environmental risk and impact as-
sessments complaint with the National Environmental Policy Act.
Prior to this, he served as the associate director with the U.S.
Environmental Protection Agency’s Office of Pesticide Programs.
He worked for the EPA in various capacities from 1989 to 2007.
Mr. Abel will not deliver testimony, but will be available to answer
subcommittee members’ questions.
The Honorable James J. Jones is the principal deputy assistant
administrator of the EPA’s Office of Chemical Safety and Pollution
Prevention. He is responsible for managing the day-to-day oper-
ations of the office, which implements the Nation’s pesticide toxic
chemical and pollution prevention laws. The Office has an annual
budget of over $260 million, more than 1,200 employees. Erom
2003 to 2007 Mr. Jones served as a director of the office of pesticide
programs. In this role he was responsible for the regulation of pes-
ticides in the United States with a budget of approximately $150
million and 815 employees, making it the largest EPA head-
quarters program office. I want to thank each of the witnesses for
appearing before the subcommittee.
It is the policy of our Committee on Oversight and Government
Reform to swear in all witnesses before they testify. Now Mr. Able,
even though you’re not making an opening statement. I’m going to
ask if you would agree to be sworn because your answers to your
questions will put your testimony on the record. And I would ask
that all the witnesses rise.
[Witnesses sworn.]
Mr. Kucinich. Let the record reflect that each of the witnesses
has answered in the affirmative.
I ask that each witness give an oral summary of his or her testi-
mony to keep the summary under 5 minutes in duration. Your
complete written statement is going to be included in the record.
So what we want in 5 minutes is to try to get a sense of what you
want to communicate to this committee. I would like to begin with
Ann Wright, the first witness on the panel, please begin.
STATEMENTS OF ANN WRIGHT, DEPUTY UNDER SECRETARY,
U.S. DEPARTMENT OF AGRICULTURE; SID ABEL, ASSISTANT
DEPUTY ADMINISTRATOR, BIOTECHNOLOGY REGULATORY
SERVICE, ANIMAL AND PLANT HEALTH INSPECTION SERV-
ICE, U.S. DEPARTMENT OF AGRICULTURE; AND JIM JONES,
DEPUTY ASSISTANT ADMINISTRATOR, OFFICE OF CHEMICAL
SAFETY AND POLLUTION PREVENTION, U.S. ENVIRON-
MENTAL PROTECTION AGENCY
STATEMENT OF ANN WRIGHT
Ms. Wright. Thank you, Mr. Chairman and Mr. Chairman. I ap-
preciate the opportunity to be here today to discuss USDA’s bio-
technology regulatory programs and the issue of herbicide-resistant
weeds. First, I would like to emphasize that at USDA, we support
all forms of agriculture, including conventional, genetically engi-
neered and organic crops to meet the Nation’s and world’s needs
for security, energy production and the economic sustainability of
farms. All three of those methods of production must be strong and
viable. As the world population increases, the demand for food is
8
growing and the land available to farm is shrinking. We need inno-
vative agriculture production systems to not only to maintain the
competitiveness of the United States, but also to fulfill growing
food needs. Biotechnology is just one tool to address those needs,
but it’s a critical one.
USDA’s role in regulating the products of biotechnology is carried
out in coordination with EPA and FDA. Through the Plant Protec-
tion Act, our animal, plant health inspection service regulates
those products that may pose a plant pest risk, while EPA and
FDA use their authorities to address the safety of our food supply
and the safe use of pesticides.
USDA’s biotechnology regulatory program, which has been in
place since 1986, is rigorous and science based. Since the program
began we have effectively overseen nearly 30,000 field trials at
86,000 locations and deregulated over 75 products. While our cur-
rent biotechnology regulations have been effective in insuring the
safe introduction of GE organisms, we are constantly learning from
our experiences, reforming and refining our first rate program to
protect American agriculture and the environment.
As part of those refinements, we are always looking at ways to
improve our program. Chief among these is our effort to update our
biotechnology regulations. USDA is examining the policy issue
raised in over 66,000 comments that were submitted on our pro-
posed regulations, with the goal of better positioning the agency to
address new challenges while meeting current needs. Our bio-
technology program has evolved as the number of environmental
issues to be considered under NEPA has grown as well as in re-
sponse to several NEPA-related lawsuits.
At the same time, it’s important to remember that we have made
thousands of regulatory decisions without legal challenge, and just
as important, not one of our plant pest risk determinations have
been overturned in court.
You also asked me to discuss how USDA approaches herbicide-
resistant weeds in relation to GE crops. A key point is that while
the consideration of the herbicide resistance in weeds under NEPA
informs our decisionmaking, and we are fully committed to meeting
our NEPA obligations, USDA’s biotechnology regulatory decisions
are ultimately based on plant pest risk, consistent with our author-
ity under the Plant Protection Act.
It is also important to note that the development of herbicide re-
sistance among weeds is natural and an evolutionary process. It is
not exclusively associated with GE crops, and that GE crops pro-
vide many benefits, such as reduced pesticide use and decreased
soil erosion thanks to no till farming. And we want to preserve
those benefits.
We must also be cognizant that if we limit the use of herbicide
tolerant crops, farmers will likely have to return to older, less envi-
ronmentally friendly weed control methods.
Because herbicide resistance is an important issue for the agri-
cultural community, USDA has multiple agencies engaged on the
issue through research and education, as well as partnerships with
outside groups and other Federal agencies. For instance, our Na-
tional Institutes of Food and Agriculture’s Competitive Grants Pro-
9
gram provided $4.6 million in 2009 research for the biology of
weedy invasive species.
Further NIFA’s extension outreach programs provide the connec-
tion between scientific research and its application on farms, the
training sessions, field days and other outreach to growers.
USDA’s Agricultural Research Service has nearly $4.4 million in
herbicide resistant weed research in fiscal year 2010, which is part
of $36 million it’s dedicating to all weed science issues this year.
And APHIS is partnered with the EPA and the Weed Science Soci-
ety of America to better understand the extent of herbicide resist-
ance in managed ecosystems as well as the methods being used to
manage herbicide resistance in weeds.
We are fully committed to working with our partners to identify
potential solutions and alternative techniques to address herbicide
resistance. This will require a coordinated effort by everyone in-
volved, the government. Congress, researchers, the agricultural
community, technology and crop protection companies, and public
interest groups. At USDA, we are looking at the broader context
of herbicide resistance beyond just its relation to biotechnology. We
look forward to working with our partners, including all in Con-
gress. Together we are confident that we can find solutions that
make sense.
Mr. Chairman, Mr. Chairman, thank you again for the oppor-
tunity to testify. I look forward to answering your questions.
[The prepared statement of Ms. Wright follows:]
10
Testimony of Ms. Ann Wright
Deputy Under Secretary for Marketing and Regulatory Programs
United States Department of Agriculture
Before the Subcommittee on Domestic Policy
of the
House Committee on Oversight and Government Reform
September 30, 2010
Thank you for the opportunity to be here today to discuss the U.S. Department of Agriculture’s
(USDA) biotechnology regulatory program, as well as the issue of herbicide resistant weeds. 1
am Ann Wright, Deputy Under Secretary of Marketing and Regulatory Programs. In this
capacity, I oversee a broad array of issues within three USDA agencies, including the Animal
and Plant Health Inspection Service (APHIS), which, among other things, regulates organisms
derived through biotechnology. Additionally, several other USDA agencies are looking at
herbicide resistant weed issues and I look forward to updating you on those efforts. Sidney Abel,
Assistant Deputy Administrator of APHIS’ Biotechnology Regulatory Services program, is
joining me today.
First I would like to emphasize that at USDA, we support all forms of agriculture — conventional
(including the use of genetically engineered (GE) products) and organic — to meet the nation’s
and the world’s need for food security, energy production, and the economic sustainability of
farms. As the world’s population increases, the demand for food is growing and the land
available to farm is shrinking. Innovation in agricultural production systems is vital to maintain
the competitiveness of the U.S. agricultural sector and to help supply the world’s food needs.
This is why USDA is pursuing policies that promote the coexistence of conventional, organic,
and GE crops. USDA believes that our future food security necessitates that all types of
agriculture be able to coexist and thrive.
At the same time, it is critical that we ensure our regulatory oversight is consistent, effective, and
science-based, that we are keeping pace with the latest scientific developments, and that we do
so transparently. As you know, the Plant Protection Act authorizes USDA, through APHIS, to
regulate the importation, interstate movement, and safe field testing of GE organisms that may
pose a pest risk to plants. In regulating the products of biotechnology, APHIS works closely
with the U.S. Food and Drug Administration and the U.S. Environmental Protection Agency
(EPA). Together, we ensure that the development, testing, and use of the products of
biotechnology occur in a manner that is safe for plant and animal health, human health, and the
environment.
In March 2008, APHIS Administrator Cindy Smith updated this Subcommittee on a number of
actions the Agency had taken to build a strong program for regulating the products of
biotechnology. This included the development of more detailed environmental analyses,
increased oversight of pharmaceutical and industrial crops, and the creation of a dedicated staff
for compliance and enforcement. Today 1 would like to update you on more recent initiatives
1
11
that we are undertaking with our biotechnology regulatory program, as well as discuss activities
we are undertaking to address herbicide resistant weeds.
USDA’s Biotechnology Regulatory Program - A Constant Evolution
USDA’s biotechnology regulatory program has been in place since 1986, and as I mentioned, we
continue to evolve as the field of biotechnology grows and changes. Over time, we have
developed a tramework for regulating the products of biotechnology that is rigorous and science-
based, and which serves as a model globally that encourages the safe and unimpeded trade in
these products. Since the program began, APHIS has effectively overseen the safe adoption of
products of biotechnology, with 26,000 field trials grown under our notification procedures and
3,000 field tests grown imder the permitting process, encompassing field trials at 86,000 different
locations. In addition, we have deregulated over 75 products in that time. While our current
biotechnology regulations have been effective in ensuring the safe introduction of GE organisms,
we’re constantly learning from our experiences, reforming, and refining our first-rate program to
protect American agriculture and the environment.
The broadest of these efforts is a comprehensive update to our current biotechnology
regulations — to better position APHIS to address new challenges, as well as meet current needs
in evaluating and addressing the plant pest or noxious weed risks associated with regulated GE
organisms. We accepted public comments on the proposed regulatory changes for over 6 months
and held 5 public meetings, resulting in over 66,000 public comments by the time the comment
period closed last June. Many important policy issues were raised, and USDA’s policymakers
are currently examining those issues to determine how to proceed. Ultimately, we want to
advance a rule that will continue to support innovation in biotechnology in a responsible way
that provides farmers and consumers with safe and beneficial options.
In addition to our larger effort to improve our biotechnology regulations, we have made other
changes to keep pace with innovation in this growing field. We have welcomed the critical looks
taken by the Government Accountability Office and USDA’s Inspector General, and have made
improvements to our regulatory program consistent with their recommendations. We have
addressed the majority of recommendations — many which were in line with ongoing Agency
initiatives at the time — through efforts such as requiring additional information on field trials and
enhancing tracking of inspections and field test reports.
Additionally, the 2008 Fann Bill included recommendations that APHIS had made and begun
implementing in late 2007 to improve the management and oversight of regulated biotechnology
products. A number of those recommendations are addressed in our proposed revisions to our
biotechnology regulations. Others are ongoing, such as our partnership with the Association of
Official Seed Certifying Agencies to examine isolation distances for field trials.
The Farm Bill also directed APHIS to take steps to ensure the quality and completeness of
records and to develop standards for quality management and effective research. These and
other issues are being addressed tlirough our expanding Biotechnology Quality Management
System (BQMS) Program — a voluntary compliance assistance program — to help biotechnology
researchers and companies develop plans and manage their operations to comply with USDA’s
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12
biotechnology regulatory requirements. The program provides participating organizations with
improved management capabilities for regulated activities, and requires internal as well as
independent third-party audits to make sure that the quality management system is being
followed at all levels of the organization. In 2009, five organizations representing large and
small companies and university researchers participated in the BQMS pilot program and helped
APHIS refine the program. We are now preparing to implement the refined BQMS program and
are soliciting additional organizations to join. We are encouraging broad participation from large
and small companies and academic research communities. We are also finalizing the BQMS
audit standards and program requirements and have begun training our second cohort of
participating organizations.
APHIS’ biotechnology program has also evolved as more varied environmental issues have
arisen that should be considered under the National Environmental Policy Act (NEPA), as well
as in response to several NEPA-related lawsuits on APHIS regulatory decisions. However, it is
important to point out that we’ve made thousands of regulatory decisions without legal
challenge, and none of our plant pest determinations have been overturned in court. We have
taken these decisions and built into our program process improvements to ensure that we fully
document information pertaining to environmental issues so that we meet all environmental
requirements.
We have also taken and continue to take other steps to improve the environmental review
process within our biotechnology regulatory program. For example. Secretary Vilsack approved
a reorganization of APHIS’ biotechnology staff that includes the establishment of a new NEPA
team that is devoted to preparing high-quality environmental documents to better inform our
regulatory decisions.
As we move forward with making future reviews of the potential environmental issues
associated with the regulatory requests before the Agency, APHIS will continue to use the best
available scientific information, data, and expert advice to prepare the appropriate level of NEPA
analysis. We consider each regulatory action on a case-by-case basis, in accordance with
Council on Environmental Quality (CEQ) NEPA implementing regulations and the USDA and
APHIS NEPA regulations and procedures. And we will continue to consult with EPA on our
analyses related to requests to remove products from regulation, which currently include GE
alfalfa and sugar beets. In these ongoing consultations, EPA provides valuable feedback to the
Agency on its analysis and proposed alternatives. And we are receiving a positive response to
our efforts — EPA, in a letter on our draft environmental impact statement (EIS) for alfalfa,
indicated no objection to APHIS’ determination to grant non-regulated status and rated the draft
EIS as “Lack of Objections,” which indicates EPA had no concerns regarding APHIS’
determination.
Herbicide Resistance - Issues, Challenges, and USDA’s Role
At USDA, we recognize that herbicide resistant weeds pose an important challenge. You’ve
asked me to speak to the Subcommittee today about how USDA approaches this issue in relation
to the regulation of GE crops. I’d like to lay out this relationship, and then discuss how we’re
looking at herbicide resistance more broadly within USDA.
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13
First, the development of herbicide resistance among weeds is a natural and evolutionary
process. Many weed species evolved resistance to a wide variety of herbicides long before the
advent of GE crops, resulting from the common use of herbicides in agriculture for decades.
This is not a new concern for agriculture and is not exclusively associated with GE crops. Any
time an herbicide or any other weed control tactic is used continually — whether with GE or non-
GE crops — it is going to put pressure on weeds to develop resistance. USDA understands that
growers are being challenged by these issues, and that they’re looking for guidance and
assistance. And we want to help, which is why we have a number of initiatives underway that
I’ll mention shortly.
Second, we are committed to meeting our obligations under NEPA and are committed to
performing the appropriate NEPA environmental reviews and seeking the views of the public on
these issues. However, while the consideration of herbicide resistance in weeds under the NEPA
process informs our decision making, USDA decisions on the regulation of GE crops are
ultimately based on plant pest risk, consistent with our authority under the Plant Protection Act
(PPA). Relatedly, I would like to clarify, in response to two questions the Subcommittee has
asked me to discuss, that, because our regulatory decisions are ultimately based on plant pest risk
under the PPA, 1) Herbicide resistance in weeds is not being addressed in APHIS’ proposed
revisions to its biotechnology regulations and, 2) APHIS has not considered alternatives to full
deregulation of a GE product in order to address herbicide resistant weeds, because there must be
a plant pest risk to deny a full deregulation, and herbicide resistance does not constitute a plant
pest risk.
Third, as policy considerations are made, we must be cognizant not to lose the many benefits of
GE crops, such as overall reduced pesticide use, increased use by farmers of less damaging
pesticides, and decreased soil erosion due to increased use of no-till fanning. According to the
National Research Council’s 2010 report. The Impact of Genetically Engineered Crops on Farm.
Sustainability in the United States:
For GE farmers, the general increase in yield, reduction in some input costs,
improvement in pest control, increase in personal safety, and time management benefits
have generally outweighed the additional costs of seed. The use of [herbicide resistant]
crops. ..has generally improved weed control... improved farmers ' incomes by saving time
thus facilitating more off-farm work or providing more management time on the farm.
Additionally, advances in biotechnology have provided farmers with safe, environmentally
friendly tools for feeding our country and the world. If we limit the use of herbicide tolerant
crops, fanners will likely have to return to older, often costly, and less environmentally-friendly
weed control methods. At the same time, we are mindful of the economic impact on farmers
caused by herbicide resistant weeds. This is why, as I’ll discuss next, we are investing in
research on solutions to this growing issue.
Multiple USDA agencies are engaged in addressing herbicide resistant weeds through research,
education, and partnerships with other Departments and outside groups. USDA’s National
Institute of Food and Agriculture (NIFA) supports research, education, and extension programs
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14
in the Land-Grant University System and other partner organizations. In 2009, NIFA relaunched
its competitive grants program as the Agriculture and Food Research Initiative (AFRI), and
offered $4.6 million in the Biology of Weedy Invasive Species in Agroecosystems program area.
In 2010, NIFA restructured AFRI to be more responsive to important national issues. Of the five
societal challenge areas scientists receiving grants will work under, weed science is included in
both Climate Change and Global Food Security, and can also be addressed under the Sustainable
Bioenergy Production focus area.
Providing the connection between the results of scientific studies and their actual application on
farms is key to addressing herbicide resistance among crops derived through conventional
methods and biotechnology. This is why NIFA supports Extension outreach programs to
actively disseminate research findings to agricultural producers who could benefit fi'om new
knowledge about the management of herbicide resistance. For example, Extension weed
scientists along with Extension integrated pest management and pesticide safety education
specialists regularly discuss the issue of herbicide resistance management during training
sessions and field day activities with growers, NIFA is also supporting the development of a
web-based training system, called IPM^, which offers training in a wide variety of topics related
to integrated pest management (IPM). IPM^ offers a weed module that includes herbicide
resistance issues and management strategies. Anyone who completes this training will have a
good understanding of weed biology and science-based management strategies that will reduce
the potential for the development of herbicide resistance.
USDA’s principal in-house research agency, the Agricultural Research Service (ARS) is funding
nearly $4.4 million in herbicide resistant weed research in FY 2010, which is part of ARS’ $36
million research effort this year on all weed science issues. I will briefly mention just two of the
research projects underway. First, scientists at ARS’ Crop Production Systems Research Unit in
Stoneville, MS, are conducting studies on the development and management of herbicide-
resistant weeds. The studies will examine the mode-of-action of herbicides and mechanisms of
resistance, the reproduction and spread of weeds, and the development of integrated weed
management teclmiques, in order to develop strategies for sustainable management of existing
herbicide-resistant weed populations and to prevent future incursions. Second, scientists at the
Natural Products Utilization Research Unit in University, MS, are conducting studies to discover
natural product-based chemistries in order to provide new tools to control weeds resistant to
current herbicides.
Additionally, APHIS has partnered with the Weed Science Society of America (WSSA) to
identify methods being used to manage the spread and development of herbicide resistance in
weeds, assess their effectiveness and degree of adoption, understand the reason for adoption or
non-acceptance, and identify what can be done to increase the use of integrated resistance
management programs. WSSA also recently completed a project for APHIS, in coordination
with EPA, to understand the extent of herbicide resistance in managed ecosystems.
While these are just a few examples of USDA’s efforts to address herbicide resistant weeds, we
are committed to continuing to work with our partners to identify potential solutions and
alternative techniques and technologies to address this important issue. This is going to require a
coordinated effort by everyone involved — the government, researchers, the agricultural
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15
community, technology and crop protection companies, and public interest groups, to name a
few.
Moving Forward with Addressing Biotechnology in USDA
Biotechnology is a critical tool in addressing important global issues, including food security,
biomass production, sustainability, and climate change. USDA continues to be committed to a
strong, science-based regulatory system that ensures that the products of biotechnology are safe
for agriculture and the environment, food, and feed. At the same time, we continue to see the
direct results that the benefits that biotechnology can offer.
With that in mind, we are working to maintain rigorous polices and regulations that ensure
product safety. We are also working to ensure that our policies and regulations keep pace with
new technologies as they develop. And we want to develop and implement policies that promote
the coexistence of genetically engineered, conventional, and organic crops, to help meet the
agricultural challenges and consumer needs of the 21st century. Products produced through
biotechnology will continue to be an important part of U.S. agriculture, and USDA has a
complex and critical role in protecting consumers, the environment, and the farm economy while
also contributing to global food needs.
Herbicide resistant weed development is not wholly a biotechnology issue, and we at USDA are
looking at it in a much broader context to determine how everyone involved with this issue can
evolve to address this challenge. Our agricultural producers are a resilient group, and we are
confident that together, we can find sound solutions that make sense.
Thank you for the opportunity to testify today. I’d be happy to answer any questions.
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16
Mr. KuciNICH. Thank you. Mr. Jones.
STATEMENT OF JIM JONES
Mr. Jones. Good afternoon, Chairman Kucinich, Chairman
Towns. I am pleased to appear before you today to discuss the En-
vironmental Protection Agency’s regulation of transgenic B.t. crops,
as well as EPA’s involvement with the U.S. Department of Agri-
culture and their assessments of the environmental impact of her-
bicide-tolerant crops and herbicide-resistant weeds.
Under the coordinated framework for the regulation of bio-
technology, EPA regulates products produced through bio-
technology that are intended to have a pesticidal effect under its
authorities under the Federal Insecticide, Fungicide and
Rodenticide Act, and the Federal, Food, Drug and Cosmetic Act.
EPA first registered a transgenic B.t. crop in 1995. Over the past
15 years, B.t. crops have substantially reduced the need for grow-
ers to apply older, more risky conventional chemical pesticides to
corn and cotton crops. Because sprayable B.t. formulations are nat-
urally derived organic pesticides, they are very important to or-
ganic farmers. Given the importance of this technology to organic
agricultural as well as the favorable environmental profile of B.t.
as a pesticide, EPA has, from the very beginning of its regulation
of transgenic B.t. crops, required registrants to market these prod-
ucts with specific mandatory insect-resistant management require-
ments.
EPA would consider the development of insect resistance to B.t.
toxins to constitute and adverse effect on the environment. These
IRM requirements have evolved as the science has evolved, and we
have altered and tailored the IRM requirements to match the latest
and most relevant scientific data and information.
The USDA regulates genetically engineered herbicide-tolerant
crops, while EPA regulates the herbicides used on these crops. In
order to coordinate our reviews in 2001, the agencies developed a
Memorandum of Understanding that outlined the Agency’s respec-
tive roles. In 2007, responding to increases in reported cases of re-
sistance, EPA and USDA held discussions on the extent to which
herbicide-resistant weeds were occurring in the herbicide-tolerant
crops. As a result of these discussions, the EPA and USDA initi-
ated a project with the Weed Science Society of America to develop
a comprehensive manuscript to better understand the scope of her-
bicide resistance in genetically engineered, and non genetically en-
gineered cropping systems. The report is due later this year.
As glyphosate-resistant weeds have become more widespread in
herbicide-tolerant crops, technology providers and users have be-
come more open to efforts to address herbicide-resistant weeds. The
support for resistance management from technology providers and
users has spurred the development of strategies to prevent or man-
age herbicide-resistant weeds in herbicide-tolerant crops.
EPA and USDA are working with researchers and professional
societies to expand resistance management education and promote
research aimed at increasing the understanding of the best prac-
tices and strategies for preventing and managing herbicide-tolerant
weeds. EPA is also working with pesticide registrants encouraging
them to include mechanism of action information on herbicide la-
17
bels. This information is critical to the implementation of resist-
ance management plans, which typically involve rotation of two
herbicides with different mechanism of action as a proven strategy
for preventing or delaying development of resistance.
Recently, EPA and USDA have reinvigorated our efforts in this
area to promote resistance management in herbicide-tolerant crops
and preserve this valuable technology. We look forward to working
with this committee, our fellow agencies, our stakeholders in the
public, to ensure an environmentally and economically healthy
country for all Americans. Thank you, and I’d be pleased to answer
any questions.
[The prepared statement of Mr. Jones follows:]
18
TESTIMONY OF
JIM JONES
DEPUTY ASSISTANT ADMINISTRATOR FOR
CHEMICAL SAFETY AND POLLUTION PREVENTION
U.S. ENVIRONMENTAL PROTECTION AGENCY
BEFORE THE
DOMESTIC POLICY SUBCOMMITTEE
OVERSIGHT AND GOVERNMENT REFORM COMMITTEE
UNITED STATES HOUSE OF REPRESENTATIVES
September 30, 2010
Introduction
Good afternoon Chairman Kucinich, Ranking Member Jordan, and Members of
the Committee. I am pleased to appear before you today to discuss the Environmental
Protection Agency's (EPA) regulation of transgenic Bacillus thuringiensis (B.t.) crops. I
welcome the opportunity to participate on this panel and explain the steps that EPA has
taken to forestall the development of insect resistance to these important crops. Further, I
look forward to discussing EPA’s involvement with the U.S. Department of Agriculture
in their assessments of the environmental impacts of herbicide tolerant crops and
herbicide resistant weeds. EPA provided technical expertise to USDA to assist in the
development of herbicide stewardship plans. More recently, as USDA has engaged in
analysis of these crops under the National Environmental Policy Act (NEPA), EPA is
expanding its support to USDA in its environmental analyses.
19
The Coordinated Framework and NEPA
EPA and USDA share responsibility, along with FDA, for regulating agricultural
biotechnology. The Coordinated Framework for the Regulation of Biotechnology,
released in 1986, describes each agency’s role and sets forth a comprehensive scheme for
federal regulation of biotechnology. The basic framework was that the products of
biotechnology were to be regulated under existing statutory authorities and in a manner
similar to products produced by means other than biotechnology. Thus, EPA regulates
products produced through biotechnology that are intended to have a pesticidal effect
under its authority under the Federal Insecticide, Fungicide, and Rodenticide Act
(FIFRA) and the sections of the Federal Food, Drug, and Cosmetic Act (FFDCA)
applicable to residues of pesticides in food and feed.
Under the Plant Protection Act, USDA's Animal and Plant Health Inspection
Service (APHIS) regulates the introduction of organisms altered or produced through
genetic engineering that are plant pests, may be plant pests, or may be related to plant
pests. APHIS has procedures whereby a person may petition APHIS for a determination
that an otherwise regulated article does not pose a plant risk and should not be regulated.
USDA recently completed a NEPA analysis of glyphosate-tolerant alfalfa and EPA
provided comments on the sections of that Environmental Impact Statement that discuss
development of resistance. EPA is also providing support to USDA on an EIS for
glyphosate-tolerant sugarbeet that is under development. EPA stands ready to provide
whatever additional assistance may be needed in the future.
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EPA's Regulation of B.t. Plant Incorporated Protectants
EPA first registered a transgenic B.t. crop product in 1995. Over the past fifteen
years, B.t. crops have substantially reduced the need for growers to apply older, more
risky conventional chemical pesticides to com and cotton crops. As B.t. crops now
comprise over 60% of planted com acreage, and over 90% of planted cotton acreage, the
decreasing usage of more risky pesticides has significantly reduced health risks to farm
workers. Also as a condition of B.t. com and cotton registrations, EPA required that
registrants conduct field surveys to assess biodiversity in B.t. crop fields compared to
non-B.t. crop fields.
Those data, along with independent assessments published in the scientific
literature, have conclusively demonstrated that there is significantly greater insect
biodiversity in B.t. crop fields compared to fields treated with conventional pesticides.
Because sprayable B.t. formulations are naturally derived organic pesticides, they are
very important to organic farmers and organic agricultural production in general. Given
the importance of this technology to organic agriculture, EPA has, from the very
beginning of its regulation of transgenic B.t. crops, addressed the potential issue of
resistance by requiring that B.t. crop registrants market these products with specific
mandatory insect resistance management (IRM) requirements. These requirements have
evolved as the science has evolved, and we have altered and tailored the IRM
requirements to match the latest and most relevant scientific data and information.
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EPA's development of a regulatory scheme for plant incorporated protectants
(PIPs) began in the 1980s. EPA held public meetings with the Agency's Biotechnology
Safety Advisory Committee (BSAC), the FIFRA Scientific Advisory Panel (SAP), the
Office of Pesticide Programs Pesticide Program Dialogue Committee (PPDC), and
numerous public meetings and workshops with interested stakeholders. Through this
long process of stakeholder consultation and external scientific peer review, EPA
developed a rigorous and robust regulatory approach to PIPs that was based on the most
up to date science. From the very beginning, it was clear that developing methodologies
and approaches to forestall the development of insect resistance should be a major focus
of the Agency in its regulation of B.t. crops. EPA has regularly met with the SAP on
IRM issues, and, as the IRM requirements have evolved on the basis of new data and
inforaiation, the SAP has provided key input into these regulatory developments.
To address the potential of insect resistance to B.t. proteins, EPA has imposed
IRM requirements on registered B.t. PIPs. EPA would consider the development of
insects resistant to B.t. toxins as a result of unmitigated exposure to PIPs to constitute an
adverse effect on the environment. EPA's strategy to address insect resistance to B.t. is
two fold: (1) mitigate any significant potential for pest resistance development in the
field by instituting IRM plans; and (2) continually investigate and understand better the
mechanisms behind pest resistance. Initially, IRM plans incorporating “refuges”
(portions of the crop that did not produce and were not treated with B.t.) were determined
on a case by case basis using data submitted with each application. As a consequence.
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IRM requirements varied from product to product. In 2000, based upon input from the
SAP, and working with the National Com Growers Association and other groups, EPA
imposed across the board IRM requirements of a 20 percent refuge for B.t. com and a 5
percent refuge for B.t. cotton.
The baseline 20 percent refuge for com and 5 percent refuge for cotton held for a
number of years until more complex products were developed and supporting scientific
data indicated that it was appropriate to alter these requirements. For B.t. cotton,
registrants developed "pyramided" products that contained more than one B.t. protein
efficacious against a specific pest ("stacked" products contain B.t. toxins efficacious
against more than one pest). By targeting the pest with independently acting toxins, the
likelihood of resistance developing to either toxin was substantially decreased, and it
became possible for EPA to decrease the percentage of refuge crop required for a
pyramided crop.
Also, registrants developed data demonstrating that in many cotton producing
areas, non-cotton plants that are food sources for cotton pests often surround, or are close
by cotton fields. In effect, in these areas, the cotton fields are surrounded by "natural"
refuges.
These large alternative sources of habitat for cotton pests, combined with
pyramided B.t. cotton products, precluded the need for growers to plant refuges for those
products. Thus, for pyramided B.t cotton products planted from Maryland to Kansas,
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there are no refuge requirements. Those same products planted outside of these areas
maintain the requirement for planted refuges. Similarly for B.t. com, new products are
being developed that support refuge requirements different from the baseline 20 percent
com refuge. Registrants have developed pyramided com products that require refuges of
5 percent or 10 percent non-B.t. com seed. Also, registrants are developing products that
incorporate refuge seed in the same seed bag as the B.t. com seed, such that when
planted, an in field refuge is automatically put in place. To date, there have been no
confirmed instances of B.t. resistant pests appearing in the field in the Continental United
States. We will maintain our diligent approach to forestalling potential resistance to B.t.
crops.
In addition to requiring that registrants require purchasers of their products to
plant crop refuges, EPA mandates that registrants monitor for resistant insects emerging
during the growing season as an important early warning sign of resistance developing in
the field and a check as to whether IRM strategies are working. Grower participation,
e.g., reports of unexpected damage, is a critical component of such monitoring.
Resistance monitoring is also important because it provides validation of biological
parameters used in models. In 2000, the SAP concluded that resistance monitoring
programs should be peer reviewed and used to assess the success of IRM plans. EPA’s
Office of Research and Development, National Risk Management Research Laboratory
and Office of Pesticide Programs held a small expert group workshop in July, 2001, that
provided guidance on insect resistance monitoring plan design and detection techniques
for B.t. com.
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EPA and USDA Cooperation on Herbicide Resistance Concerns
USDA regulates genetically engineered herbicide-tolerant crops, while EPA
regulates the herbicides used on these crops. Recognizing the need for EPA and
USDA/ APHIS to coordinate their reviews, the agencies developed a Memorandum of
Understanding (MOU) in 2001 outlining a process for improved communication and
information-sharing to facilitate better coordination of regulatory activities between the
two agencies. Under the MOU, USDA was to request that each petition for "deregulated"
status include a voluntary stewardship plan for the management of herbicide resistance,
and then consult with EPA as to the viability of the stewardship plan during its
environmental assessment.
To implement relevant portions of the MOU, USDA and EPA developed a draft
document to assist applicants in the preparation of voluntary resistance management
stewardship plans to be submitted with petitions for nonregulated status of herbicide-
tolerant (HT) crops, and with applications to EPA to register herbicides intended to be
used on HT crops. Initial efforts by EPA and USDA to implement the provisions of the
MOU were met, however, with resistance from both users, pesticide registrants, and the
technology providers. At that time, the development of resistance in weeds as a result of
the use of HT crops was not widely documented in the scientific literature, nor was it
viewed as a significant problem by these stakeholders, who considered the economic
costs of developing and implementing a stewardship program unnecessary.
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25
In 2007, responding to increases in reported cases of resistance, EPA and USDA
held discussions on the extent to which herbicide resistant weeds were occurring in
herbicide tolerant crops. As a result of these discussions, EPA and USDA initiated a
project with the Weed Science Society of America (WSSA) to develop a comprehensive
manuscript to better understand the scope of herbicide resistance in genetically
engineered and nongenetically engineered cropping systems. This report is due later this
year.
As glyphosate resistant weeds have become more widespread in HT crops,
technology providers and users have become less resistant to efforts to address herbicide
resistant weeds. The support for resistance management from technology providers and
users has spurred the development of strategies to prevent or manage herbicide resistant
weeds in HT crops. More recently, EPA has provided comments on the section of
USDA's EIS that discuss the development of resistance as a result of the deregulation of
glyphosate-tolerant alfalfa.
EPA and USDA are working with researchers and professional societies,
including the Weed Science Society of America (WSSA), to expand resistance
management education and promote research aimed at increasing understanding of the
best practices and strategies for preventing and managing HT weeds in HT crops. EPA is
also working with pesticide registrants, encouraging them to include mechanism of action
information on herbicide labels. This information is critical to the implementation of
resistance management plans, which typically involve rotation to herbicides with a
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26
different mechanism of action as a proven strategy for preventing or delaying
development of resistance.
There has been much attention given to the best way to delay or prevent the
development of pesticide resistance to pests in general, beyond resistance in weeds in
glyphosate-tolerant crops. Professional scientific societies, e.g., the Weed Science
Society of America, the Entomological Society and the American Phytopathology
Society, as well as Resistance Action Committees (composed of technical staff from
pesticide producers) have been involved in identifying ways to accomplish this goal.
EPA has been in discussion with each of these groups to obtain their input on how to
incorporate guidance on resistance management on pesticide labels.
Additionally, EPA has been collaborating with its NAFTA partners (The Pest
Management Regulatory Authority (PMRA) of Canada and Cicoplafest of Mexico) to
develop harmonized approaches to resistance management language on pesticide labels
EPA has and continues to encourage pesticide registrants to include mechanism of action
information on pesticide labels to better inform growers and other pesticide users of one
proven strategy for preventing or delaying development of resistance.
In summary, the early efforts by EPA and USDA to implement the resistance
management provisions of the 2001 MOU were hindered by the lack of interest and
support from the technology providers and user community. Recently, however, with the
support of these sectors, EPA and USDA have reinvigorated their efforts in this area,
9
27
working collaboratively to promote resistance management in HT crops and preserve this
valuable technology.
We look forward to continuing our work with this Committee, our fellow
agencies, our stakeholders, and the public to ensure an environmentally and economically
healthier country for all Americans.
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Mr. Kucinich. Thank you very much. I would like to begin the
first round of questions with Ms. Wright. As you know, the USDA,
since they began deregulating Roundup-Ready Corn, Soy And cot-
ton, among other genetically engineered herbicide-resistant crops
in the late 1990’s, weed scientists estimate that there are up to 11
million acres of American farmland, and a dozen species of weeds
that have evolved to be resistant to Roundup herbicide. The result
for farmers has been greatly increased cost of weed management,
and a probable loss of Roundup as an efficacious weed control
chemical in large parts of the country. Is it the position of the
USDA that it could not regulate genetically engineered herbicide-
resistant crops in order to prevent this spread of herbicide-resistant
weeds?
Ms. Wright. Mr. Chairman, USDA recognizes the development
of herbicide-resistant weeds across the board.
Mr. Kucinich. What does that mean?
Ms. Wright. It means that we recognize it as probably the No.
1 issue for farmers and ranchers whether they are raising crops
using biotechnology, or organic, or conventional seed. I think we
have a number of ways that we’re looking at this through our ac-
tive and dedicated research programs that are looking at critical
national priorities like the sustainable production of bioenergy cli-
mate change, global food security. We continue to see this issue as
critical to farmers bottom lines.
And right now, we have confidence in a science-based process
that regulates in and around our plant protection authorities, our
statutory commitments are to that act.
Mr. Kucinich. Well, you know, that’s very interesting, but the
question that I asked is, is it your position that the USDA could
not regulate genetically engineered herbicide-resistant crops in
order to prevent the spread of herbicide-resistant weeds?
Ms. Wright. That’s correct. Our statutory authority allows us to
make regulatory decisions based on plant pest risk.
Mr. Kucinich. Tell me more about that.
Ms. Wright. Well, what I can tell you is that the plant pest risk
is determined by — well. I’m going to let
Mr. Kucinich. Let me go to Mr. Jones a minute. Mr. Jones, the
EPA has taken a different position. EPA believed that it could reg-
ulate one genetically engineered plant variety in particular, those
containing the B.t. or the Bacillus thuringiensis gene in order to
prevent the development of pest resistance to B.t.; is that correct?
Mr. Jones. That’s correct. We’re operating under a different stat-
ute, in this case, FIFRA.
Mr. Kucinich. Mr. Jones, I understand the EPA’s been regulat-
ing B.t. crops to prevent pest resistance for about 15 years. Is there
a problem with B.t. resistance in this country comparable to the
problem of Roundup resistance in weeds?
Mr. Jones. There is not.
Mr. Kucinich. Pardon?
Mr. Jones. No, there is not.
Mr. Kucinich. Are there 11 million acres of B.t. resistant farm-
land right now?
Mr. Jones. We’re not aware of resistance yet
29
Mr. Kucinich. How many acres of American farmland has been
infested with B.t. resistant pests?
Mr. Jones. We’re not aware of any. It doesn’t mean there isn’t
some.
Mr. Kucinich. Well, is B.t. still an efficacious pesticide in the
United States?
Mr. Jones. It is.
Mr. Kucinich. Does it concern EPA to learn that weed resistance
to Roundup is now widely prevalent?
Mr. Jones. Yes.
Mr. Kucinich. If so, why?
Mr. Jones. Glyphosate to Roundup is — has a very favorable, as
you mentioned in your opening remarks, environmental profile.
And so it’s a compound that we think it’s in the interests of the
environment to have a long commercial life.
Mr. Kucinich. So your saying that it’s because the glyphosate is
relatively benign?
Mr. Jones. It has a very favorable environmental profile.
Mr. Kucinich. Ms. Wright, 11 million acres of infested farmland,
$1 billion in added weed control costs to farmers. The loss of effi-
cacy for a relatively benign pesticide in many places, these are
some of the consequences of the USDA’s position that it could not
regulate Roundup Ready crops to prevent the evolution of resistant
weeds.
Now, Ms. Wright, you say in your written testimony, “There
must be a plant pest risk to deny a full deregulation. An herbicide
resistance does not constitute a plant pest risk.” Now I’m question-
ing your legal interpretation as to whether it’s well-founded. Your
position is that the sum total of the USDA’s authority derives from
section 411 of the Plant Protection Act which gives the Secretary
authority to prevent the introduction of plant pests.
But that is not the sum total. The very next section of the act,
section 412, covers your authority to prevent the spread of, “Nox-
ious weeds.” Section 412 “gives the Secretary authority to prohibit
or restrict . . . the movement ... of any plant ... if the Sec-
retary determines that the prohibition or restriction is necessary to
prevent . . . the dissemination of a . . . noxious weed within the
United States,” from the statute. Now “noxious weeds” are defined
by the statute at 7 U.S.C. section 7702 as, “Any plant or plant
product that can directly or indirectly injure or cause damage to
crops or . . . other interests of agriculture ... or the environ-
ment.”
Ms. Wright, a plain reading of section 412 gives the Secretary
the broad authority to restrict the use of Roundup-resistant crops
if sound science determines that those restrictions are necessary to
prevent the spread of Roundup-resistant noxious weeds. How can
you come to Congress and insist that effectively that section 412
doesn’t even exist?
Ms. Wright. Well, first let me say that this USDA is very com-
mitted to looking at all of our programs and policies, and ensuring
that they are there for all forms of agriculture
Mr. Kucinich. I know you’re not — this is your first time before
a committee.
Ms. Wright. It is.
30
Mr. Kucinich. And I do appreciate your being here. I asked you
a question, and I would like an answer. That was not responsive.
Ms. Wright. We interpret our existing authorities as those fo-
cused on plant pest risk. Back in March 2009, we issued a set of
updates to our rules and regulations that expanded our authorities
into the Noxious Weed Act. We’re now looking at 66,000 comments
on those rule updates. This is a new administration, we will be tak-
ing a close look at the full range of comments that came in and be
looking very carefully at where our authorities are.
Mr. Kucinich. Are you familiar with section 412 of the act?
Ms. Wright. No, sir.
Mr. Kucinich. You’re really not? Before the end of this hearing,
I would like staff to have a copy made of section 412 of the act and
provide it to the witness, because if the regulatory agency is not
fully familiar with the extent of its authority, it may be one of the
difficulties we’re having here.
Ms. Wright. I think the Agency is probably very familiar, but I
personally am not, and I’m sorry.
Mr. Kucinich. Well, I can understand that it is a new adminis-
tration, and that you’re new, and you do have a very good reputa-
tion where you come from. But I think it’s important that you be-
come familiarized with the act and with the sections that I articu-
late, particularly section 412, which actually does change the role
of your agency and your office to effectively regulate herbicide-re-
sistant weeds. If you — I’ll take you at your word that you’re not fa-
miliar with it.
But what I glean from that, since you are not familiar with it,
you can’t point to any provision of the Plant Protection Act that
would deny the USD A the ability to use the authority of the section
to prevent the spread of Roundup-resistant weeds.
I think it’s clear from your testimony that the USDA’s position
is not too much a legal judgment as is a statement of policy. And
that it’s been the policy of the USD A not to use the authority that
it does have under section 412, it’s just very clear. I just want to
make this statement to you as the chairman of this oversight sub-
committee that a plain reading of section 412 makes it obvious that
if the Agency wants to become involved in the enforcement of her-
bicide-resistant weeds, that it could do it, that you do have the
statutory authority to do it, and that it’s a policy question.
Now you may not be the person who makes the final call on that,
but somebody all the way up to — the ladder at Agriculture is mak-
ing that call, and this subcommittee’s determined to see the statute
enforced.
Now, Ms. Wright I know that the Department understands at
this point, that the problem of superweeds is a crisis. What I don’t
understand, and what defies comprehension is this: That the De-
partment does have the legal ability to help farmers deal with the
crisis, and to prevent it from worsening, and that the USDA has
not made a policy, a decision to use this authority or has made a
policy decision not to use it. Do you have anything further that you
can tell this subcommittee? You will read the statute?
Ms. Wright. Thank you. Yes, I promise to fully read the statute
and I would like to say — and thank you for the opportunity to ad-
dress this problem and to address the entire issue of coexistence.
31
We’re going to have to have a full slate of partners at the table
looking at this, including Congress, as well as technical service pro-
viders, other Federal agencies, regulated entities and public inter-
est groups. And together, I think, we will be able to solve this prob-
lem, including growers, it’s not one that — as well as the markets,
it’s not one that exclusively rests on our shoulders.
Mr. Kucinich. Ms. Wright, I want to draw attention to the De-
partment’s view that it currently has authority to regulate future
planting of GE crops through administrative action. The Depart-
ment outlined three such actions in a court filing from July of this
year. I move to insert into the record the fourth declaration of the
APHIS administrator Cindy Smith.
[The information referred to follows:]
32
Case3:08-cv-00484-JSW Document554 Filed07/15/10 Pagel of 7
UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION
CENTER FOR FOOD SAFETY, et ai, ) Case No.: 3:08-cv-00484-JSW
)
Plaintiffs, )
)
vs. )
)
)
TOMVILSACK,e/af., )
)
Defendants, )
)
and )
)
MONSANTO COMPANY; SYNGENTA )
SEEDS, INC.; AMERICAN SUGARBEET )
GROWERS ASS’N, et al,: BETA SEED, INC.; )
and SESVANDERHAVE USA, INC., )
)
Defendant-Intervenors, )
)
FOURTH DECLARATION OF CINDY SMITH
I, Cindy Smith, do hereby declare as follows:
1 . I make the following statements based on my personal knowledge and experience as
well as upon facts made known to me in my capacity as the Administrator of the Animal and
Plant Health Inspection Service (APHIS), United States Department of Agriculture (USDA).
2. I previously provided declarations on February 12, May 7, and June 18, 2010.
3. I am providing this declaration to respond to the Court’s June 24, 2010 Order
requiring APHIS to address the Supreme Court’s statement in Monsanto Co. v. Geertson Seed
Fourth Declaration of Cindy Smith
Page 1
33
Case3:08-cv-00484-JSW Document554 Filed07/15/10 Page2of7
Farms . U.S. , 2010 WL 2471057, at *15 (2010), regarding the effect of an immediate
♦
vacatur of APHIS’ determination of nonregulated status.
4. If the determination of nonregulated status on Roundup Ready sugar beets (RRSB) is
vacated and the vacatur would go into effect immediately, RRSB would again be a regulated
article under 7 C.F.R. Part 340 and the Plant Protection Act (PPA). As a regulated article, RRSB
could neither be planted nor moved interstate without approval from APHIS. However, a new
deregulation decision, whether in whole or in part, is not the only means for APHIS to approve
future planting (release into the environment) and/or interstate movement of the regulated RRSB.
5. There are several administrative actions under the authority of the PPA and/or Part
340 that APHIS could take to allow the planting and/or interstate movement of regulated RRSB.
a. First, APHIS has the authority to allow the planting of RRSB as a
regulated article under permit. Permitting is the regulatory scheme under Part 340.
Permits are issued after appropriate NEPA analysis. The type of NEPA documentation
needed will affect the timing of the issuance of the permit.
b. Second, APHIS may either revise the Part 340 regulations or issue a new
rule, after notice and comment, in order to allow the APHIS Administrator to use her
discretion to allow the planting of RRSB under a revised or new regulatory scheme
pursuant to PPA statutory authority. (7 U.S.C. §§ 771 1, 7712, 7714, and 7754). If
APHIS revises Part 340 or issues a new rule to allow the Administrator the discretion to
impose a different regulatory scheme than is currently employed under Part 340, such as
the use of general permits, administrative orders or other PPA authority, APHIS would
conduct the appropriate NEPA analysis prior to taking any regulatory action provided for
by the rule change.
Fourth Declaration of Cindy Smith
Page 2
34
Case3:08-cv-00484-JSW Document554 Filed07/15/10 Page3of7
c. Third, the PPA provides APHIS with the authority to issue orders as the
Secretary considers necessary to carry out the PPA. (7 U.S.C. § 7754). Prior to the
issuance of such an order, APHIS would conduct the appropriate NEPA analysis and
prepare the appropriate documentation, which will affect the timing of such an order.
6. The PPA prohibits the importation, entry, export, or movement (including release into
the environment) of a plant pest unless the movement is authorized under a general or specific
permit and is in accordance with such regulations as the Secretary may issue to prevent the
introduction into or dissemination within the United States of a plant pest. 7 U.S.C. § 771 1(a).
APHIS currently allows the movement of genetically engineered regulated articles under a
permitting scheme, using specific permits and notifications. Notification is a form of permit.
APHIS reviewed its permitting process under Part 340 and in 1995 (60 Federal Register 6000)
determined that permits and notifications complied with and satisfied the categorical exclusion
requirements set forth in APHIS’s NEPA implementing regulations. (7 C.F.R. §372.5(c)(3)(ii)).
Prior to the deregulation of RRSB in 2005, RRSB was a regulated article which was allowed to
be planted and grown under notification.
7. APHIS has overseen numerous field trials under Part 340. At least 142 of the
authorizations since 2006 were for crops ranging from just over 1000 acres to 20,000 acres. The
field trials were overseen by APHIS through inspections and/or third party inspections and
auditing. APHIS ensures that every permit is inspected by APHIS staff or by a qualified
independent third party inspector.
8. As I declared both in my second and third declarations, I respectfully proposed that
the Court order a remand without vacatur until May 31, 2012, and impose the specific interim
measures that I described in detail in paragraphs 44-45 of my second declaration pending
Fourth Declaration of Cindy Smith
Page 3
35
Case3:08-cv-00484-JSW Document554 Filed07/15/10 Page4of7
completion of the RRSB Environmental Impact Statement (EIS). (Second Smith Decl. at 44-
45, Third Smith Decl, at f 5). Such court-imposed measures would provide certainty for farmers
of the RRSB seed and root crops that APHIS action, which is subject to challenge, cannot
provide. In the alternative, if the Court is inclined to immediately vacate and remand APHIS’S
determination of non-regulated status of RRSB, I respectfully requested that the Court stay its
vacatur of APHIS’s Determination of Non-Regulated Status for RRSB until March 1, 201 1, to
allow APHIS adequate time to establish appropriate interim regulatory measures to deal with all
regulated RRSB until completion of the RRSB EIS. (Third Smith Decl. at | 6). If the Court is
inclined to vacate APHIS’s determination and remand but is not inclined to stay the vacatur imtil
March 1, 2011, I respectfully requested that the Court, at the very least, stay the vacatur with
respect to all RRSB in the United States currently planted as of the date of the Court’s order.
Such an order would prevent significant harm to the thousands of farmers that have currently
planted RRSB in the United States and would prevent significant harm and disruption to sugar
beet sugar supplies and prices. (|d. at f 8).
9. If there is an immediate vacatur and remand, the following RRSB activities would
either be taking place on the Court’s August 13, 2010 hearing date or be imminent: (1) the
harvest and interstate movement of the 2009-2010 seed crop from the fields to seed processing
plants which is expected to occur between July and October 2010; (2) the interstate movement of
the 2009-2010 seed crop harvested between July and October 2010, from processing plants along
the sales chain (i.e. to distributors and individual growers), which is expected to take place from
November 2010 to March 2011; (3) the planting of the 2010-201 1 seed crop which is expected to
take place as early as July 2010, and is likely to be completed by the end of September 2010; and
Fourth Declaration of Cindy Smith
Page 4
36
Case3:08-cv-00484-JSW Document554 Filed07/15/10 PageSofZ
(4) the harvest and interstate movement of the 2010 root crop from field to sugar processing
plants which is expected to take place from September 2010 to December 2010.
10. If the vacatur does not apply to any RRSB crop that has been planted as of the date
of a vacatur, only new plantings after that date and other releases into the environment (e.g.
flowering of the seed crop) would require the agency’s approval. The planting of the 2010-201 1
seed crop is the only activity that is imminent and would require immediate regulatory action by
APHIS.
11. If permits for new plantings of the 20 1 0-20 1 1 RRSB seed crop were to be requested
by Interveners seed companies after vacatur, APHIS has the authority to issue permits solely for
the planting of RRSB seed crop under a categorical exclusion as currently provided for under
Part 340, provided that APHIS determines that none of the exceptions to the categorical
exclusion applies. However, such permits for the planting of the RRSB seed crop would still
take some time, possibly up to a month before they could be issued. The time needed to issue
such permits could likely prevent certain seed growers from any further planting of the RRSB
seed crop after vacatur, depending on factors such as the date by which they must complete their
seed planting. It would be expected that any permits APHIS may issue in time for the planting
of the 2010-201 1 RRSB seed crop could allow planting but would not allow flowering, which
would not be expected to occur until approximately May 2011. To address the flowering stage
of the RRSB seed crop, APHIS may, after preparing an EA, issue a new permit or an amended
pemiit under Part 340 or under other regulatory mechanisms (as described in paragraph 5 above),
APHIS has considerable experience with the issuance of permits that do not allow flowering and
with the issuance of permits that only allow flowering under strict conditions. An EA for new or
Fourth Declaration of Cindy Smith
Page 5
37
Case3:08-cv-00484-JSW Document554 Filed07/15/10 Page6of7
amended permits that would allow flowering of the RRSB seed crop would be expected to be
completed by March 1,2011.
APHIS could also use its authority under the PPA to issue a federal order to address
imminent RRSB activity after the appropriate NEPA analysis and documentation is prepared,
APHIS is currently considering how such authority to issue orders might be used,
12. In addition to the immediate activities related to regulating RRSB (both seed and root
crops) in the United States as described above, the following are additional planting or interstate
movement RRSB activities that would occur prior to the time when APHIS completes its RRSB
EIS and that would require APHIS approval, if requests for such production actions were made;
(1) the planting of the 201 1 root crop which is expected to take place between April and July
201 1 and the interstate movement of this 201 1 harvested root crop, which is expected between
September and December 2011; (2) the harvest and interstate movement of the 2010-2011 seed
crop, planted after vacatur, from the fields to the processing plants, which is expected to occur
between July and October 20 1 1 ; (3) the interstate movement of 2010-201 1 seed crop, planted
after vacatur, from processing plants along the sales chain (i.e., to distributors and individual
growers), which is expected to take place from November 201 1 to March 201 2; (4) the planting
of the 2011-2012 seed crop which is expected to occur between July and September 201 1; and
(5) the planting of the 2012 root crop which is expected to occur between April and July 2012.
With regard to these production activities, if requests for such production actions were made,
APHIS could use any of the authorities as described in paragraph five above to allow the
activities under PPA regulation with the appropriate NEPA analysis and documentation.
13. APHIS has the authority pursuant to 7 C.F.R. § 340.6 to approve a petition for
determination of nonregulated status in whole or in part. If APHIS were to receive a new
Fourth Declaration of Cindy Smith
Page 6
38
Case3:08-cv-00484-JSW Document554 Filed07/15/10 Page/ of 7
petition or a supplement or amendment to a previous petition for a determination of nonregulated
status of RRSB, APHIS could consider granting that petition in whole or in part. Depending
upon the specific petition and its complexity, if APHIS were to approve such a petition, APHIS
anticipates that it could take at least until March 1, 201 1, to complete the appropriate NEPA
analysis and documentation and the appropriate plant pest risk assessment.
Cindy J. Smith, APHIS Administrator
ISSSS
Fourth Declaration of Cindy Smith
Page 7
39
Mr. Kucinich. My question, Ms. Wright, is this: Is it also the De-
partment’s view that it could, by means of any of those administra-
tive actions, place requirements on a permitted planning of GE her-
bicide-tolerant crops to prevent the proliferation of herbicide-resist-
ant weeds.
Ms. Wright. In both the case of GE alfalfa as well as GE sugar
beets there are currently formal petitions before the agency for us
to look at ways to partially deregulate these.
Mr. Kucinich. So that’s a yes?
Ms. Wright. We’re in the process of looking at that.
Mr. Kucinich. So that’s a yes?
Ms. Wright. So the industry has come to us and asked us to look
at that options.
Mr. Kucinich. So is this consistent with the testimony that has
been given in court?
Ms. Wright. Yes.
Mr. Kucinich. You found expansive authority to devise three ad-
ministrative actions allowing to you approve large scale planting
under a permit system. What is the basis? Do you have
Ms. Wright. No, sir. The industry came to us and asked us to
look at partial deregulation as one way to allow the planting of a
GE crop.
Mr. Kucinich. Are you talking about the cases that were struck
down by Federal district courts?
Ms. Wright. Yes, sir.
Mr. Kucinich. That was at the request of the industry, right?
Ms. Wright. Yes.
Mr. Kucinich. OK. What’s the — I’m still trying to figure out the
basis for your view here today that a permit system which the GE
crop would remain a regulated article and nevertheless not permit
to you to place requirement on planting and preventing the spread
of Roundup resistance in weeds.
Ms. Wright. Unless we determined there a plant pest risk, we
do not have it that expansive authority.
Mr. Kucinich. So you’re still stuck on one section of the act and
haven’t read the other.
Ms. Wright, isn’t it true that the Department has had under de-
velopment, a new biotechnology rule and that the rule was also
under development during the previous administration?
Ms. Wright. Yes.
Mr. Kucinich. OK. And with the change in administration, can
this Congress expect to see any differences in the Department’s ap-
proach to herbicide-resistant weeds and the rule you’re now work-
ing on.
Ms. Wright. I can tell you that we’re having internal discussions
about our policies, and around coexistence, and that we just hon-
estly cannot afford to look at options and alternatives that are not
supportive of various cropping systems, including biotechnology, or-
ganic and conventional. They all play a very critical role in the
health of our rural economy and in our agricultural economy.
Mr. Kucinich. I know that was in your opening statement. I
heard that. But it’s not responsive to the question I asked.
Ms. Wright. Can you ask your question again? Will you please
restate your question?
40
Mr. Kucinich. There has been a change in administrations, can
we expect to see any difference in the Department’s approach to
herbicide-resistant weeds in the rule that you’re now working on?
Ms. Wright. I think we’re looking at all — a lot of options, and
we’re going back and looking, considering the comments that were
submitted. We’re internally having discussions across the Depart-
ment. We have a Secretary and an administration that’s very com-
mitted to the idea of addressing the issues of coexistence, and
that’s as much as I can say today.
Mr. Kucinich. See the thing that I’m concerned about — and I am
really trying to give you the benefit of the doubt on what you’re
saying, the thing that I’m concerned about, is that when you go
back to your talking points, you actually inadvertently shut the
door on consideration of the science and experience that’s been
brought forward through the EPA’s enforcement through the prac-
tical experience of farmers, through the NRC report. And so I’m
trying to — ^because it’s important that we understand — ^you’ve made
it clear that the policy, you know, what the policy is, you haven’t
extended that to a legal interpretation, but if you’re just saying
well, you know, we have different ways of supporting agriculture,
we’re going to try to support them all.
But if you rest on that and don’t go deeply into expressing to this
subcommittee a concern that the extent to which herbicide-resist-
ant weeds may represent an attack on the rights of farmers, the
economic rights of farmers, the environment, if you don’t articulate
that, it causes me to pause.
Ms. Wright. Well — out of all due respect, I would say that it’s
not that we don’t recognize this as a bottom line issue for farmers
and ranchers
Mr. Kucinich. It’s what?
Ms. Wright. It’s not that we don’t recognize this as a critical
issue for farmers and ranchers, but I think this administration and
USD A see biotechnology as being a very important tool for farmers
to use in addressing some very critical issues, globally and here do-
mestically. And all of the options that we look at have to be sup-
portive of that, they have to encourage and support innovation in
a smart way.
Mr. Kucinich. Do they look the other way if there is a problem?
Ms. Wright. No, I don’t think so. We take our NEPA process and
documents very seriously. In fact, the Secretary just approved a re-
organization of our BRS services, we have a whole team, a new
team, a whole program dedicated to NEPA now. We have a budget
increase request before Congress for 2011, fiscal year 2011 of $5.8
million to hire new scientists. We take these issues very seriously.
And as we learn more about the environmental impacts of this
technology, we try to adjust and we try to make our rules and regu-
lations.
Mr. Kucinich. Just out of curiosity, you think — genetic — you just
talked about the importance of biotechnology, is it your view, per-
sonally, that genetically engineered crops are the functional equiva-
lent of conventional crops?
Ms. Wright. Well, I’m not prepared to reflect on that.
Mr. Kucinich. OK, that’s fine. For the last couple of decades, the
EPA and the USDA had pledged in various Memoranda of Under-
41
standing to promote integrated pest management. One of the key
objectives of integrated pest management is preserving the efficacy
of relatively benign pesticides and preventing herbicide resistance
in weeds. Now I move to insert into the record one such Memoran-
dum of Understanding from 2001.
Now, to the EPA, I want to address this question, does it concern
the EPA from the perspective of integrated pest management that
more and more acres of farmland are showing signs of infestation
by Roundup-resistant weeds?
Mr. Jones. Yes, it does.
Mr. Kucinich. Now, in general, isn’t proliferation of Roundup-re-
sistant weeds across millions of acres of farmland a setback for in-
tegrated pest management?
Mr. Jones. Sure.
Mr. Kucinich. And to the USDA, does the USDA agree with the
EPA that from the perspective of integrated pest management to
widespread infestation of Roundup-resistant weeds constitutes a
setback?
Ms. Wright. I’m sorry, can you please repeat that?
Mr. Kucinich. Does the USDA agree with the EPA, which just
responded yes, that the proliferation of Roundup-resistant weeds
across millions of acres of farmland is a setback for integrated pest
management. I asked you, do you agree with the EPA from the per-
spective of integrated pest management, the widespread infestation
of Roundup resistance weeds constitutes a setback?
Ms. Wright. Possibly, yes.
Mr. Kucinich. Mr. Jones, in communication with the majority
staff, the EPA has stated that the USDA did solicit EPA’s input in
its Environmental Impact Statement for Roundup Ready Alfalfa,
but as we’ve already seen, the Environmental Impact Statement
will not consider any measures for preventing the spread of Round-
up-resistant weeds.
USDA testified that EPA raised no objection to their draft envi-
ronmental impact strategy on alfalfa, which USDA characterizes as
meaning, “The EPA had no concerns.”
Is that a complete representation of EPA’s comments to USDA
on the Roundup-Ready Alfalfa Environmental Impact Statement?
Mr. Jones. Chairman, to be fair to my colleagues at USDA
Mr. Kucinich. I’m asking you to answer the question, not to be
fair, but to answer the question.
Mr. Jones. The answer to the question is that an Agency’s for-
mal response that went through our office of Federal activities, we
did not raise the issue of insects — I’m sorry, herbicide resistance.
In informal conversations, when we’ve had a number of them, and
they continue to this day.
Mr. Kucinich. So you did raise a concern about weed resistance
management; is that right?
Mr. Jones. That’s correct.
Mr. Kucinich. Now Ms. Wright, this is somewhat at a variance
with your written testimony. And contrary to that, does the USDA
now acknowledge that the EPA did, in fact, express concern about
the weed resistance management issue in the alfalfa Environ-
mental Impact Statement?
Ms. Wright. Yes, we did.
42
Mr. Kucinich. Mr. Jones, did USDA ever ask EPA to offer its ex-
pertise in preventing pest resistance in the context of the USDA’s
preparation of an environmental impact statement for deregulating
GE alfalfa?
Mr. Jones. Once we raise the concerns that we have identified
through informal mechanisms that led to an ongoing dialog be-
tween USDA and EPA to address those, and so
Mr. Kucinich. Did they ask you to offer your expertise?
Mr. Jones. That is correct.
Mr. Kucinich. What did they ask you to do?
Mr. Jones. When we raised our — we raised some issues associ-
ated with resistance management, and as it was characterized in
EIS. And the Department said to us, you’ve raised some very good
points, let’s talk about that, we want to understand this better.
And those conversations continue, as I said, to this day, and I be-
lieve will continue until we feel like we’re on the same page on that
issue.
Mr. Kucinich. Well, given the scientific verification of the rapid
spread of Roundup-resistant weeds, do you think it might be justifi-
able for the EPA and the USDA to revisit the question in prepara-
tion for the final environmental impact statement for Roundup
Ready Alfalfa, Mr. Jones?
Mr. Jones. I believe that’s what we’re doing right now.
Mr. Kucinich. And to Ms. Wright, given the EPA’s successful ef-
fort thus far in preventing the Bacillus thuringiensis resistance in
pests, wouldn’t it make sense for the USDA to want to utilize the
EPA’s expertise to help regulatory means to prevent and mitigate
Roundup resistance in weeds?
Ms. Wright. Yes. And if it’s OK with you. I’d like to ask Sid Abel
to address more of the specifics around how we are working with
EPA.
Mr. Kucinich. He’s sworn, he can do that.
Mr. Abel. We are — right now we’re working very directly at the
staff level with our partners at the EPA to address specifically the
issue of glyphosate tolerance among weeds. We agree, both with
EPA and with other parts of our Eederal partners, that this is a
serious issue for farmers. It’s also a serious issue for the tech-
nology. We see that this is a very favorable compound to be used
in controlling weeds, and to preserve that technology is very impor-
tant to us. So we’ve entered into these discussions with EPA at the
staff level with the Weed Science Society of America, and with oth-
ers, universities and extension agents to get a better handle on the
extent to which glyphosate tolerance is occurring out there, not just
in GE crops, but also in conventional crops. We believe that by
going through this process, we’ll be able to put forward some strat-
egies for managing these crops in a way to preserve these tech-
nologies into the future.
Mr. Kucinich. Have you read section 412 of the act?
Mr. Abel. It has been a while, but yes, sir, I have.
Mr. Kucinich. Would you read it again?
Mr. Abel. Yes, I would.
Mr. Kucinich. I want to thank the members of this panel for
participating in this important discussion. And this committee will
43
continue to retain jurisdiction over this matter, which means that
there will be more hearings.
We are very interested in the policies of the USDA as it affects
the environment, farmers. And I’m grateful for your presence here
today and for the EPA’s continuing work in this area as well.
The first panel is dismissed and I’m going to call the second
panel to come forward, and we will begin the second panel in a cou-
ple of minutes as soon as you’re all in place.
I am going to read the introductions at this moment while staff
is getting set up. I want to welcome to this subcommittee Congress-
woman Diane Watson, Ambassador Watson from California, for
gracing this hearing.
We have here today Mr. Steve Smith. Mr. Smith, welcome. Mr.
Smith is director of agriculture at Red Gold, Inc., the largest pri-
vately-held canned tomato processor in the country. In his position
he works closely with their growers in Indiana, Ohio and Michigan.
He is co-chair for Red Gold’s new sustainability initiative and
serves on the Sysco Corp.’s national sustainability advisory board.
Mr. Smith has served on the Purdue University dean of agriculture
advisory board, the board of directors of the Mid-America Agri-
culture and Horticultural Services, as director of the American
Fruit and Vegetables Processor and Grower’s Coalition, and as an
inaugural member of the Indiana Department of Agriculture advi-
sory board. Thank you for being here.
Dr. Phil Miller currently serves as a vice president in the Mon-
santo Co. He leads the regulatory group which is responsible for
the development of health and safety research on new agricultural
and biotech products, global regulatory approvals, product safety
defense, and management of numerous key scientific and regu-
latory issues. Dr. Miller joined Monsanto in 1994 and has held nu-
merous roles in chemical discovery in biotechnology research and
development. Some key roles include director of biotechnology, crop
enhancement and crop genomics research, and Monsanto’s Sirius
Research Collaboration League.
Thank you for being here, sir.
Next is Mr. Bill Freese who is science policy analyst with the
Center for Food Safety, a D.C. -based nonprofit group. Mr. Freese
has written and lectured extensively on the science regulation and
societal implications of agricultural biotechnology for over a decade.
In 2004 he coauthored a peer-reviewed scientific paper on common
myths about U.S. regulation of genetically engineered crops. Mr.
Freese is a frequently quoted expert on agriculture biotechnology
in the mainstream media as well as the scientific press. He has re-
viewed and critiqued numerous petitions for deregulation of herbi-
cide-resistant crops, the subject of today’s hearing.
Finally, Mr. Jay Vroom, who is president and chief executive offi-
cer of CropLife America, the largest national trade organization
representing developers, manufacturers, formulators, and distribu-
tors of agricultural pesticides across the United States. Mr. Vroom
has held his position since 1989. Previously Mr. Vroom served as
executive vice president and chief executive officer of National Fer-
tilizers Solutions Association in St. Louis, Missouri. He began his
professional career on the staff of the Fertilizer Institute.
44
As with the previous panel, I want to make you aware that it is
the policy of the Committee on Oversight and Government Reform
to swear in all witnesses before they testify. I ask that you gentle-
men rise and raise your right hands.
[Witnesses sworn.]
Mr. Kucinich. Let the record reflect that each of the witnesses
has answered in the affirmative.
I would now ask that each witness give an oral summary of your
testimony. I would ask that you keep the summary under 5 min-
utes. And I remind you that your entire written statement will be
included in the record of the hearing and will be distributed to the
members of this committee as well as to the media. We are going
to begin with Mr. Smith. You are the first witness. I would ask you
to proceed.
STATEMENTS OF STEVE SMITH, DIRECTOR OF AGRICULTURE,
RED GOLD TOMATO; PHIL MILLER, VICE PRESIDENT, GLOB-
AL REGULATORY, MONSANTO CO.; BILL FREESE, SCIENCE
ADVISOR, CENTER FOR FOOD SAFETY; AND JAY VROOM,
CEO, CROPLIFE AMERICA
STATEMENT OF STEVE SMITH
Mr. Smith. Thank you, Chairman Kucinich, and members of the
Domestic Policy Subcommittee. I thank you for the opportunity to
present to you some important concerns about the pending release
of dicamba-resistant soybeans.
My name is Steve Smith, director of agriculture for Red Gold, the
largest privately-held canned tomato processor in the United
States. Red Gold is based in Indiana and has three processing fa-
cilities. Our tomatoes are grown by 54 family farming operations
in Indiana, Ohio, and Michigan.
Our concerns about the upcoming increased use of dicamba are
not just about tomatoes but all fruit and vegetable crops and rural
homeowners living near local farms. The use of dicamba is not new.
It is effective, it is a great weed killer, and it is economical to
apply. So many may be wondering why a product that is effective,
proven, and economical is not the No. 1 herbicide in use today. The
answer is simple: dicamba has also proven itself to move off target
and injure adjoining crops, so it is not currently widely used.
New technology is good and needs to be pursued, but must be ex-
amined for unintended consequences. At one time the conventional
wisdom thought it was a good idea to use lead in paint. The theory
of dicamba-tolerant soybeans might appear sound on the surface —
the ability to kill weeds is proven — but the potential damage to
other sectors of agriculture and rural homeowners demands that
we take a closer look at this particular advance.
When put in the spotlight, the answer will become abundantly
clear: The widespread use of dicamba is incompatible with Mid-
western agriculture, dicamba is highly vulnerable to offsite move-
ment in three forms: direct drift, volatilization, and spray-tank con-
tamination.
You would think that the risk of direct drift could be completely
controlled by good management practices such as spraying in little
or no wind or when the wind was blowing away from sensitive
45
crops such as tomatoes. But unfortunately, that is not always the
case. Red Gold has suffered over $1 million in drift claims over the
last 4 years. A reduced application window has forced otherwise
good farmers to spray on windy days when they know they
shouldn’t.
But I want to focus on volatilization because it is the real issue
that makes dicamba a danger to Midwestern agriculture. Vola-
tilization occurs when the active ingredient evaporates and then
can be moved with the surrounding air mass for up to 4 days after
application; and its killing capabilities can spread up to 2 miles or
more in certain geographic areas such as in a valley.
Even the best farmer, the most conscientious farmers can’t con-
trol or predict what will happen for up to 4 days after application.
Ironically, the very conditions that minimize direct drift actually
maximize volatilization: little or no wind, high temperatures, and
high humidity — normal conditions for when this product is applied
in June and July.
A good neighbor that awakens early in the morning to spray be-
fore the winds pick up would be at the highest risk of causing vola-
tilization injury.
In other testimony offered, we learn that new formulations of
dicamba will reduce the risk of volatilization. We believe those
claims to be overly optimistic as even the newest formulations are
still proven to move off target. It simply is impossible to control or
predict its movement. The science is clear and settled in regard to
dicamba’s susceptibility to off-target movement due to volatilility.
If, as you might hear from others, the risks of off-target move-
ment of dicamba due to volatilization are low and can be controlled
through improved product stewardship and formulations, it only
makes sense that those who will profit from the sale of this seed
technology and the makers of dicamba should willingly step up to
the plate and establish an indemnity fund to cover crop losses and
homeowners’ claims for damages.
If they are unwilling to cover potential losses, is this an admis-
sion that the safety of this technology is not as safe as we have
been led to believe? The Midwest is the home to a unique system
of family farms that are known as the bread basket of the world.
The introduction of dicamba-tolerant soybeans is a classic case of
shortsighted enthusiasm over a new technology, putting this region
at unneeded risk, and blinding us to the reality of damage that is
sure to come.
Even the best, the most conscientious farmers cannot control
where this weed killer will end up. Increased dicamba usage made
possible through the introduction of dicamba-tolerant soybeans is
poor public policy and should not be allowed.
Thank you for the opportunity to present my concerns to you
today. I will be happy to answer any questions you might have con-
cerning this topic.
Mr. KuciNICH. Thank you, Mr. Smith.
[The prepared statement of Mr. Smith follows:]
46
1
Testimony before Congress
Steve Smith
September 30, 2010
Domestic Policy Subcommittee
of
Committee on Oversight and Government Reform
Dennis J. Kucinich, Chairman
Deployment of Dicamba-resistant soybeans and what it will mean to canned and
frozen food processors and specialty crop growers in the Midwest
Thank you Mr, Chairman and members of the Domestic Policy Subcommittee, for the
opportunity to present to you some important concerns about the pending release of Dicamba-
resistant soybeans. My name is Steve Smith, Director of Agriculture for Red Gold, the largest
privately held canned tomato processor in the United States, based in Indiana with three processing
facilities located there. We purchase tomatoes from 54 family farming operations in Indiana, Ohio
and Michigan.
In my capacity at Red Gold, I am privileged to interact with a wide segment of the specialty
crop industry in the Midwest, home to a diverse array of canned and frozen fruit and vegetable
production, as well as local fresh market and organic production marketed directly to local
consumers. A growing wine grape industry has also begun to flourish in Indiana, adding to our
diverse production base. These specialty crop industries are worth 254 million dollars to the State
of Indiana, providing thousands of jobs throughout our state. These groups, and nearly every food
crop represented on the grocers shelves and produce stands, all have an intense interest about the
effects of the widespread use of dicamba and the devastation it will cause to the sensitive crops
grown in our region.
My life experiences include growing up in central Indiana on a traditional family fanning
operation, graduating with distinction from Purdue University in Agriculture and being named a
Distinguished Alumni in 2009, serving as a Regional Sales Manager for a seed com and soybean
47
2
company, holding a Certified Crop Advisor certificate and having 22 years of experience in the
specialty crop industry with Red Gold. I am convinced that In all of my years serving the
agricultural industry, the widespread use of dicamba herbicide possesses the single most
serious threat to the future of the specialty crop industry in the Midwest.
The use of dicamba is not new. It has been a labeled product for use on com for decades. It has
been proven effective for many uses and is not particularly vulnerable to developing resistant strains
of weeds. It is economical to apply.
So many may be wondering why a product that is effective, proven, and economical is not the
number one herbicide in use today. The answer is simple. Dicamba has proven itself to move off-
target and cause injury and yield reductions to soybeans and so in a large sense, it is rarely used.
Farmers respect their neighbors and know they are at risk of causing injury if they use dicamba, so
it is not widely and routinely used in com production. However, when soybeans become tolerant to
dicamba, it is very likely that the amount of dicamba used in com production will skyrocket when
the fear of soybean injury is eliminated. As an example, when glyphosate soybeans were first
introduced, there was significant injury due to drift on com the first few years. It didn’t take long
for applicators and farmers to gain a higher degree of respect for the injury that could occur. But
once the widespread use of glyphosate resistant com became common, that level of caution began
to erode because it didn’t really matter if you drifted onto your neighbor, because their crop was
also glyphosate resistant. I also predict a similar fate for dicamba use once soybeans are made
tolerant. With no fear of soybean injury, the use of dicamba on com acreage will dramatically
increase, raising the overall exposure of sensitive crops to injury. Because dicamba is deadly to
weeds and cheap to use, it is a sure prediction that dicamba use will increase dramatically, followed
by escalating crop losses.
In other testimony offered, you may hear that new formulations of dicamba will reduce the risk
of volatization. Volatization is the process where the active ingredient literally evaporates into the
air and can relocate as the air moves. We believe those claims to be overly optimistic as the
characteristics of this molecule have been well documented for about 50 years, and even the newest
fonnulations are still proven to move off-target.
Some might interpret this testimony to imply that 1 am opposed to advances in technology, and
that progress is not a thing to be pursued. Nothing could be further from the fruth. The
technological progress made in the last twenty years is responsible for us having the world’s safest,
48
3
most nutritious and affordable food supply. Many might suggest that technology has taken us the
wrong direction and is harming our environment and the sustainable nature of agriculture. I would
suggest just the opposite to be true when good stewardship practices are implemented and followed.
Productivity is a good thing. It lifts our standard of living. If Red Gold can produce a nutritious
product for our consumers at a cost they can afford, everyone wins.
However, technological advances need to be critiqued and examined for their overall
contributions and unintended consequences. Just because we can do something doesn’t mean that
we should. At one time, the conventional wisdom thought it was a good idea to use lead in paint.
The theory of dicamba tolerant technology might appear sound on the surface. The ability to kill
weeds is proven. But the potential damage to other sectors of agriculture and rural homeowners
demands that we look further at this particular advance. There may even be geographic areas of the
country where this technology would cause only minimal harm and adequate protective measures
might even be put into place to protect the public’s interest, but definitely not in the Midwest. If
dicamba tolerant soybeans are released onto the market place in the Midwest, they will be used and
cause harm to our traditional cropping system. Anything that has the potential to cause that type of
widespread crop damage should have intense discussion and oversight. When that occurs, the
answer will become abundantly clear. The widespread use of dicamba is incompatible with
Midwestern agricuiture.
Since the introduction of glyphosate resistant crops, the pattern of weed control in the Midwest
has changed from predominantly pre-plant applications of herbicides, to almost entirely a post-
plant, in-season application practice. The effects of this paradigm shift in herbicide applications has
affected our company and family growers in a very negative way, due to the potential for direct
drifting of spray material onto our tomato fields from applications during windy conditions. The
majority of herbicide applications were historically made prior to the planting of most specialty
crops, so the drifting of products caused little or no harm. However, the transformation to herbicide
applications during the growing season in June and July has put drift prevention at the forefront of
concerns to sensitive crop producers of all kinds. Over the last four seasons, our company and
growers have been involved with cropping losses exceeding a million dollars due to glyphosate
drift.
In addition to the financial loss to our growers, Red Gold is placed in considerable risk of
supply disruption due to the drifting of post-applied herbicides. Unlike commercial grain
49
4
production, if our tomatoes are damaged, processing tomatoes are not available to be purchased on
the open market to make up the losses. We suffer from the risk of having inadequate product for
our customers, which could result in the permanent loss of business due to lack of supply. We
willingly have chosen to deal with all the traditional production risks and plan our business to
minimize those risks, but we are helpless to anticipate the cropping losses that occur due to the
misapplication and drift of glyphosate onto our tomatoes. Good stewardship by neighbors and
applicators has been fairly successful in preventing direct drift. Unfortunately, with dicamba
tolerance being added to soybeans, a whole new challenge far more dangerous and unpredictable
than direct drift is knocking on our door.
With glyphosate, crop injuries are the result only from direct drift. Glyphosate is not a volatile
compound that will pick up and move in the days or hours following application. Dicamba on the
other hand, is highly vulnerable to off-site movement in three forms:
1 . Direct drift. Dicamba is readily moved by the wind during application. Direct drift is in
theory, always preventable, by either applying within label restrictions of wind or by
applying when the wind direction would not result in a threat to a sensitive crop.
2. Volatization. Dicamba is proven to volatize, or more simply, for the active ingredient to
evaporate into the air where it is easily moved off-target as the air mass moves. It can move
up to two miles in distance, or even more in certain regions such as down a valley. As
opposed to direct drift, the environmental conditions that effectively minimize drift,
ironically, maximizes the potential for volatilization. Those conditions are high
temperatures and high humidity, conditions that are common during a Midwestern summer
when a post-applied application of dicamba would be most likely. A producer trying to be a
good neighbor, who awakens early so he can spray next to our tomato field before any wind
picks up, actually would be applying the material in the most vulnerable fashion for
volatilization to occur. Because this can occur for up to four days following the initial
application, an applicator cannot adequately take measures to prevent both drift and
volatilization. He is in a no-win situation, as is every sensitive crop within a two or more
mile radius where dicamba would be applied. The science is clear and settled in regard to
dicamba’s susceptibility to off-target movement due to volatility.
3. Spray tank contamination. Dicamba has characteristics that make it extremely hard to get
completely cleaned out of spray tanks following use. Some commercial applicators have
50
5
told me that they refuse to spray dicamba because they risk damaging the crops of their
customers. Even small quantities left in a spray tank will injure crops.
Crop losses caused by direct drift are a violation of label restrictions; however, crop losses
caused by volatization are not a violation of the pesticide label. The weather conditions during the
application are the deciding factors of misapplication, not what happens at a later time. There will
be no recourse for growers or processors for crop losses resulting from volatilization. It is likely
that the source of losses might never even be completely pinpointed because under widespread use,
the problem could have come from a multitude of sources. Our very livelihoods, and those of our
growers, are under severe risk if the widespread use of dicamba is permitted.
The risk of off-target movement is not limited to only tomatoes and other fresh market produce.
Growers of non-dicamba tolerant soybeans will be at risk. Organic producers not only risk the loss
of produce for sale, but also risk their organic certification for three years if off-target movement of
dicamba would occur. Grape and vineyard production is extremely vulnerable and production
could be lost for multiple seasons if a serious off-target movement occurred, This would be
devastating for many of the most vulnerable small farm producers. These are the farms that
produce the fruits and vegetables that become our main weapon in our fight to reduce our national
obesity epidemic.
The nature of the common layouts of Midwestern farms, places all of these sensitive crops in
close proximity to soybean production where dicamba would be used in a widespread manner. But
in addition to the cropping risks posed by the widespread use of dicamba, the desire for country
living environments has driven the trend for home construction out into the countryside. Home
gardens and landscaping would be extremely vulnerable to off-target movements because of their
proximity to the farming areas of the Midwest. In an atmosphere of consumers worried about
where their food comes from and worries of residues from all crop protectants in the food supply,
damage caused by the off-target movement of dicamba would give all of agriculture a black-eye if
home gardens or landscaping were damaged.
If the risks of off-target movement of dicamba due to volatization are low and can be
effectively controlled through product stewardship and fonnulations, it only makes sense that those
who will profit from the sale of this seed technology and the makers of dicamba should willingly
step up to the plate and establish an indemnity fund to cover crop losses and homeowner’s claims
51
6
for damages. If they are unwilling to cover potential losses, is this an admission that the safety of
this technology is not as safe as we would be led to believe?
Agriculture needs to be building up the confidence of producers and consumers instead of
giving them cause for alarm. The Midwest is the home to a unique system of family farms that
have been the breadbasket of world agricultural production. The introduction of dicamba tolerant
soybeans is a classic case of short-sighted enthusiasm over a new technology blinding us to the
reality that is sure to come. Increased dicamba usage, made possible through the introduction
of dicamba tolerant soybeans, is poor public policy and should not be allowed.
Thank you for the opportunity to present my concerns to you today. 1 will be happy to answer
any questions you might have concerning this topic.
52
Mr. Kucinich. Mr. Miller, please proceed.
STATEMENT OF PHIL MILLER
Mr. Miller. Chairman Kucinich and members of the subcommit-
tee, thank you for inviting me to testify on matters relating to mod-
ern agricultural technology.
I work at Monsanto whose only focus is agriculture. I spent much
of my youth in a small agricultural community in Lawrence Coun-
ty, Illinois, where I had the privilege of helping my grandfather on
his farm. I also have a farm in Nebraska. Through my experiences,
I have a great appreciation for what the American farmer has and
can achieve with the right tools and a willingness to adopt new
technologies and practices.
I currently serve as vice president of regulatory, with more than
500 scientists in my organization, and it is responsible for the glob-
al product approval and stewardship.
The topic of today’s hearing is an important one. The world popu-
lation is growing. In the next 40 years or so, there will be 9 billion
people on our planet. That is 3 billion more people that will show
up to the dinner table, and many will want to use the foods we
have grown up with. To put it in context, that is the equivalent of
three more Chinas. The challenge is: How do we do it using fewer
resources?
Farmers are increasingly being asked to produce more with less,
and helping to do this is what Monsanto is all about. Our company
has a commitment to sustainable agriculture. We will do our part
to help farmers double yield in the core crops of corn, cotton, and
soybeans between 2000 and 2030, while producing each bushel or
bale with one-third fewer resources.
Just as important, in doing so we will help farmers earn more,
and improve the lives of their families and rural communities glob-
ally. Agricultural innovation has provided farmers with improved
agronomic practices, advances in breeding, and novel traits through
modern biotechnology, which increases yield and profits.
In 1996, the Roundup Ready system was first introduced into
soybeans. The Roundup Ready system was attractive to farmers be-
cause it offered superior crop safety and the use of a familiar and
proven herbicide that controls more than 300 weeds. In Roundup
Ready Soybeans, glyphosate sprayed after the crop’s weeds emerge
provide a level of weed control and ease of use that surpasses other
options.
Importantly, in addition to the benefits provided in weed control,
the Roundup Ready system has made the adoption of conservation
tillage practices feasible. Conservation tillage contributes to the
long-term sustainability of farming practices.
Before the Roundup Ready system was introduced, the environ-
mental benefits of conservation tillage were documented, but adop-
tion by growers had been limited. The broad enrollment in con-
servation tillage due to the Roundup Ready system has led to the
reduction and extensive plowing and tillage which has significantly
reduced the loss of topsoil due to erosion, improved soil structure,
reduced runoff of sediment and fertilizer, reduced on-farm fuel use,
reduced CO50 emissions, and increased carbon sequestration in the
soil.
53
Controlling weeds is paramount in maintaining and improving
crop productivity. Unlike insects and diseases which occur in some
years and not others, weeds occur in crops every year. Experts rec-
ommend using multiple herbicides to provide more than one mech-
anism of action. Applying multiple mechanisms of action reduces
the likelihood of a resistant weed population developing because
there is a low probability that a particular weed within a popu-
lation would have resistance to both mechanisms of action.
In addition, farmers may choose to use mechanical or cultural
techniques in addition to or in place of herbicides. The specific pro-
gram employed would depend on the farmer’s choice and the best
management practices on his or her farm.
Monsanto has shared interest with farmers in effective weed
management. The proactive adoption of best management practices
based on the principle of diversity in weed management will im-
prove weed control, help ensure that conservation tillage systems
are sustainable, and that the yield, economic, and environmental
benefits are fully realized.
As I stated at the beginning of my remarks, Monsanto’s only
focus is agriculture. If farmers don’t succeed, Monsanto doesn’t suc-
ceed. That is why as we bring new technology to the market, we
value growers’ input, such as Mr. Smith who is here today, who we
have invited and has become a member of our dicamba advisory
council. We are committed to invest and develop seed and trait sys-
tems to provide farmers with effective, affordable, convenient and
sustainable agricultural solutions, including weed control.
Thank you, Mr. Chairman, for your time and attention today. I
look forward to answering your questions.
Mr. KuciNICH. Thank you for your testimony.
[The prepared statement of Mr. Miller follows:]
54
Written Statement of Philip W. Miller on behalf of Monsanto Company
for the September 30, 2010 hearing of the Domestic Policy Subcommittee
of the US House of Representatives Oversight & Government Reform Committee
Chairman Kucinich, Ranking Member Jordan and Members of Subcommittee, thank you for
inviting me to testify on matters relating to modem agricultural technologies.
1 work at Monsanto, a company 100 percent focused on agriculture. We develop improved seed
through advanced breeding as well as biotechnology. We work with others to build cropping
systems that help farmers produce more bountiful harvests on each acre, with plants that can
protect themselves from many pests. We enable weed control within conservation tillage systems
that reduce soil erosion, water loss and carbon emissions.
Using these tools, American farmers reach imparalleled levels of productivity to feed and clothe
more people with every acre. They are driving the U.S. economy, while helping to meet the
demand for food, fuel and fiber that is increasing with global population and income levels.
Our company has a three-pronged commitment to improve sustainable agriculture: We will do
our part to help farmers double yields in our core crops of com, cotton and soybeans between
2000 and 2030, while producing each bushel or bale with one-third fewer resources (such as
land, water and energy) in aggregate. And, just as importantly, in so doing we will help farmers
to earn more and improve the lives of their families and mral communities.
We made this commitment in recognition that we are privileged to work in an amazing industry
- agriculture - that is at the heart of some of our planet’s biggest challenges, ranging from
hunger, malnutrition and rural poverty to land degradation, water scarcity and climate change.
By the end of this day, the world will have 2 1 0,000 more people than the day before who are in
need of food, fiber and fuel from agriculture. Experts have suggested that the requirements of
food production over the next 50 years will exceed the production we have achieved in the past
10,000 years, cumulatively. Irrigated crop production accounts for 40 percent of the world’s
food supply; however, with global water use growing at twice the population rate, farmers are
becoming more challenged to secure enough water for their crops. In the face of these
challenges, the agricultural sector needs to focus on farm management practices and technologies
that can improve productivity while conserving natural resources and minimizing the global
footprint of agriculture. Monsanto is committed to helping fanners become more productive and
sustainable each year.
Agricultural innovation has provided farmers with improved agronomic practices, advances in
crop breeding, and novel traits through modem biotechnology to increase yields and profits.
55
Fanners utilize a wide range of technologies on the farm to maximize yields while minimizing
the risk of crop failure.
Controlling weeds is paramount in maintaining and improving crop productivity. Unlike insects
and diseases, which occur in some years and not others, weeds are ubiquitous. They return every
year from millions of seeds, tubers or rhizomes, deposited in the soil annually from weeds that
survive in the field, fence rows, and irrigation ditches, and spread from field to field on planting,
crop treatment and harvesting machinery.
In the 1930’s, farmers relied on deep plowing and tillage for weed control but excessive tillage
caused devastating soil losses due to wind erosion and run-off. The invention and
commercialization of synthetic chemical herbicides over the past 60 years has offered growers
new tools for controlling weeds.
The herbicide glyphosate, introduced in the early 1970’s, expanded the weed management
options available to farmers. Glyphosate controlled a broad spectrum of weeds more effectively
than combinations of herbicides used previously, resulting in improved weed control for farmers
and improved farm management and profits. However, because glyphosate killed nearly all
leafy green plants, it had to be used in ways so that it did not come into contact with crops.
Glyphosate controls more than 300 annual and perennial grass and broadleaf species, providing
the widest spectrum of control compared to any other herbicide. Fanners quickly recognized the
benefits of glyphosate herbicides.
In 2000, Monsanto’s US patent on glyphosate expired. Today, farmers in the United States have
several choices of generic glyphosate herbicide products. Monsanto continues to sell
Roundup® brand glyphosate herbicide products.
In 1996, the Roundup Ready® system (seeds modified to be tolerant to glyphosate and which
allowed the use of glyphosate for weed control in the crop) was first introduced in soybeans.
The Roundup Ready system was attractive to fanners because it offered superior crop safety, and
the use of a familiar and proven herbicide that was active on a broad spectrum of atmual and
perennial weeds (grasses and broadleaves). In Roundup Ready soybeans, glyphosate sprayed
once or twice in a season after the crops and weeds emerged provided a level of weed control
and ease of use that surpassed other options.
The same was true for glyphosate tolerant com, cotton, and canola that were commercialized in
the late 1990’s. Importantly, in addition to the benefits provided in weed control, the Roundup
Ready system has made the adoption of conservation tillage practices feasible on many more
farms. Conservation tillage contributes to the long-term sustainability of famiing practices.
Before the Roundup Ready system was introduced, the environmental benefits of conservation
56
tillage, including low-till and no-till practices, were documented but adoption by growers had
been limited, in part, because they could not get acceptable weed control without tillage in many
instances. The use of herbicides and in particular glyphosate for weed control instead of
extensive plowing and tillage has significantly reduced the loss of topsoil due to soil erosion,
improved soil structure with higher organic matter, reduced runoff of sediment and fertilizer,
reduced on-farm fuel use, reduced CO 2 emissions, and increased carbon sequestration in soil.
Over the past 20 years, the number of com, soybean and cotton acres in conservation tillage has
nearly doubled to a total of 82 million acres in 2008. Farmers have consistently indicated that
Roundup Ready technology has been a critical innovation allowing them to shift to conservation
tillage. In 2001 , a survey by the American Soybean Association (ASA) of its members revealed
that the adoption of Roundup Ready technology was the primary reason farmers reduced tillage
in soybean production.
The topic of herbicide resistance in weeds is of interest to the Subcommittee. A herbicide
resistant weed will survive an application of a herbicide that will normally kill the weed. Within
a weed population, individual plants with resistance to a particular herbicide and/or herbicide
class can occur naturally. Such biological variability is not caused by use of the herbicide.
Subsequent use of the herbicide merely selects for those plants that already have the resistance.
Weed resistance to herbicides is not new. Guided by continuing research, new strategies to
manage herbicide resistance have been developed and continue to evolve, Monsanto, other
companies, universities, government agencies, and crop commodity groups are working to
provide farmers with the most up-to-date recommendations and to educate them on the
importance of adopting practices to manage herbicide resistance.
There are inherent differences among the herbicide classes. Some herbicide classes are more
prone to resistance than others. The first instance in the United States of a weed being
detennined to have resistance to a herbicide occurred in 1957 when spreading dayflower in
Hawaii was found to be resistant to the herbicide 2,4-D. Although resistant weed populations
have been known for over 50 years, 2,4-D is still widely used around the world and is an
ingredient in products familiar to consumers such as Weed B Gone. The first weed displaying
resistance to glyphosate was annual ryegrass discovered in Australia in 1996. In 1998, ryegrass
resistant to glyphosate was observed in California where glyphosate was being used for weed
control in orchards.
Today there are 19 weed species worldwide with confirmed resistance to glyphosate, 10 of
which are present in the U.S. This compares to 107, 68, and 37 species with confirmed resistance
to the three other major classes of herbicides (ALS inhibitors, PSIl (triazines) and ACCase
inhibitors, respectively) used by many fanners growing soybean, cotton and com in the U.S. As
with glyphosate, farmers continue to use these products because they provide significant value in
57
their weed management programs. As weed resistance occurs, farmers adjust their weed
management practices. The best way to manage weed resistance on a particular farm depends on
the particular circumstances on that farm.
Weed resistance is an herbicide issue, not a biotech crop issue, and is dependent on how
herbicides are used. Under the Federal Insecticide, Fungicide and Rodenticide Act ( FIFRA) and
the Federal Government’s Coordinated Framework for regulating biotechnology-derived
products, EPA is the agency charged with analyzing the potential environmental impacts from
the use of a pesticide. Specifically, EPA must evaluate whether the use of a pesticide in
accordance with instructions on its label will result in “unreasonable adverse effects [to humans
or] the environment.” EPA balances the risks and benefits of pesticide products when applying
this standard to determine whether to register a particular pesticide for a specific use.
Before an herbicide is authorized for a particular use, including over the top of a herbicide-
tolerant crop, EPA must register that use in accordance with FIFRA. Since its introduction in the
1 970’s, EPA has regulated the use of glyphosate and for over fifteen years, EPA has registered
glyphosate for use over the top of Roundup Ready crops.
EPA recognizes and has addressed weed resistance as an issue requiring attention. The Agency
has issued guidance to pesticide registrants concerning weed resistance management information
on pesticide labels. This guidance instructs registrants on information to provide to farmers
regarding the mechanism of action of the herbicide and recommendations on practices to
implement for delaying herbicide resistance. Monsanto follows EPA’s guidance on its
glyphosate labels and goes beyond EPA’s specific guidance in providing recommendations to
farmers.
Monsanto is actively evaluating and reevaluating herbicide resistance in order to refine further
the best proactive management practices. Over the last 5 years Monsanto has invested more than
$30 million dollars in collaboration with academics in the U.S. alone to study developments in
resistance to glyphosate and improve management practices. EPA, USDA-ARS, and others in
industry are also devoting resources to actively address herbicide resistance.
Today there is broad agreement among public and private sector scientists on practices that can
minimize the potential for additional weeds developing resistance to herbicides. These practices
were highlighted in a National Research Council Report issued in April. A summary of these
best management practices is published on the Herbicide Resistance Action Committee (HRAC)
website (www.hracelobal.com l and the Weed Science Society of America (WSSA) website.
Experts recommend using multiple herbicides to provide more than one mechanism of action.
Using multiple mechanisms of action reduces the likelihood of a resistant weed population
developing because there is a low probability that a particular weed within a population would
58
have resistance to both mechanisms of action. In addition, farmers may choose to use
mechanical and/or cultural techniques in addition to, or in place of, herbicides. In many cases a
proactive weed management program, in fields where no resistant weeds are present, will be
identical to the weed control practices that a farmer would employ to control resistant weeds.
The specific program employed will depend on the particular circumstances on that farm.
Even in locations where there are glyphosate resistant weeds, glyphosate continues to provide
significant benefits to farmers and continues to be recommended by academics and extension
agents as a key component in weed management systems. Glyphosate provides a foundation for
economical and effective weed control in a diversified weed management program.
The need for proactive management of weed resistance continues to be addressed in many
diverse venues. Weed scientists have learned from over 30 years of research that there is more
than one way to manage herbicide resistance. University and industry experts believe that the
best way to influence grower behavior is through intensive training and education programs.
Monsanto, university/cooperative extension services, and other companies have devoted
significant time and resources to grower/retailer education and training programs. Other
organizations are also involved. For example the National Association of Conservation Districts
and USDA’s National Resources Conservation Service (NRCS) have brought together weed
scientists and soil conservation officials from the south, southeast and mid-west to explore
opportunities to further expand outreach to farmers on the need to implement best management
practices for weed resistance. As growers are educated, more and more of them are adopting
diverse weed control practices.
The Weed Science Society of America, in particular, has been active in coordinating activities of
the scientific community regarding farmer education programs. Farm publications have also
focused on the issue, raising awareness and serving as a means for public and private sector
scientists to promote best management practices. These efforts are also leading more farmers to
adopt diversified weed management programs on their crop acres.
In addition to farmer education and training about on-fann weed control practices, many
companies are investing in the development of new weed control toots for fanners. At Monsanto,
some specific technologies under development include new formulations of existing herbicide
products and the development of new herbicide tolerant traits for soybeans and cotton plants that
will provide additional options for weed control practices.
For example, Monsanto has been in the process of developing crops tolerant to dicamba because
the ability to use dicamba in the Roundup Ready system would give growers more weed control
options and flexibility. With dicamba tolerant soybean, for instance, the grower has the option tc
use dicamba as an effective weed control treatment prior to planting and can then plant soybeans
without further delay. Furthermore, the ability to use glyphosate and dicamba together
59
throughout the growing season enables growers to manage resistant weeds and improve control
of tough broadleaf weeds.
After more than 40 years of use there are four plant species with populations that are resistant to
dicamba in the U.S. and Canada, and 5 worldwide. Dicamba is a member of the auxin family of
herbicides.
Proper stewardship of dicamba in dicamba tolerant crops is imperative, and includes attention to
guarding against the development of weeds resistant to dicamba and minimizing off-site
movement of dicamba. To address weed resistance, we will continue training growers on the
importance of a diverse weed management program and will only recommend the use of
dicamba in combination with other herbicides. It is well known by scientists and farmers that
off-site movement of pesticides occurs. Monsanto is aware of the concerns regarding the off-site
movement of dicamba and is working with multiple stakeholders to address this issue. We are
also working with other companies to develop improved dicamba formulations that reduce the
potential for off-site movement.
Monsanto has a shared interest with farmers in effective weed management and in conservation
tillage systems that are sustainable. The proactive adoption of best management practices based
on the principle of diversity in weed management will improve weed control, help ensure that
conservation tillage systems are sustainable, and that the economic and environmental benefits
are fully realized. As we educate fanners, more and more are adopting diverse practices.
As I stated at the beginning of these remarks, Monsanto is 1 00% focused on agriculture. If the
fanner doesn’t succeed, Monsanto doesn’t succeed. We are committed to developing seed and
trait systems that provide fanners with effective, affordable, convenient, and sustainable
agricultural solutions, including weed control. We recognize that proactive and diverse weed
management practices arc needed to preserve the benefits of the Roundup Ready system. To
support best practices for sustainable weed management, Monsanto is broadly engaged in
education and outreach efforts. We’re also involved in public and private sector initiatives
committed to sustaining the farmer and environmental benefits of herbicide tolerant crops and
conseiwation tillage systems. And, Monsanto will continue to invest in research to provide our
customers with products and recommendations that make them successful and promote
sustainable agriculture.
60
Mr. Kucinich. Mr. Freese.
STATEMENT OF BILL FREESE
Mr. Freese. Yes. Chairman Kucinich and members of the sub-
committee, thank you for inviting me here today to testify. I would
just like to preference my remarks quickly to respond to something
Ms. Wright and Mr. Miller just said about world hunger and pro-
ductivity.
Actually, the subject here. Roundup Ready crops, do not have
higher yields. That is a myth. It is basically designed to save time
and save labor and help farmers get bigger. Also, there is an in-
crease in pesticide use with these crops, actually quite substantial,
not a decrease. And the conservation tillage benefits that Mr. Mil-
ler mentioned, conservation tillage was mostly adopted before the
introduction of these Roundup Ready crops.
Just as Roundup Ready crops were being introduced in 1997,
Monsanto scientists published a paper in which they presented all
of the reasons weeds were not likely to evolve resistance to
glyphosate. It is not the first time they have been wrong, and they
turned out to be disastrously wrong. As discussed in part 1 of this
hearing in July, unregulated use of these crop systems has trig-
gered an epidemic of glyphosate-resistant weeds, and it fostered
sharp increases in herbicide use, greater use of soil-eroding tillage
operations, and is substantially raising weed control costs for ever-
more growers.
Now Monsanto and other pesticide firms assure us that multiple
herbicide-resistant weeds are the solution to glyphosate-resistant
weeds.
Dupont, for instance, even envisions a single crop resistant to
seven or more different classes of herbicides. There are hundreds
of millions of dollars being invested in resistance genes to just
about every herbicide imaginable, including paraquat, for instance,
and about half of the GE crops pending deregulation at USDA
right now are herbicide-resistant.
We shouldn’t let ourselves be misled again. These new herbicide-
resistant crops are the wrong response to glyphosate-resistant
weeds. Just very briefly, and I can go into detail in questions if you
would like, but one reason is that they simply won’t work. At best
we will get a short-term reprieve until nature cleverly evolves re-
sistance to the new and multiple herbicides deployed against them.
Second, farmers will pay in multiple ways through increasingly
expensive biotech seeds and the multiple herbicide cocktails that
come with them, and through crop damage, as Steve mentioned, or
through purchasing the HR seed in order to defend oneself against
drift.
Third, both public health and the environment will suffer from
a substantially increased use of toxic herbicides such as 2,4-D and
dicamba.
Finally, this new wave of crops diverts attention from truly sus-
tainable weed control practices, which I would like to get to in a
moment.
I think it is very clear that the glyphosate-resistant weed epi-
demic is a symptom of regulatory breakdown. We have USDA
which regulates an herbicide-resistant crop, and the EPA the herbi-
61
cide; but no one regulates the combination, the herbicide-resistant
crop, the herbicide system. And it is the system, the continual use
of a herbicide, glyphosate on Roundup Ready crops, that is respon-
sible for the growing epidemic of resistant weeds. This system has
been presented to farmers as self-contained, two component, seed
and Roundup, and that is the way it has been used. I am tired of
people blaming farmers for this.
When a Federal district court judge reversed APHIS’s deregula-
tion of Roundup Ready alfalfa, he underscored APHIS’s failure to
examine glyphosate use. APHIS now gives purely pro forma atten-
tion to herbicide use in their regulatory reviews, and even this
minimal treatment is grossly inadequate.
APHIS, for instance, dismissed analysis of herbicide use of
Roundup Ready crops in the Roundup Ready draft and Environ-
mental Impact Statement that relied on gold-standard data from
its sister agency, the National Agricultural Statistic Service, and in
its place it used bogus data from simulations conducted by pes-
ticide industry-funded groups, like the National Center for Food
and Agriculture Policy and PG Economics.
In other cases, USDA cited completely irrelevant data that was
10 years old or more, no relevance. APHIS also ignored research
by scientists from USDA’s Agricultural Research Service and oth-
ers that point to potentially increased disease susceptibility in
Roundup-treated, Roundup Ready crops. And, unfortunately, USDA
does not require testing of Roundup Ready crops to which Roundup
has been applied, which is the invariable practice of farmers. In
view of the growing evidence of disease, possible disease suscepti-
bility issues, that is inexcusable.
I would just like to say USDA should definitely follow the lead
of the EPA. The successful insect resistant management program
could be followed by USDA. And I don’t buy Ms. Wright’s protesta-
tions that USDA doesn’t have authority. The noxious weed provi-
sions of the Plant Protection Action clearly gives them authority to
regulate practices that foster noxious weeds, and that is exactly
what these Roundup Ready systems are.
Mr. Kucinich. I thank the gentleman for his testimony. As I
said, your entire testimony will be included in the record of this
hearing. I am sure that we will get back to you with some ques-
tions. Thank you very much.
[The prepared statement of Mr. Freese follows:]
62
Testimony Before the Domestic Policy Subcommittee of the House Oversight and
Government Reform Committee
by William Freese
Science Poliey Analyst
Center for Food Safety
September 30, 2010
In 1997, just as Roundup Ready crops were being introduced, Monsanto scientists published a
paper in which they presented all the many reasons weeds were NOT likely to evolve resistance
to glyphosate, the active ingredient in Roundup [1], Well, this prediction turned out to be wrong,
disastrously wrong for a growing number of farmers. As discussed at Part 1 of this hearing in
July, unregulated use of glyphosate-resistant crop systems has triggered an epidemic of
glyphosate-resistant weeds infesting 10 million acres or more. It has also fostered sharp
increases in herbicide use and greater use of soil eroding tillage operations, and is substantially
raising weed control costs for ever more growers. Syngenta’s Chuck Foresman projects a 40%
annual increase in area with glyphosate-resistant weeds, which would infest 38 million acres, or
one of every four row crop acres, just 3 years from now in 201 3 [2].
Now Monsanto and other pesticide firms assure us that the solution to glyphosate-resistant weeds
lies in a dizzying array of new crops resistant to older, more toxic herbicides like 2,4-D [3] and
dicamba [4], and to multiple herbicides. DuPont envisions a single crop resistant to seven or
more different classes of herbicides [5]. This is the major R&D focus of the industry, with
hundreds of millions of dollars being invested [6], and resistance genes available for practically
every major class of herbicide, including the notorious neurotoxin paraquat [7], Nearly half of
the genetically engineered (GE) crops pending deregulation at USDA are herbicide-resistant [8],
and most will be offered in multiple herbicide-resistant (HR) cultivars.
We should not let ourselves be misled once again. These new HR crops are the wrong response
to resistant weeds, for several reasons. First, they will substantially increase use of the
associated herbicides, increasing our exposure to them in water and food. And as recently
highlighted by the President’s Cancer Panel, many pesticides are known or suspected
63
carcinogens that we should be reducing, not increasing, or exposure to [9], Some pesticides, like
2.4- D, can also mimic human hormones, disrupting the body’s intricate signaling system that
plays such a crucial role in development, metabolism and reproduction. For instance, male
pesticide applicators exposed to 2,4-D had lower sperm counts and more spermatic abnormalities
than men not exposed to it, 2,4-D has also been shown to significantly depress levels of thyroid
honnone, essential for normal development of the brain, in ewes treated with the chemical [10].
2.4- D-resistant soybeans and com break down 2,4-D into a still more toxic compound known as
dichlorophenol, presenting food safety risks [1 1].
Second, HR crops facilitate mid-season use of herbicides that drift and volatilize to damage
neighbors’ crops. In some cases, farmers will purchase expensive HR seeds not because they
want them, but to defend against drift from or misapplication by neighbors. Of course, even this
is only possible if an appropriate HR cultivar of the pertinent crop is available. In either case,
whether through crop damage or “defensive” purchase of expensive HR seed, the non-adopting
farmer is incurring costs he should not have to bear.
Third, HR crops will accelerate the evolution of weeds resistant to HR crop-associated
herbicides. Already, common waterhemp resistant to three and four classes of herbicides are
rampant in Missouri and Illinois. Weeds can acquire resistance to herbicides one at a time, or to
several at once via a mechanism known as metabolic degradation. The evolution of weed
resistance to several herbicides simultaneously will be fostered by increased use of herbicide
mixtures with multiple HR crops, a very troubling development. I would be happy to explain
further why faith in multiple herbicide resistance as a “solution” to HR weeds is misplaced, and
in fact will likely accelerate the evolution of weeds resistant to multiple herbicides.
The glyphosate-resistant weed epidemic is a symptom of regulatory breakdown, a devastating
example of how thoroughly discoordinated the Coordinated Framework for Regulation of
Biotechnology actually is. USDA’s Animal and Plant Health Inspection Service (APHIS)
regulates the HR crop, EPA regulates the associated herbicide(s). But NO ONE regulates the
combination, the HR crop-herbicide system. And it is the system ~ the invariable use of
glyphosate made possible and fostered by glyphosate-resistant seeds, for instance - that is
2
64
responsible for the growing epidemic of glyphosate-resistant (GR) weeds. This is clearly
demonstrated by the near complete absence of GR weeds for the first 20+ years of glyphosate’s
use, and the explosion of weed resistance in the decade since the widespread adoption of
Roundup Ready crop systems. We can anticipate similar issues with future HR crop systems
unless serious regulatory action is taken.
When a federal district court judge reversed APHIS’s deregulation of Roundup Ready (RR)
alfalfa due to inadequate environmental assessment, he underscored APHIS’s failure to examine
glyphosate use linked to the RR crop, and the interrelated issue of resistant weeds, as a major
failing [12]. Since that time, APHIS has given purely pro forma attention to herbicide use in
association with glyphosate-resistant and other HR crops. And even this minimal treatment is
grossly inadequate. In APHIS’s draft environmental impact statement (EIS) on Roundup Ready
alfalfa, for instance, it dismissed analysis of herbicide use with RR crops by an independent
scientist that relied on gold-standard data from its sister agency, USDA’s National Agricultural
Statistics Service (NASS) [13], and mistakenly criticized these data as lacking in ways they
aren’t. Instead, APHIS relied on misinformation from bogus “simulation studies” conducted by
pesticide-industry funded groups or contractors, such as the National Center for Food and
Agriculture Policy (NCFAP) and PG Economics. In other cases, USDA cited pesticide usage
data that were 10 or more years old, largely before Roundup Ready (RR) crops and the resistant
weeds fostered by these crop systems drove substantial increases in herbicide use. I would be
happy to provide more detail on these matters.
In still other cases, APHIS has ignored or dismissed research by scientists from another USDA
sister agency, the Agricultural Research Service (ARS), that points to mineral deficiencies and
increased disease susceptibility in Roundup-treated Roundup Ready crops [14], and in non-RR
crops planted in the same field in subsequent seasons [15]. Interestingly, APHIS allows
companies (e.g. Monsanto) submitting petitions for deregulation of glyphosate-resistant crops to
submit the results of agronomic observation trials (to assess seedling vigor, growth habit, crop
susceptibility to disease and insects, and similar features) that do NOT involve application of
Roundup/glyphosate to the glyphosate-resistant crop. In view of the considerable and growing
body of research by U SDA ARS and other independent scientists alluded to above, this is
3
65
inexcusable. When a new GR crop is deregulated, the applicant has thus provided essentially no
information on whether it is more prone to mineral deficiencies or fungal diseases than a
conventional variety - despite peer-reviewed literature on similar GR crop systems suggesting
that it very well may. A crop system that increases the disease susceptibility of a crop presents a
potential plant pest risk that may require regulation under the Plant Protection Act.
In the programmatic EIS APHIS conducted for its GMO rules revision process that was
completed in 2007, herbicide-resistant crops and weeds were almost completely ignored.
Incredibly, the brief discussion of GR weeds referred to reports in Australia in the 1 990s, and
completely neglected to discuss the resistant weed epidemic triggered by RR crop systems in the
U.S., much less any regulatory options for managing it.
USDA should follow the lead of the EPA, which has largely forestalled evolution of insect
resistance to the insecticidal toxins in Bt crops through mandatory insect resistance management
(IRM) plans. These plans have helped greatly to prevent the emergence of Bt toxin-resistant
insect pests, despite serious compliance problems. Compliance deficits probably relate to the
fact that IRM plans, though mandatory, are largely administered by the biotech-seed companies
themselves. One example is Monsanto’s illegal distribution of Bt cotton seeds in Texas over the
five years from 2002 to 2007 without informing farmers of IRM planting restrictions in grower
guides, for which EPA levied a $2.5 million fine on the company [16], Thus, more direct
involvement and oversight by EPA would be desirable.
EPA determined that because the insecticidal protein was incorporated in and inseparable from
the Bt plant’s tissues, its regulatory jurisdiction extended to the Bt plant. Based on its
assessment that Bt insecticidal toxins are less toxic than conventional chemical insecticides, and
that selection pressure for evolution of Bt toxin-resistant insects would be enormous, and thus
rapidly degrade the efficacy of these compounds through resistance, EPA determined that
mandatory resistance management was called for - to preserve the efficacy of these compounds
as a public good.
Very similar considerations apply to glyphosate and glyphosate-resistant crops. The mere fact
4
66
that the GR plant and glyphosate are not physically joined as Bt toxins are in Bt crop tissues
matters little in practical terms if indeed the two are invariably used together, as they are, by
design. And since glyphosate is generally regarded as less toxic than most herbicides, it would
be beneficial to preserve its efficacy. We shoidd note, though, that many scientists have found
that certain supposedly “inert” ingredients added to Roundup formulations to increase the
efficacy of glyphosate are more toxic than glyphosate itself. One such “inert” ingredient in
particular, polyethoxylated tallowamine (POEA), has long been implicated in causing high
mortality to populations of frogs exposed to Roundup formulations containing it at field-relevant
concentrations [17], (To its credit, Lisa Jackson’s EPA is taking initial steps towards improved
regulation of these often toxic “inert” ingredients.)
However the science eventually plays out on the toxicity/safety of glyphosate and its various
formulations, it would be beneficial to preserve its efficacy, and that means checking the GR
weed epidemic. Roundup Ready crop systems have proven to be wonderfully adapted to breed
rapid evolution of GR weeds. Such weeds, once emerged, can spread to infest the fields of other
growers, including those who do not use glyphosate-resistant crops at all. (The windbome seed
of horseweed can travel for miles on the wind [18], and it is perhaps not a coincidence that GR
horseweed is the most prevalent of GR weeds, infesting at last count up to 6.3 million acres in
the U.S. [19]). Such a grower (say of wheat) may well use glyphosate as a bumdown herbicide.
Single season bumdown use of glyphosate is much less likely to foster evolution of GR weeds
than the two and three in-crop applications that are becoming ever more common for Roundup
Ready growers. A wheat grower whose fields are infested with GR weeds in this manner,
through no fault of his own, would have to apply more toxic herbicides like 2,4-D instead of (or
in addition to) glyphosate, incurring both added cost and potential harm to health.
USDA has the authority to regulate HR crops for their clear propensity to foster rapid evolution
of HR weeds under the noxious weed provisions of the Plant Protection Act, as well as the
general provisions charging APHIS with protection of the “interests of agriculture.” When one
considers the huge costs imposed on cotton growers by glyphosate-resistant Palmer amaranth
and horseweed, regulation becomes not just possible, but an urgent necessity. According to
University of Georgia’s Brad Haire, speaking of glyphosate-resistant Palmer amaranth: “We’re
5
67
talking survival, at least economically speaking, in some areas, because some growers aren’t
going to survive this” [20], Eminent weed scientist Alan York has a similar take, once
comparing glyphosate-resistant Palmer amaranth to the boll weevil in terms of the threat it poses
to the U.S. cotton industry [21]. The boll weevil devastated cotton growers throughout the
South, making it impossible to grow for many years in some areas, and necessitated massive
campaigns for its eradication. By one account, the boll weevil cost the cotton industy $46 billion
dollars over the past century [22]. In the face of costs and risks from GR weeds that are even a
fraction of this magnitude, continued inaction by USDA is irresponsible.
CFS has the following recommendations.
1 ) USDA should refrain from deregulation of any new HR crop, particularly Roundup
Ready alfalfa and Roundup Ready sugar beets, unless or until:
a. Weed resistance management plans, and
b. Protection plans for those farmers who choose not to adopt the HR crop;
are made mandatory conditions for commercial planting. Good resistance
management plans will take study and work, and input from growers as well as
extension agents, independent scientists and the EPA.
2) Such management plans would best incorporate some prohibition on continual, year-in,
year-out planting of an HR crop in order to lessen selection pressure for evolution of
resistant weeds from continual use of the associated herbicides(s). Such management
plans should be developed for existing GR crops as well. This would be the temporal
equivalent to the spatial refiigia required (or once required) by EPA for IRM. USDA
should consult with EPA in formulating such plans.
3) USDA should promote integrated weed management practices that prioritize non-
chemical modes of weed control, such as cover crops, and do this at every level:
research, stronger IWM curricula at land grants, demonstration plots, training of
extension agents and farmers, etc. Winter cover crops such as cereal rye, hairy vetch
and red clover are planted in the fall after the main crop’s harvest, grow in the fall and
6
68
next spring, and when killed prior to spring planting provide physical suppression of
weeds in the following main crop. Cover crops provide multiple additional benefits
as well, including uptake of excess nitrogen and phosphorus from fertilizer
application (reducing adverse nutrient loading of water bodies from runoff) and
inhibition of soil erosion during snow thaw in the spring. Weed scientists have
specifically recommended increased use of cover crops to suppress glyphosate-
resistant weeds. Such promotion of IWM practices could be funded by USDA’s
National Institute of Food and Agriculture, and perhaps also by an HR seed fee that is
collected from each pesticide-biotech firm for each acre of HR seed or HR trait acre
that is sold. USDA should also fund active and comprehensive monitoring of
herbicide-resistant weeds led by independent land grant scientists, as recently
recommended by the Government Accountability Office, given the inadequacies of
the current system, funded largely by the pesticide industry.
7
69
References
[1 ] Bradshaw, L.D. et al (1997). “Perspectives on glyphosate-resistance,” Weed Technology
11(1): 189-98.
[2] Syngenta (2009). “Leading the fight against glyphosate resistance,” Syngenta,
httD://www.svngentaebiz.com/DotNetEBiz/lmageLlbrarv/WR%203%20Leading%20the%20Fig
ht.pdf .
[3] Kaskey, J (2010). "Dow plans new trait to combat Roundup-resistant weeds,"
Bloomberg, May 05, 2010, http://www.businessweek.eom/news/2010-05-05/dow-plans-
new-trait-to-combat-roundup-resistant-weeds-update2-.html.
[4] Behrens, M.R. et al (2007). "Dicamba Resistance; Enlarging and Preserving
Biotechnology-Based Weed Management Strategies,” Science 316: 1185-88.
[5] Castle, L.A. et al (2009). "Novel Glyphosate-N-Acetyltransferase (GAT) Genes," U.S,
Patent Application Publication, Pub. No. US 2009/0011938 Al, assigned to Pioneer Hi-Bred
International and DuPont, January 8, 2009, paragraph 33.
[6] Kilman, S. (2010). "Superweed Outbreak Triggers Arms Race,” Wall Street Journal,
June 4, 2010.
http://online,wsi,com/article/SB10001424052748704025304575284390777746822.html
[7] Green et al (2007). "New multiple-herbicide crop resistance and formulation
technology to augment the utility of glyphosate,” Pe.st Management Science 64(4);332-9.
[8] http://www.aphis.usda.gov/biotechnologv/not ree.html .
[9] Reuben, S.H. (2010). “Reducing Environmental Cancer Risk: What We Can Do Now,"
The President's Cancer Panel: 2008-2009 Annual Report, Dept of Health and Human
Services, National Health Institute, National Cancer Institute, April 2010.
http://deainfo.nci.nih.gOv/advisorv/pcp/annualReports/pcp08-09rpt/PCP Report 08-
09 508.pdf . See also: Kristof, N.D, (2010). "New alarm bells about chemicals and cancer,"
New York Times, May 6, 2010.
[lOJ For documented review of 2,4-D's adverse health impacts, see Comments to EPA on
its 2,4-D Risk Assessment, Docket ID No OPP-2004-0167, submitted by a coalition of public
health groups, including NRDC and Beyond Pesticides, August 23, 2004.
[11] Laurent, F. et al (2006). "Metabolism of [>''C]-2,4-dichlorophenol in edible plants,"
Pest Management Science 62: 558-564.
[12] Geertson Seed Farms, et al. v. Johanns, Docket No. 06-1075 (N.D. Cal. Feb. 14, 2007)
8
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[13] Benbrook, C. (2009). “Impacts of Genetically Engineered Crops on Pesticide Use; The
First Thirteen Years,” The Organic Center, November 2009. http://www.organic-
center.org/science.pest.php?action=view&report id= 1 59 .
[14] Kremer. R.J & Means, N.E. (2009). “Gl 3 tphosate and glyphosate-resistant crop
interactions with rhizosphere microorganisms,” European Journal of Agronomy,
doi:10.1016/j.eja.2009.06.004; Kremer, R.J. etal. (2005). "Glyphosate affects soybean root
exudation and rhizosphere microorganisms," International |. Analytical Environ. Chera.
85:1165-1174. Robert Kremer is the USDA Agricultural Research Service scientist. See
also: Motavalli, P.P. et al. (2004). "Impact of genetically modified crops and their
management on soil microbially mediated plant nutrient transformations,” ]. Environ. Qual.
33:816-824; King, A.C., LC. Purcell and E,D. Vories (2001). "Plant growth and nitrogenase
activity of glyphosate-tolerant soybean in response to foliar glyphosate applications,"
Agronomy Journal 93:179-186; Gordon, B. (2007). “Manganese nutrition of glyphosate-
resistant and conventional soybeans," Better Crops, Vol. 91, No. 4: 12-13; Eker, S., Ozturk,
L., Yazici, A., Erenoglu, B., Roemheld, V., Cakmak, I. (2006). “Foliar applied glyphosate
substantially reduced uptake and transport of iron and manganese in sunflower
(Helianthus annuus L.) plants. J. Agric. Food Chem. 54: 10019-10025; Bernards, M.L. et al
(2005). "Glyphosate interaction with manganese in tank mixtures and its effect on
glyphosate absorption and translocation,” Weed Science 53: 787-794; Cakmak, I, Yazici, A.,
Tutus, U. and Ozturk, L. (2009). "Glyphosate reduced seed and leaf concentrations of
calcium, manganese, magnesium and iron in non-glyphosate resistant soybean," Eur. J.
Agron. Doi:10.1016/].eja.2009.07.001.
[15] Fernandez, J.R. et al (2009). "Glyphosate associations with cereal diseases caused by
Fusarium spp. in the Canadian Prairies,” Eur. J. Agron., doi:10.1016/j.e|a.2009.07.003;
Fernandez, M.R., F. Selles, D. Gehl, R. M. DePauw and R.P, Zentner (2005). "Crop production
factors associated with Fusarium Head Blight in spring wheat in Eastern Saskatchewan,"
Crop Science 45:1908-1916. http://crop.scijournals.Org/cgi/content/abstract/45/S/1908.
[16] Stock & Land (2010). "Monsanto fined $2.Sm,” Stock & Land, July 12, 2010.
http://sl.farmonline.com.au/news/nationalrural/agribusiness-and-
general/general/monsanto-fined-25m/1882390.aspx
[17] Relyea, R. A. (2005a). "The lethal impact of Roundup on aquatic and terrestial
amphibians,” Ecological Applications 15(4): 1118-1124; Relyea etal (2005b). “Pesticides
and amphibians: The importance of community context,” Ecological Adaptations 15; 1125-
1134.
[18] Dauer, J.T. et al (2009). "Conyza canadensis seed ascent in the lower atmosphere,”
Agricultural and Forest Meteorology 149: 526-534.
[19] Collation of acreage infested figures collated from GR horseweed reports listed at:
http://wtvw.weed.sdence.org/Summarv/UspeciesMOA.asp?lstMOAID=12&.FmHRACGroup
=Go .
9
71
[20] Haire, B. (2010). "Pigweed threatens Georgia cotton industry," Southeast Farm Press,
July 6, 2010. http://southeastfarmpress.com/cotton/pigweed-threatens-georgia-cotton-
industrv-0706/ .
[21] As quoted in: Minor, E. (2006). "Herbicide-resistant weed worries farmers," AP,
12/18/06.
[22] Muzzi, D. (2004). "Boll weevil changed face of cotton industry," Southeast Farm Press,
4/14/04. http://.southeastfarmpress.com/boll-weevil-changed-face-cotton-industrv
10
72
Mr. Kucinich. Mr. Vroom.
STATEMENT OF JAY VROOM
Mr. Vroom. Thank you, Chairman Kucinich and Congresswoman
Watson, for allowing me to come and provide testimony today on
hehalf of the crop protection industry and CropLife America. Thank
you for introducing me earlier.
In addition to my role as CEO of our trade association, I also
have an Illinois farm background and happen to still own the fam-
ily farm that I was reared on.
I happen to have been in Illinois twice in the last 6 weeks. Six
weeks ago I stopped to take a look at one of the fields that is now
being operated by my cousin. It was planted this year in Roundup
Ready Soybeans. It was planted as a no-till crop, and Mr. Chair-
man, I would love to share this photograph. There are three of
them here. I am most proud of this particular view, because it
shows this field in the direction in which a terrace that my father
installed as a charter member of our Bureau County, IL, soil and
water conservation district, one of the first terraces installed in the
country, to provide then the cutting-edge technology for soil con-
servation at that time.
I remember as a youth hand-weeding and hand-cultivating with
mechanical means fields of soybeans and other crops on this very
field, and we were not able to control the soil erosion as we can
today with the Roundup Ready technology. If I can pass this up
and maybe ask your staff to share that with you.
Mr. Kucinich. We will include it in the record. Without objec-
tion, so ordered.
[The information referred to follows:]
73
74
75
76
Mr. Vroom. Thank you.
So conservation tillage is an important component of the intro-
duction of biotechnology.
I also have a report by our Crop Protection Research Institute
that illustrates on page 2 a graph of introduction of modern bio-
technology and then the takeoff of the adoption of conservation till-
age in this country. It has made a meaningful difference, and I be-
lieve there are clear USD A statistics to that effect.
Mr. Kucinich. Without objection, that will be included in the
record of the hearing.
[The information referred to follows:]
77
1
CropLife Foundation
■■■ ('!!>)* Protection Research Institute
The Value of Herbicides in U.S. Crop Production: 2005 Update
Executive Summary
Herbicides are chemical pesticides that kill weeds. U.S. farmers have sprayed herbicides on
nearly 90% of the nation’s cropland acreage for the past 30 years.
The value of the use of herbicides in 2005 is estimated to have been $16 billion in increased crop
yields and $10 billion in reduced weed control costs.
The use of herbicides greatly reduces the need for 4
fuel and laborers on U.S. farms. If farmers did not = ^
use herbicides, the alternatives for weed control =
CC -y
would be increased mechanical cultivation and »>
increased hand labor to puli weeds. The need for i
fuel would be 337 million gallons higher, since o
twice as many cultivation trips would be needed to
replace herbicide spray trips and cultivators use four
times more fuel per trip than herbicide sprayers. A
minimum of 1.1 billion hours of hand labor would
be required at peak season for hand weeding,
necessitating the employment of 7 million more agricultural workers. Even with the increased
cultivation and hand weeding, crop yields would be 20% lower. Approximately 70 million
workers would be needed to prevent any yield loss without herbicides.
The largest production loss would be in corn, with a reduction of 2.7 billion bushels. Corn is the
main feedstock for U.S. ethanol production, a major alternative being developed to reduce
dependence on oil. The corn production loss due to the non-use of herbicides is equivalent to 7.3
billion gallons of ethanol, which is equal to the entire projected capacity of U.S. ethanol
production by 2010.
Without herbicides. U.S. growers would have to abandon no-till production practices, which are
effective and popular techniques for reducing soil erosion. Without tillage, growers kill weeds
with herbicides. If U.S. growers stopped using herbicides and resumed tillage on the 62 million
acres that were not tilled in 2005, soil erosion would be 356 billion pounds higher than it is today.
Soil erosion deposits sediments in streams and rivers resulting in downstream damages. The
damage resulting from increased soil erosion due to tanning without herbicides is estimated at
$1.4 billion.
V^alue of Herbicides in li.
S. Crop Production: 2005
Total Acres Treated with Herbicides
215 million
Current Herbicide Cost to Growers
$7- i billion
Herbicide Non-Use Cost Increase
$9.7 billion
Herbicide Non-Use Yield Loss {Volume^
295.7 billion pounds
Herbicide Non-Use Yield Loss ( Value)
$16.3 billion
Herbicide Non-Use Labor
+ 1.1 billion hours
Herbicide Non-Use Erosion
+356 billion pounds
Herbicide Non-Use Fuel Consumption
+337 million gallons
Herbicide Non-Use Net Income Impact
-$26.0 billion
CmpLife Foundation
1156! 5th Street, N W #400 Washington. DC 20«)5
Phone 202-296-1585 vvww.croplifefoundation.oig Fa.x 202-463-0474
78
This report for 2005 is an update of a previously issued report for 200 1 . The same methodology
was used in both reports, which makes it possible to report on fluctuations in the herbicide market
and changes in the benefits of herbicides. Due to significant price decreases, U.S. farm
expenditures for herbicides declined by $300 million between 2001 and 2005. The price decline
for herbicides was outweighed by increases in the costs of applying herbicides due to higher labor
and fuel costs (+$500 million) and increases in the premium prices paid for biotech herbicide-
tolerant seed (+$3 1 2 million). Thus, the total
cost of herbicides and their application
increased by $512 million between 2001 and
2005.
Increased fuel and labor costs, however, also
made the costs of alternatives to herbicides
higher. The aggregate cost of cultivation and
hand weeding as replacements for herbicides
increased from $14.3 billion in 2001 to $16.8
billion in 2005, resulting in a net increase in
weed control costs without herbicides from
$7.7 billion in 2001 to $10 billion in 2005.
The value of the crops also increased significantly between 2001 and 2005, which means the 20%
loss in production without herbicides is worth more in 2005 ($16 billion) than in 2001 ($i3
billion). Overall, the value of herbicides increased from $21 billion in 2001 to $26 billion in
2005.
"•Organic
Three trends that occurred in crop production and weed control between 2001 and 2005 are
noteworthy, especially those relating to no-till, biotech, and organic crop production. Two of
these practices are dependent on herbicides and one is not. The number of no-till acres on which
herbicides substitute for tillage increased from 52 million acres to 62 million acres. The number
of biotech herbicide tolerant acres where herbicides are used with crops that have been
genetically-engineered for tolerance increased from 66 million acres to 94 million acres.
Meanwhile, the number of cropland acres grown according to organic standards where herbicides
are not used increased by 1 00,000 acres to 1 ,4 million. Organic fanners substitute labor and
tillage for herbicides, which is very costly. The problem of controlling weeds without herbicides
has been cited numerous times as the single largest obstacle that organic growers encounter. The
following quotation from Earthbound Farms (the largest organic producer in North America)
underscores the expense of doing without herbicides:
Controlling weeds without herbicides takes a lot of time and is very
costly for us. We do all our weeding by tractor or by hand, which is very
labor intensive. Conventional farmers spend only about $50 an acre on
herbicides that knock out every weed in sight. Organic farmers may
have to spend up to $1,000 an acre to keep weeds under control.
There is not likely to be a vast expansion in domestic organic acreage due to the high cost of
labor in the U.S. in comparison to many developing countries.
The full report, The Value of Herbicides in U.S. Crop Production: 2005 Update, including state
and crop specific data, is available on the Crop Protection Research Institute’s web site at:
hltp:.7www.croplifefoun dalion.orc/cpri benefits herbicides.htm . For more information, please
contact the authors: Leonard Gianessi at 202-872-3865 or igianessiiffcrop lilelbii ndalion.or a: or
Nathan Reigner at 202-872-3866 or n reigneri'mcropiifefoundation.oi 'c.
79
Mr. Vroom. Thank you.
My experience, and I just talked to my cousin who was combin-
ing soybeans this morning, he assured me that he was aware of
weed resistance and he has taken steps to manage it on this par-
ticular field, and we know that we don’t have the most severe
weed-resistance problems with regard to glyphosate situations, as
are apparent in some of those 11 million acres that you refer to.
Our industry, along with USDA — and unfortunately Ms. Wright
probably didn’t have adequate time or background to explain to you
the full resources the USDA brings to bear with regard to helping
farmers manage weed resistance in both biotechnology crops and
elsewhere. Extension, our industry scientists, crop consultants that
are private individuals, crop input retailers, all have a stake in all
of this and we have a marvelous system to help farmers manage
these issues. But we do appreciate the fact that you have an inter-
est in examining the regulatory authority of the agencies that are
charged with overseeing these technologies, and we look forward to
working with you as you give consideration to ways to have over-
sight and consideration of these matters.
Last, I would just tell you that our industry has formed a herbi-
cide resistance action committee. It is a global entity that CropLife
and our partner associations around the world are involved with,
and it provides a mechanism for the common research that herbi-
cide companies engage in with regard to helping to stay ahead of
the curve and ensure that we can manage herbicide resistance in
both biotechnology-enhanced crops and conventional crops as well.
So we believe that we do have a system in place that allows us
to continue to manage these issues. We understand the particular
media attention that has been given to herbicide resistance in bio-
technology crops, but we believe that we have an adequate system,
and we appreciate the attention that you will continue to provide
to this issue.
Mr. Kucinich. Thank you very much, Mr. Vroom.
[The prepared statement of Mr. Vroom follows:]
80
Testimony of Jay Vroom
President and CEO
CropLife America
Before the Domestic Policy Subcommittee,
House Oversight and Government Reform Committee
“Are Superweeds and Outgrowth of USD A Biotech Policy”
September 30, 2010
Thank you, Chainnan Kucinich and Ranking Member Jordan, for the opportunity to
address the Subcommittee on behalf of CropLife America and its members, as well as their
customers the American farmers. CropLife America is the leading trade association representing
the U.S. crop protection industry and our members supply virtually all of the crop protection
products used by American fanners. CropLife America’s member companies, and members of
our counterpart association at RISE', proudly discover, manufacture, register and distribute crop
protection products for American agriculture, and specialty use products outside of agriculture,
such as those used for public health protection and commercial pest management inside of homes
and commercial buildings,
CropLife America members work with farmers, ranchers and growers everyday to ensure
that crop protection tools are registered properly and used correctly. As a matter of fact,
America’s abundant, affordable food supply depends on the availability of safe, effective crop
protection products. Careful use of crop protection products contributes substantially to
production of U.S. farm exports valued at some $100 billion per year, CropLife America
members support modem agriculture by looking forward: each year the agrochemical industry
spends hundreds of millions of dollars on research and development, with much of that
investment going into producing data that meet or exceed the Environmental Protection
Agency’s (EPA) information requirements and requests for pesticides.
Responsible Industry for a Sound Environment (RISE) — www.pcstfact5.org
81
Three major points are essential to understanding weed resistance to herbicides and the need for
best management practices to minimize the potential for resistance development:
• First, herbicide resistance occurs naturally, and best management practices need to be
applied in ensuring that resistance development is avoided or delayed.
• Secondly, the market can and will facilitate the development of solutions to combat the
issue of weed resistance in crop production to ensure production of safe, affordable, and
plenti&l food.
• Third, the current regulatory framework for herbicides is robust.
Weeds, insects and fungi readily adapt genetically to their environments. Pesticides and other
pest control technologies, used over widespread areas, will control many target pests, but some
pests may have a genetic advantage and survive. The survivors, if not removed from fields
physically or with an alternative chemical control option, will grow and become more prominent
in the local environment. Weed adaptation has been happening as long as man has tried to grow
crops and is not unique to the use of chemical control or adoption of biotech crops. Under a
regimen of physical control, weeds might become physically harder to distinguish or more
difficult to remove. While ‘superweeds’ might be a catchy moniker, there is nothing particularly
super about the weeds that have developed resistance to any particular herbicide. Resistance of a
particular weed species to a particular herbicide has arisen multiple times over the past several
decades. The problems have been overcome through adjustments to the use of the specific
herbicides, and through availability and use of additional herbicides and weed control strategies,
all acting by different mechanisms, so that no one weed species or variety can escape all of the
control approaches.
To avoid the onset of resistance growers need to be aware of and adopt best management
practices (BMPs). Information regarding BMPs and integrated weed management is available
from multiple reliable sources. Growers who ignore that infonnation do so at their peril, with
potentially serious economic consequences. Adoption of biotechnology hasn’t caused the rapid
onset of resistance in weed species; appropriate use of all technologies will reduce its impact.
82
The market can and will facilitate the development of solutions to the issue of weed resistance in
crop production to ensure production of safe, affordable and plentiful food. Farming is a long-
term investment, and growers will adapt their operations to succeed. They need the flexibility to
manage their farm operations for the current season and for the future. That flexibility requires
access to the tools that enable them to take care of their business interests and sufficient latitude
in terms of how and when they are used. Growers are in the best position to know their fields,
the weeds growing in them, and how to best manage their farm inputs. Such knowledge will
enable them to make the best decisions on what tools to use, including crop protection products
and biotech crop seed, considering the economics and their future management plans.
Weed control options will continue to be developed. Crop protection is a competitive business.
If a weakness in a particular weed control option emerges, there will be other new or existing
technologies that will seek to fill that void. The market favors maximization of the tools
currently available. The development of new herbicides is an involved and expensive process.
To make that investment worthwhile requires that the useful life of a product will be extended as
long as possible with available means. Some recent marketing programs have included
manufacturer rebates for use of competitive products in combination with a company’s product,
in order to stem the onset of resistance. This is one example of how the market addresses the
issue.
Regulation of pesticides, including herbicides, is science-based, stringent, thorough and robust.
The approval process and use of pesticides are overseen by the Environmental Protection
Agency (EPA) through implementation of the Federal Insecticide, Fungicide, and Rodenticide
Act (FIFRA). Development and registration of a new pesticide active ingredient takes 8 to 1 0
years, costs over 200 million dollars, and requires at least 120 scientific studies, conducted at the
manufacturer’s expense and thoroughly reviewed by EPA. EPA must approve the product label
before it grants a “registration” for sale and use of the product. The label contains the necessary
instructions and precautions to use the product safely and effectively. When used according to
the label, registered pesticides will not harm humans, animals or the environment. EPA
continues to monitor use of the pesticide in the marketplace. If problems in product efficacy are
discovered by EPA or the registrant or users, adjustments are made as necessary to the label
83
instructions to make sure the product can continue to be used safely and effectively. The
changes may be initiated either by EPA or the manufacturer, but must be approved by EPA.
I appreciate the opportunity to appear before the Subcommittee today to discuss the important
issue of resistance management on behalf of the chemical crop protection industry. We remain
committed to continuing to work with the Congress, our regulator and our end-users who use our
technology to produce our nation’s safe, affordable and abundant food supply. I look forward to
answering any questions you may have regarding my testimony.
84
Mr. Kucinich. I just want to assure you that we provided Ms.
Wright with as much time as she needs to be able to answer this
committee’s questions, and we will continue to do that.
Let’s go to questions of this second panel.
Mr. Miller, with Monsanto’s 100 percent focus, as you have said,
on agriculture, I am wondering who is responsible for the prolifera-
tion of weeds and weed species that have become Roundup-resist-
ant since the introduction of Roundup Ready crop systems?
Mr. Miller. Thank you, Mr. Chairman. As I mentioned earlier,
if our farmers are not successful, we are not successful, and we
take this matter very seriously.
I would say herbicide-tolerant weeds is not a new thing. It is
something we have had to manage in the industry as well as with
university weed scientists and farmers in how they run their oper-
ations on their farm. So we invest a lot in the science of weed re-
sistance and understanding that and providing technical solutions
to growers along with others. That is really our focus.
Mr. Kucinich. I don’t know if you have testified before a congres-
sional committee, and all committees are different.
Mr. Miller. No, sir.
Mr. Kucinich. I am the kind of chairman that when I ask a
question, I would like to get a direct answer.
Would you tell me who is responsible for the proliferation of
weeds and weed species that have become Roundup-resistant since
the introduction of Roundup Ready crop systems?
Mr. Miller. I think weeds that are resistant to glyphosate are
the responsibility of industry, government, weed sciences, as well
as farmers, to properly steward the product.
Mr. Kucinich. So industry — ^you are part of the industry with
Monsanto. The USDA is part of that system. There is a responsibil-
ity there. There is a whole feedback loop here, you are saying;
right?
Mr. Miller. I think there is a feedback loop, but this is a herbi-
cide issue, and I believe herbicides are regulated under the Envi-
ronmental Protection Agency.
Mr. Kucinich. It is encouraging that you have stated that indus-
try has a responsibility here. But you also stated that government
has a responsibility as a regulatory authority, did you not?
Mr. Miller. Mr. Chairman, I believe that our regulatory agen-
cies have clear responsibilities to demonstrate and prove the safety
in use of these products.
Mr. Kucinich. Thank you. Let me direct your attention to this
ad circulated before 2005. This is Monsanto, Mr. Miller, in this ad,
telling farmers to use more and more Roundup and to use it exclu-
sively to control weeds. That was just 5 years ago. And it was also
5 years after Roundup-resistant horseweed was discovered in
Roundup Ready crop yields in Delaware.
Mr. Miller, help us out here. Isn’t it true if farmers followed
Monsanto’s advice conveyed in this ad, that they would have
Roundup-resistant weeds in their fields today?
Mr. Miller. Mr. Chairman, weed resistance is caused by many
factors. Prior to 2005, and many systems that we developed and co-
developed with the university weed science academics and the
Weed Science Society of America — and, by the way, I believe one
85
of those academics was actually referenced in that ad just reflect-
ing on a picture I saw — the recommendation was that glyphosate
had a low probability of developing resistance, and our rec-
ommendation was to utilize that in the system.
But in cases where we have begun to discover there are resistant
weeds, we have done a lot of training, education with growers, re-
tailers, and other in the industry to recommend multiple modes of
actions into our cropping systems.
Mr. Kucinich. I am going to ask staff to copy this and give you
a copy. Have you read this? Just look at it. I’m not trying to trap
you here, because I believe in having a conversation. It says no
benefit in rotating glyphosate. No benefit.
Can you explain that to me in light of what you said a moment
ago? Take your time. When you are ready to answer, go ahead. If
you want to rephrase anything for the record, you can do that, too.
Mr. Miller. Actually, I would like to read the recommendation
as stated by Monsanto in this particular article.
In many Midwest cropping systems, agronomic conditions and
cultural practice are conducive to preemergent application, an her-
bicide that is not glyphosate, so one mode of action, followed by
Roundup agriculture herbicides, or a tank mix of residual, two dif-
ferent modes of action, agricultural herbicide before weeds exceed
4 inches.
So this particular ad does actually steward two growers, and I
am responding to the title, “No Benefit from Rotating Glyphosate,”
was the fact that you use multiple modes of action in your system,
and if you use a Roundup Ready crop in the same field the next
year, and you steward it properly by using multiple modes of ac-
tion, there is no need to change your overall cropping system.
Mr. Kucinich. This is your ad. It says, no benefit in rotating
glyphosate, as you just read.
Now, I showed the same ad and asked the same question to a
prominent weed scientist who testified at our previous hearing. I
am sure that somebody in your organization read that testimony.
He was the author of the weed chapter of the National Research
Council’s report published in April.
Do you want to guess what his response was to the question of
whether farmers would have Roundup-resistant weeds in their
fields today if they followed the advice that was conveyed in
Monsanto’s ads? What do you think his answer was?
Mr. Miller. Chairman Kucinich, I wouldn’t want to speculate on
that.
Mr. Kucinich. OK. That is fine. It is recommended reading for
you. His answer was “yes.”
Mr. Miller, why was the discovery of Roundup-resistant
horseweed as early as the year 2000 not sufficient evidence of
Roundup resistance in weeds to move Monsanto to change its ad-
vice to farmers?
Mr. Miller. Congressman, first of all, I will go back to if our
growers are not successful, we are not successful. So as we actually
had the evidence of the first resistant weeds, we actually enabled
university research, our own research, to understand the mecha-
nism of that resistance.
86
The second thing that we did was enlisted those regional univer-
sity extension agents to help us develop what the recommendation
for the grower was in order to keep their farming operations suc-
cessful. Once we had that identified, we actually went out and did
significant training with producers, often recommending our com-
petitor’s product as part of the solution to ensure that the farmer
has a weed-free field.
Mr. Kucinich. Let me just share something with you. About 5
hours ago, I was in a full committee hearing with Johnson & John-
son looking at how they let two different products enter the mar-
ket, one of which had potential serious health consequences for con-
sumers. And one of these drugs, they sent in phantom purchasers
to get the drug back. There was active concealment going on.
The thing that strikes me that you said about if your customers
are not successful, you are not successful. You said that earlier in
your testimony. I actually wrote it down here. If farmers don’t suc-
ceed, Monsanto does not succeed. It is eerily similar almost to the
words except changing “Johnson & Johnson” to “Monsanto” to the
testimony of the CEO of Johnson & Johnson. That is the reason I
am calling it to your attention. I don’t question your background.
You have a tremendous background and you are certainly qualified
to testify before this subcommittee. There is no question about
that. You represent Monsanto well.
The question I have is the aspirational expressions that you
make on behalf of Monsanto do not square with the experiential
elements of the use of this crop. That is kind of where we are going
with this. I am not condemning you; I just want to say that there
is some difficulty in squaring this.
Now, Mr. Freese, is it true that Roundup-resistant weeds was a
development that took everyone, including Monsanto, by surprise?
Or was it a foreseen danger?
Mr. Freese. I think it was mixed. I know there were some weed
scientists who thought there wouldn’t be resistance evolving, but
others predicted it.
Mr. Kucinich. Some were surprised?
Mr. Freese. Yes.
Mr. Kucinich. What about you?
Mr. Freese. I wasn’t following the issue at the time.
Mr. Kucinich. But you have a 1980 report; isn’t that right?
Mr. Freese. A 1990 report, yes, by some colleagues in the public
interest community called “Biotechnologies: Bitter Harvest.” It is a
very searching and comprehensive report on what at that time was
still an experimental technology. 1990, this was 6 years before the
introduction of the first Roundup Ready crop — in this report the
scientists clearly see huge potential for development of herbicide-
resistant weeds, and particularly with this technology.
There was a 1996 report by Consumers Union, another consumer
group.
Mr. Kucinich. So you are saying that scientists did see the po-
tential for herbicide-resistant weeds. Which scientists are you talk-
ing about?
Mr. Freese. This report was written by Dr. Rebecca Goldberg
with Environmental Defense Fund; and Jane Rissler, who is now
87
with Union of Concerned Scientists; and Hope Shand and Chuck
Hassebrook.
Mr. Kucinich. What year was that?
Mr. Freese. 1990.
Mr. Kucinich. Mr. Miller, you have been with Monsanto since
1994, right?
Mr. Miller. That is correct.
Mr. Kucinich. I actually took notes during your testimony, and
you said in your testimony that Monsanto has 500 scientists who
work for the company. Did you say that?
Mr. Miller. Actually, sir, my statement was that in my regu-
latory group there are 500 scientists. There are over a couple of
thousand scientists in our company.
Mr. Kucinich. That is even more impressive. A couple thousand
scientists. Do you have any knowledge within the sphere of your
activities in the regulatory group of any reports that were brought
to you expressing concerns about herbicide-resistant crops?
Mr. Miller. I was not in that responsibility at that time. But I
can say
Mr. Kucinich. When did you come into that responsibility?
Mr. Miller. Just in the last 6 months, sir. But I have been in
the company 16 years as a researcher. I can share with you that
I think it is even documented in literature that with the Roundup
or glyphosate tolerance, we stated there was a possibility. We said
it was a low probability.
And I would say anytime we develop any of our products, as I
mentioned earlier, including with Mr. Smith here, before we de-
velop them, we actually create forums to understand the data that
is out there and the concerns that exist, and take that into consid-
eration as we develop our safe products.
Mr. Kucinich. What I would like to do, and I want to direct the
subcommittee staff here to work with Mr. Miller in gaining access
to the studies that were done by the scientists at Monsanto with
respect to herbicide-resistant weeds, because what we can do here
is to be able to identify the progress that has been made through
this scientific research with the 500 scientists who are working for
you and perhaps thousands of scientists who are working with
Monsanto.
So we will produce from this hearing a followup request for docu-
ments so that we can enable a better understanding of Monsanto’s
awareness of this. I would appreciate your cooperation.
Mr. Miller. Mr. Chairman, I will be happy to work with you on
that request.
Ms. Watson. Mr. Chairman, can you yield just 2 minutes to me?
I have another subcommittee hearing.
Mr. Kucinich. I am pleased to yield to the gentlelady at this mo-
ment. I was going to yield 10 minutes to you. If you need 10 min-
utes, you can have it now.
Ms. Watson. Thank you. I won’t use all of that time. I am very
interested in this subject matter, because just recently they an-
nounced that there is a new salmon that is going to be on the mar-
ket that has been, shall I say, biologically bred to grow larger, and
you might recall some of the advertisements in the last few days.
88
We are questioning whether that will have an impact on humans
once they consume that salmon. And so I was listening very closely
to see if Monsanto or other companies like you test the environ-
mental impact of these new — what you are working with is an her-
bicide — ^but do you test first to see what the impact will be on the
environment. Or does it grow?
The chair is asking for you to kind of document what was done
prior to putting it on the market, and I am wondering how far do
you go putting these products out there before you test their effect
on the environment?
Mr. Miller. Would you like me to answer that?
Ms. Watson. Yes.
Mr. Miller. OK. You know, I am very proud of the process that
we use both to validate the value that we bring to growers, as well
as the safety of our products. As you know, the products that we
have put out on the market , if it is a chemistry, it is EPA. Biotech,
it could be EPA, USD A, FDA. All of those go through thorough
health and safety assessments both internally in our organization
as well as with those agencies.
Often we have other third parties that look into that, because at
the end of the day, we want to ensure the health and safety, and
we believe that system has worked extremely well.
Ms. Watson. What do you feel you have to do now in light of
this, the findings that this superweed is so strong that it doesn’t
react to whatever you have out there to try to kill it? It is going
to have an impact, and it is going to have a financial impact cer-
tainly on the farmers and all.
And so what do you see that needs to be done? We are the sub-
committee of oversight. What is it that we can do within this proc-
ess to guarantee that people won’t be harmed, crops won’t be
harmed? What needs to be done? What are we missing?
Mr. Miller. Chairman Watson, I am not sure I can address the
question of what we are missing, but I can address what we are
doing. I think this is being taken very seriously by Monsanto, as
well as other technology providers in the industry. I think it is
being taken extremely seriously by weed scientists. And as was
mentioned by Jay earlier, our growers take this very seriously,
even before they have weed-resistance issues. What we are doing
about it, we have invested well over $30 million in just the last 5
years.
Mr. Kucinich. If the gentleman would suspend. Ms. Wright, I
just want to put it on the record that Ms. Wright did stay for most
of the testimony because that doesn’t always happen, and I want
to thank you for your presence here and for listening to the wit-
nesses’ testimony and questions. Thank you very much. I just
wanted to put that on the record.
If you are ready to continue, you may. Thank you.
Mr. Miller. Yes. So we are putting significant research, as well
as working with those local academics to help come up with best
recommendation for farmers.
Two things that I want to bring out. There are glyphosate-resist-
ant weeds, but there are still greater than 290 weeds that do not
have resistance, so this is still a hugely available tool to growers,
and they acknowledge that every time I go out and visit with them.
89
I am not going to diminish the fact that if one of the weeds is
resistant to glyphosate, that there needs to he a control option pro-
vided for that grower, and we actually have spent a lot of time,
even with the ad that was shown earlier, working on that particu-
lar species of weed. There are control options available on the mar-
ket, and we are helping growers he trained on how to use that in
their agricultural systems.
Ms. Watson. I am really concerned about the consumer side of
all of these new products that are out there, and so we are going
back and the chair is asking that we have some documentation so
that we can guarantee that we who have the oversight have done
all we can to ensure that these products will not have a negative
effect on whatever it is, and on consumers. So we are just probing
right now to see what our responsibilities are.
And if you are looking at evaluating the environmental impacts
of your product, I want to say thank you so much. That is what
I would like to know. And I am sure that the chair has also asked
for that information.
With that, I will wait to see it. As we probe in this area, Mr.
Chairman, I want to be a partner with you.
I am really concerned about that new — does anybody remember
seeing the information on television? If so, put your hand up. I
want to know about this salmon that is going to be three or four
times the size of any normally grown salmon. If we are to consume
it, what is the impact going to be on our digestive systems with
this larger salmon?
So in all good faith, we are just asking you to let us know what
we need to look at so we can protect the consumers.
Thank you very much.
Mr. Kucinich. I thank the gentlewoman for her questions. The
subcommittee is also looking at the issues with respect to geneti-
cally engineered salmon.
I want to say, when the gentlelady asked the question. What are
we missing, she was actually inviting Mr. Miller to help us in our
probe here. But I would say this; that we look forward to cooperat-
ing with you, that cooperation through information that brings us
to a level of comfort that the public interest is being protected. And
in pursuit of the public interest, we try not to miss too much.
Mr. Miller, you have heard testimony today about concerns that
your dicamba/Roundup-tolerant soybean will cause collateral injury
to fruit and vegetable farmers, and I would add, even backyard
gardeners. That is essentially what Mr. Smith was testifying to.
Your testimony, in fact, acknowledges concerns.
Now, in the event that an injury should materialize, apropos of
a question Mr. Smith raised, who would be liable for the economic
costs to the affected farmers? Would it be Monsanto or another
party?
Mr. Miller. Mr. Chairman, you know, I am not an attorney.
Mr. Kucinich. I am not either. I just play one on TV.
Mr. Miller. I don’t believe I can answer that. We would be
happy to followup with you later at the appropriate time when we
have that information.
Mr. Kucinich. I will accept you are not an attorney and you
don’t want to answer a question that gets you, excuse the expres-
90
sion, into the weeds about the legal implications of this policy. But
I would say that we would seek to entertain that discussion with
Monsanto attorneys, because this is one of the questions that is
being raised here. You have a product, if it has some adverse effect
on certain people, there are some questions of liability.
I am not asking you to accept liability here. I know what your
limitations are as a witness at this moment. You made that clear.
But let me ask you this: Do you think it is correct to classify the
injury fruit and vegetable farmers fear from the use of the dicamba
soybean system as an indirect cost of the development of Roundup
resistance in weeds?
Mr. Miller. Mr. Chairman, I am not sure that I follow your
question. I would appreciate if you could restate it.
Mr. Kucinich. Well, you have Roundup resistance in weeds that
is showing up. Farmers are concerned, and some farmers have ex-
pressed that there has been an injury to their fruits and vegeta-
bles. You have sold this dicamba soybean system. If the farmers
are experiencing this loss, isn’t that loss essentially an off-loading
of expense, an indirect cost of the development of Roundup resist-
ance in weeds?
Mr. Miller. You know, we are 5 years away from introducing
dicamba/Roundup Ready soybeans into the market. So as we bring
these forward — and it takes us well over a decade from the time
we begin to develop these products until we launch it — 5 years be-
fore the launch, we actually set up a dicamba grower or dicamba
advisory council, including many of the producers in the fruit, vine-
yard, and tomato industry.
And by the way, as Monsanto, we are one of the largest vegetable
seed producers in the world. Tomato customers in that business are
some of our biggest customers. And as I mentioned earlier, we care
about our customers’ success.
Our focus is to continue to bring weed-free cropping systems to
our producers in corn, soybean, and cotton, as well as serve the in-
terest of those fruit and vegetable producers. We have a significant
amount of research going on, with their input, to ensure when that
product comes on the market it is successfully implemented.
Mr. Kucinich. Do you have legal counsel here with you?
Mr. Miller. Yes, I do.
Mr. Kucinich. Would counsel identify himself, please?
Mr. SOPKO. John Sopko of Akin Gump.
Mr. Kucinich. OK. Actually, I know you gave an answer. You
didn’t answer the question; but if I pressed you to answer the ques-
tion, I know counsel would advise you not to, so I will move on.
Mr. Freese, can you answer the question I asked about do you
think it is correct to classify the injury fruit and vegetable farmers
fear from the use of the dicamba soybean system as an indirect cost
of the development of Roundup resistance in weeds?
Mr. Freese. I think that is very good way to describe it. The way
that the Roundup Ready crop system is used and is meant to be
used, I would say it has led to some pretty massive weed resist-
ance. Unfortunately, the way we approach weeds in this country is
so completely focused, so completely focused on using pesticides,
that a new herbicide-resistant crop, resistance to different herbi-
cides, seems to be the only thing that a lot of our companies and
91
even the USDA takes seriously. In fact, there are many very viable,
nonchemical ways to control weeds.
Mr. Kucinich. I am going to go back to Mr. Smith here, because
you are in touch with a base of people about these products. You
have testified, and I am quoting from your testimony, “The wide-
spread use of dicamba is incompatible with Midwestern agri-
culture.”
Mr. Smith. Yes, sir.
Mr. Kucinich. I am from Ohio. I hear that. How significant is
the risk of injury to fruit and vegetable farmers and processors
from planting the dicamba soybean in Indiana farm fields, and do
you have any estimate of potential cost?
Mr. Smith. We are working on providing an estimate of that
through a study with Purdue University at this time.
Mr. Kucinich. Would you produce that to the subcommittee
when that is done?
Mr. Smith. Yes.
Mr. Kucinich. You testified, “Increased dicamba usage, made
possible through the introduction of dicamba-tolerant soybeans, is
poor public policy and shouldn’t be allowed.”
Is there is a technological fix to the collateral harm you foresee
occurring, such as having Monsanto develop dicamba-resistant fruit
trees, melons, peas and tomatoes; is that the path we should take?
Mr. Smith. From a consumer standpoint, that is a path we can-
not take.
Mr. Kucinich. Why?
Mr. Smith. There is consumer resistance to the consumption of
genetically modified crops.
Mr. Kucinich. Why?
Mr. Smith. I am not an expert to answer that.
Mr. Kucinich. You don’t have to answer.
Mr. Miller, your testimony explains that the dicamba/Roundup
soybean is designed to “give growers more weed control options.” It
sounds somewhat artful. It sounds like an artful way of saying that
farmers can’t rely on Roundup to control weeds anymore, so they
now need to use another pesticide.
Is it your belief, Mr. Miller, that the best solution to Roundup
resistance in weeds is a farmer using another pesticide?
Mr. Miller. I would say my belief, a broad array of university
scientists, other industry scientists, the Weed Science Society of
America, believes that adding multiple modes of action into an ag-
ricultural production system is good agricultural practice, Mr.
Chairman.
Mr. Kucinich. Thank you.
Mr. Freese, is the only or best way to control weeds after Round-
up resistance has set in more and more chemicals and new chemi-
cal-tolerant crops?
Mr. Freese. I think that is actually a very dangerous path to
take.
Mr. Kucinich. Why?
Mr. Freese. We are learning lots of new things about weed re-
sistance, and new mechanisms are being discovered all of the time.
Mr. Kucinich. Why is it dangerous? You used the word “dan-
gerous.” What do you mean?
92
Mr. Freese. I think it is dangerous because it is going to lead
to greater resistance down the line.
Mr. Kucinich. How do you know that?
Mr. Freese. Because what we have seen is an increase in mul-
tiple herbicide-resistant weeds already.
Mr. Kucinich. So you use more chemicals. And we had testi-
mony earlier from Ann Wright about the evolution of crops that
contain herbicide resistance generally, right?
Mr. Freese. Yes. So, for instance, in the eighties and nineties,
a popular class of herbicides was called the ALS inhibitor.
Mr. Kucinich. And ALS stands for?
Mr. Freese. Acetolactate synthase. And they generated a huge
expanse of herbicide-resistant weeds, and those resistant weeds
were one reason farmers adopted Roundup Ready crops. Now we
are getting weed populations that are resistant to both herbicides.
In Missouri and Illinois, we have weed populations resistant to
three and four different herbicides.
Mr. Kucinich. For those who are not initiated, what are the im-
plications of that? Draw out for us the practical implications that
this scenario that you envision happening as a result of your sci-
entific background — tell us where we are going.
Mr. Freese. Well, we are headed toward more pesticide use, for
one thing. That is pretty clear. At the last superweed hearing, one
of the weed scientists spoke on the order of a 70 percent increase
in 2,4-D and dicamba use soon after the introduction of the 2,4-D
and dicamba-resistant soybeans.
Mr. Kucinich. What happens then?
Mr. Freese. One thing is you have greater levels of these resi-
dues of these herbicides on the crop. A little-known fact about her-
bicide-resistant crops is the companies seek increases in what are
called tolerances, the maximum allowable residue of the pesticide
on the crop. We have seen that repeatedly with Roundup Ready,
greatly increased glyphosate tolerances each time a new Roundup
Ready crop is approved.
Now, it is very troublesome when we think about that with more
toxic herbicides like 2,4-D and dicamba, both of which have been
linked to cancer in pesticide applicators and farmers. 2,4-D is a
likely endocrine disrupter; that is, a disrupter of our hormone sys-
tems which are so important in controlling our development, our
reproductive system, and our metabolism.
EPA was supposed to start looking at endocrine effects on all of
our pesticides in 1998, but hasn’t been funded to do that, and so
it is only just now getting started.
Mr. Kucinich. Are there any weed scientists to recommend an
approach other than Monsanto’s preference for dealing with weed
resistance to their product Roundup.
Mr. Freese. Can you restate that?
Mr. Kucinich. Is there another approach that weed scientists
would recommend in dealing with this problem of resistance?
Mr. Freese. Yeah, and as a matter of fact, it’s quite interesting
because there is a technique that’s long been used by organic grow-
ers, but also conventional growers. It involves planting winter
cover crops. And basically it just — it means after harvest of the
main crop, you can plant a cereal like rye, or a legume like hairy
93
vetch or clover. And this cover crop grows in the fall, and then
more in the spring, and it holds the soil, and it also absorbs excess
nitrogen and phosphorous fertilizer. And then in the spring, it’s
killed off and forms a thick mat into which you can plant your
main crop, that mat suppresses weeds physically. Sometimes the
cover crop also releases chemicals that inhibit the growth of weeds.
It’s a very, very beneficial practice, because again, it’s effective —
it effectively suppresses weeds and provides multiple other benefits
as well.
Mr. Kucinich. All right. I want to thank you for answering that.
Did you want to add something, Mr. Vroom?
Mr. Vroom. Yes, Mr. Chairman. So we’ve delved into a lot of de-
tail, but one important broad category of differentiation among
weed control with regard to crop protection products is whether the
chemistry is used after the weeds emerge, are sprayed on to the
weeds, or it’s applied to the soil as a pre-emergent control product.
The ALS herbicide Mr. Freese is talking about are pre-emergent
products, they are applied to the soil before the crop is planted.
And so the — while the registrants for those chemicals that are pre-
emergent products oftentimes do have protective tolerance levels,
should some tiny amount be left in the soil and then get into the
crop plant, there’s virtually no evidence of residual in the actual
crop from those kinds of products that are applied by the farmers.
So big difference there between the technologies that all herbi-
cides aren’t applied the same way. And again, I think we come
back to the industry, farmers, the USDA and the extension are all
looking at redeploying a lot of old technologies — I’m certain that
Monsanto and others have already reinvented some of the formula-
tion technologies so that it can be better managed than it was
when that particular product was more prominently used.
And so it’s all part of the solution, and I think what you’re draw-
ing out here is that we all have to work together, reinvent old prod-
ucts, because we also have evidence, and I’ve got a study here that
I would also like to ask you to consider submitting into the record
by
Mr. Kucinich. You can submit it.
[The information referred to follows:]
94
June 2010 No. 128
Agrochemical Industry R&D
in 2009, the level of research and development expenditure for the fifteen leading
companies within the agrochemical industry is estimated to have increased by almost
1 5% in nominal US dollar value to reach a total of $5196 m. Because of the relative
change in the value of the US dollar versus the Euro during the year, in Euro terms
the increase is closer to 7,0%,
Since 2000, the overall level of R&D expenditure incurred by the 15 leading
companies in the agrochemical sector has grown at a compound annual growth rate
(CAGR) of 5,0%, raising the level of R&D expenditure from $3360 million to a total of
$5196 million in 2009,
Total R&D Expenditure by the Leading Agrochemical Companies
2000 2001 2002 2003 2004 2005 2006 2007 2008 2009
Although the overall level of R&D expenditure by these 15 leading companies
increased in 2009, the value of expenditure devoted to conventional agrochemical
R&D actually fell back by 2,2% in nominal terms in 2009 to reach $2648m. In
contrast to this the level of R&D expenditure devoted by these fifteen leading
companies in the seed and trait sector, in the same time period, increased by 5,7% in
2009 over 2008 to reach $2548 m.
As outlined above, one of the key factors driving industry R&D expenditure has been
the increasing focus by several of the leading companies on the seed and trait
sector. As a result of the higher rate of growth, the overall proportion of the R&D
budget of the fifteen leading companies devoted to the seed and trait sector has
increased from 35,7% in 2000 to reach 49,0% last year. This result reflect a
compound growth rate (CAGR) of 8.7% per annum in seed and trait R&D since 2000,
compared to the equivalent value of 2.3% per annum for conventional agrochemical
R&D expenditure.
95
It is evident that the environment for chemical crop protection R&D is becoming
exceedingly more competitive, the cost of developing a new active ingredient is
increasing (see AgriFutura 125, March 2010), whilst the regulatory environment is
also becoming stricter, particularly in the EU with the updating of the requirements for
re-registration. This coupled with the shift in R&D focus by the major companies to
seeds and traits and the consolidation of the industry has not only reduced the
number of companies involved in basic agrochemical R&D, but also resulted in these
companies becoming more selective regarding which product candidates are
selected to advance from research into development. These combined factors have
resulted in fewer new active ingredients being introduced.
It is also evident that the growth in the uptake of GM crops has resulted in a
reduction of R&D activity in sectors affected by GM technology, notably soybean
herbicides and cotton insecticides. Whilst a number of new insecticides for
Lepidoptera control have been introduced recently, it is notable that the key crop
focus for these products is fruit & vegetables, rather than the traditional market for
Lepidoptera control products, cotton, a sector which is now dominated by B.t.
technology.
Product Introductions and R&D by Crop
Number of new Active Ingredients
Time period
1980/1989
1990/1999
2000/2009
In R&D
Herbicides
Cereals
15
12
12
Oj
Soybean
11
10
1
0
Maize
2
10
9
1
Rice
11
19
14
4
F&V
2
1
0
1
Other
10
5
2
1
Totai
51
57
38
10
Insecticides
F&V
11
16
15
6
Rice
5
2
3
3
Cotton
9
12
3
1
Others
4
7
5
3
Total
29
37
26
13
Fungicides
F&V
13
9
17
6
Cereals
14
16
8
8
Rice
9
5
7
5
Others
0
0
0
1
Total
36
30
32
20
Others
7
3
5
1
Total
123
127
101
44
Averageannual rate of introduction
12 3
12.7
10.1
8.8
rhe final line
of the table shows
the average rate of
new active
ingredient
introduction by decade, and indicates a slowdown in the rate of new products coming
to the market. At present there are 44 product candidates in the development stage,
which are anticipated will enter the market within the next five years, if this is realized
then the average rate of new introduction will fail to 8.8 products per annum, in
comparison with 1 0 per annum in the 2000s and 1 2.7 per annum in the 1 990s.
Despite the attractions of the seed sector, significant opportunities in the
agrochemical market are still evident, notably as a result of re-registration issues in
the EU and especially following the adoption of revised regulations at the end of
2009. As endocrine disruption is becoming an issue, the registrational position of a
number of products has been brought in to question, some of which hold important
positions in resistance avoidance strategies. Removal of these products from the
market would clearly create an opportunity for new active ingredients.
96
The table below compares R&D expenditure with market performance since 2000.
R&D Expenditure Compared to Market Performance
Market $m
2000
2008
2009
2009/08 %
2009/00% p.a.
GM Seed
2194
9150
10570
15.5
19.1
Conventional Seed
14269
16870
16160
-4.2
1.4
Total Seed
16463
26020
26730
2.7
55
Agrochemical
31977
46130
43720
-5.2
3.5
Overall Total
48440
72150
70450
-2.4
4.2
R&D $m
2000
2008
2009
2009/08 %
2009/00% p.a.
Seed and Traits
1200
2411
2548
5.7
8.7
Agrochemicals
2160
2707
2648
-2.2
2.3
Overall Total
3360
5118
5196
1.5
5.0
Since 2000, the total seed market (GM and Conventional) has grown at an average
annualised rate of 5.5% p.a., whilst Seed and Trait R&D expenditure for the leading
1 5 agrochemical companies has increased on average by 8.7% p.a. Over the same
period the agrochemical market (crop protection and non-crop) has grown by 3.5%
p.a., whilst R&D expenditure of the top 15 companies has grown by only 2.3% p.a.
indicating the continuing shift in R&D expenditure towards the seeds and traits area.
Company Sales and R&D Expenditure 2009
Sm
$!Ti
In 2009, Monsanto was the leading company in terms of R&D expenditure on
agrochemicals and seeds & traits, it is clear that almost all R&D expenditure by
Monsanto is devoted to the seeds and traits area, with a modest level of
agrochemical R&D limited to product defense, formulation development and seed
treatments; the company is no longer involved in the research of new chemical active
ingredients. The second leading company, again both in terms of sales and R&D
expenditure, is Bayer. Over the last few years, Bayer has been increasing the
proportion of its R&D budget to seeds and traits however currently the majority of the
R&D budget is targeted at conventional agrochemical R&D.
Analysis of the active ingredients that have left the EU market due to either not being
supported through re-registration, or not achieving acceptance, indicates that the
market sector most affected has been fruit & vegetables. An increasing focus of R&D
on fruit & vegetable insecticides and fungicides is now evident, not only with chemical
crop protection products, but also with biologicals.
in addition to the R&D products listed in the table above, there are also believed to
be around 50 active ingredients in development in China, the majority are understood
to be analogues of chemistry already introduced outside China. These products are
not included in this analysis as the majority do not have GLP registration packages;
hence the potential for their introduction in markets outside China is limited.
If the rate of active ingredient introduction of the major companies also involved in
R&D in the seed sector is compared with time, then a slowdown in new product
introduction can be seen. Over the same time period the rate of introduction from
companies not involved in seed R&D has increased.
Rates of New Active Ingredient Introduction
A.I. introductions
Rate
A.I. introductions
Rate
since 1980
p.a.
since 1994
p.a.
Companies with Seed R&D
213
7.1
99
6.6
Others
138
4.6
79
5.3
Total
351
11.7
178
11.9
It can be seen that the rate of new active ingredient introduction by the companies
involved in seed R&D has declined from 7.1 products per annum on average over the
last thirty years to 6.6 p.a. over the last fifteen years. Conversely, the rate of
introduction from other companies has increased from 4.6 p.a. to 5,3 p.a. over the
same periods.
Active Ingredient Introduction and in R&D by Company
Introduced 1994-2009
Currently in R&D
Bayer
35
6
Syngenta
17
5*
BASF
19
.5*
Dow
19
2
Sumitomo
15
2*
DuF>ont
?
3*
Monsanto
1
0
Other Japanese
44
18
Rest
21
5
lo
178
46*-'
’ ^ 1 no ID CO IK ’If'p 1
Svi-fV-* Of' sf'U
It nt'v Jh
tl. t JUnctti
For the future it seems likely that investment in seed and trait R&D will continue to
outpace that of agrochemicals. In 2009 the overall spend on R&D for agrochemicals,
by the leading fifteen companies was $2648 m., down 2.2%, whilst expenditure by
these companies on seed and trait R&D increased by 5.7% to $2548 m. With the
crop protection market forecast to grow at 1.8% p.a. through to 2014 in 2009 dollar
terms, and the GM sector anticipated to expand by 4,0% p.a. over the same period, it
is likely that this shift in R&D emphasis is likely to continue.
Phillips McDougall Vineyard Business Centre
Copyright 2010 Saughland
Pathhead
Midlothian
EH37 5XP
Tel: 44 (0)1875 320611
Fax; 44 (0)1875 320613
For private circulation only. The information
contained in this report constitutes our best judgement
at the time of publication, but is subject to change,
Phillips McDougail do not accept any liability for any
loss, damage or any other accident arising from the
use of the information in this report.
98
Mr. Vroom. McDougal organization that shows that in the dec-
ade of the 1980’s and 1990’s, our crop protection companies were
able to discover and bring to market more than 50 new herbicide
products. In the decade of the 2000’s, that number has dropped to
38. And so it’s just a reminder that while our research goes on, we
found the ease to discover and most broad spectrum efficacious her-
bicides, and now we’re needing — now we’re looking for things that
are much more targeted and the need to reinvent the older prod-
ucts that are proven safe that can be reformulated and applied by
farmers in different ways. Thank you.
Mr. Kucinich. Thank you very much. I would just like to say in
response to the point that you raise something that’s obvious, that
we’re really probing here into cause and effect. Some causal chains
begin in nature. With biotechnology and genetic engineering, some
causal chains begin in the laboratory. So we just are trying to find
out which way things are going here, and doing the best we can.
Mr. Vroom. Thank you.
Mr. Kucinich. Thank you for being here. I want to thank each
of the witnesses. You’ve given this subcommittee additional infor-
mation; we’ll continue to seek more. We’re going to do it in a dis-
passionate way. Just try to gather information so that we can rec-
ommend policies that would be in the best interest of all parties
concerned.
I do take note of Mr. Miller’s testimony that government does
have a role to play, it’s not only the industry that’s the question
here, and I appreciate that you raise that.
So without any further testimony, this is the Domestic Policy
Subcommittee of Oversight and Government Reform. The subject of
today’s hearing “Are ‘Superweeds’ an Outgrowth of USDA Biotech
Policy?” This is the second part of this hearing.
The subcommittee will continue to retain jurisdiction over this
matter. I want to thank the staff for its presence here today and
its participation in helping to structure this hearing. There being
no — and thank the witnesses certainly. There being no further
businesses before this subcommittee, this subcommittee stands ad-
journed. Thank you.
[Whereupon, at 4:08 p.m., the subcommittee was adjourned.]
[Additional information submitted for the hearing record follows:]
99
Response to Questions From the Domestic Policy Subcommittee of the House
Oversight and Government Reform Committee
With Regard to Herbicide-Resistant Weeds Following Testimony Delivered Before
the Subcommittee on September 30, 2010
by William Freese
Science Policy Analyst
Center for Food Safety
What does your research reveal about when Monsanto should have known and reacted
to development of Roundup-resistant weeds?
Prior to the confirmation of the first glyphosate-resistant weed population in 1996, weed
scientists had collected abundant evidence showing that resistant weeds were likely to
evolve with frequent use of glyphosate. For instance, Duncan & Weller [1987) conducted
experiments on five biotypes of field bindweed that had been shown by DeGennaro &
Duncan (1984) to have substantial variability in their tolerance to glyphosate. They
concluded from their experiments that: "These results further suggest that glyphosate
tolerance in a field bindweed population could be enhanced by selection pressure in the
form of repeated glyphosate applications.”^ Boerboom et a! (1990) similarly found a
three-fold range of glyphosate tolerance in specimens of the weed birdsfoot trefoil.^ As
with field bindweed, repeated glyphosate applications would kill off the more susceptible
types, leaving the more tolerant to propagate, potentially leading to a resistant population
quite rapidly
In 1996, the eminent weed scientist Dr. Jonathan Gressel reviewed some of the evidence
pointing to the likelihood that glyphosate-resistant weeds would emerge, and rebuked
Monsanto scientists for giving the false impression that glyphosate was "invincible" to
* DeGennaro, F.P. & S.C. Weller (1984). "Differential susceptibility of field bindweed (Convolvulus arvensis)
biotypes to glyphosate," Weed Science 32: 472-476; Duncan, C.N. & S.C. Weller (1987). "Heritability of
glyphosate susceptibility among biotypes of field bindweed,” The journal of Heredity 78: 257-60,
2 Boerboom, C.M. et al (1990). "Mechanism of glyphosate tolerance in birdsfoot trefoil," Weed Science 38:
463-467.
3 Although “tolerance" and "resistance" to herbicides are formally distinct, in practice the terms are often
used interchangeably by weed scientists, in common usage, tolerance denotes a weed that withstands lower
doses of an herbicide, while resistant weeds survive higher doses.
100
resistance.'* Dr. Gressel first presented the following excerpt of a paper written by
Monsanto scientists Steven Padgette and colleagues for a symposium in Spain.®
“Evolution 'of weed resistance to glyphosate appears to be an unlikely event, based
on the lack of weeds or crops that are inherently tolerant to glyphosate and the
long history of extensive use of the herbicide resulting in no resistant weeds.
Unique properties of glyphosate such as its mode of action, chemical structure,
limited metabolism in plants, and lack of residual activity in soil indicates that the
herbicide exerts low selection pressure on weed populations' (Padgette et a!
1995)." (emphasis added)
As noted above, at least two weeds had been shown in peer-reviewed studies in the 1980s
and 1990 to have precisely the "inherent tolerance to glyphosate" of which Monsanto's
Padgette and colleagues profess ignorance in 1995, Many other weeds, such as
morningglories, yellow nutsedge, field horsetail, prairie cupgrass, wild buckwheat,
and dayflower species have long been recognized as glyphosate-tolerant.® The statement
that glyphosate "exerts low selection pressure on weed populations" is grossly misleading,
in that it considers only certain chemical properties of glyphosate, and ignores the much
more important factor of how glyphosate is used. The frequency, intensity and timing of
glyphosate use with Roundup Ready crops generate tremendous selection pressure for
evolution of resistant weeds, whatever "unique properties" the glyphosate molecule may or
may not possess.
Dr. Gressel’s commentary on the quote presented above makes it clear that Monsanto
scientists were not innocently wrong, but rather guilty of intentional misrepresentation.
Speaking directly to Padgette and colleagues’ 1995 paper that contains the statement
quoted above, Gressel said:
"The impression of invincibility from resistance was enhanced by not citing the
growing literature on the known inter-, and especially intra-specific, genetic
variability in quantitative levels of glyphosate resistance. This literature was
known to the various authors, yet must have been considered irrelevant. In turn,
this led to dismissing the need to set resistance management strategies in
motion, and the ensuing appearance of a giyphosate-resistant population in the
management system and the weed where it was most likely to occur.” (emphasis
added).
■> Gressel, J. (1996). "Fewer constraints than proclaimed to the evolution of giyphosate-resistant weeds,"
Resistant Pest Management Newsletter, Vol. 8, No, 2 (Winter 1996), pp, 20-23.
http://whalonlab.msu.edu/Newsletter/pdf/8_2.pdf.
5 Padgette, S.R., X. Delannay, L. Bradshaw, B. Wells & G. Kishore (1995). “Development of glyphosate-tolerant
crops and perspectives on the potential for weed resistance to glyphosate," in: International Symposium on
Weed and Crop Resistance to Herbicides, Cordoba, Spain. Abstract 92.
« Boerboom, C. & M.D. Owen (2006). "Facts about Glyphosate-Resistant Weeds," The Glyphosate, Weeds and
Crop Series, Purdue University Extension, Dec, 2006.
http://www.extension.purdue.edu/extmedia/GWC/GWC-l,pdf,
2
101
Dr. Gressel goes on to discuss the ample evidence for likely resistance that Monsanto
scientists had conveniently ignored. For instance, he cites and discusses eight published
scientific articles that present eight different mechanisms by which weeds might evolve
resistance to glyphosate. The lead author of one of these papers was Monsanto scientist
Stephen Padgette. We discuss Dr. Gressel's reference to a glyphosate-resistant weed
population below.
Why would Monsanto scientists misrepresent this important issue of glyphosate's potential
to foster glyphosate-resistant weeds? (And they did this not only in Padgette et al (1995),
but in a flurry of papers presenting essentially the same distorted view, for instance:
Bradshaw et al (1995), Padgette et al (1996) and Bradshaw et al (1997)'^). The answer is
clear. In the mid 1990s when these papers appeared, Monsanto was in the midst of
launching the company's first Roundup Ready (RR) crop, RR soybeans, which were first
planted commercially in 1996. While Monsanto’s microscopic focus on the supposedly
“unique properties" of the glyphosate molecule had some success in quelling resistance
concerns (e.g. see Jasienuik 1996),® most weed scientists were not fooled. Dr. Gressel and
many others were convinced that Roundup Ready crop systems would likely do what two
decades of glyphosate use had thus largely far failed to do: foster rapid evolution of GR
weeds.
As early as 1990, public interest scientists published a strong critique of the herbicide-
resistant (HR) crop paradigm entitled Biotechnology’s Bitter Harvest, which highlighted the
high potential for HR weed evolution presented by HR crop systems, among other risks,
such as increased use of toxic herbicides.’ In 1992, Dr. Rebecca Goldburg (co-author of
Biotechnology's Bitter Harvest] published a peer-reviewed paper in the journal Weed
Technology, which made similar points. Interestingly, Dr. Goldburg conceded that HR crops
resistant to newer and safer herbicides (e.g. glyphosate vs. older, more toxic herbicides like
2,4-D) might offer some short-term benefits in terms of displacing more toxic herbicides,
but cautioned that: "resistant weeds already limit use of some of the newer chemicals, and
the availability of crops that tolerate the newer herbicides could further encourage the
evolution of resistant weeds..."*’
Weed scientist Dr. Brian Sindel (1996) made the same point in an article discussing the
first glyphosate-resistant weed population (discussed further below), quoting his colleague
Dr. Roger Cousens of Latrobe University to the effect that herbicide-resistant crops that
rely entirely on herbicides for weed control are "in danger of crashing down around our
* See Gressel (1996), op. cit., for references.
8 Jasieniuk, M. (1996). “Constraints on the evolution of glyphosate resistance in weeds,” Resistant Pest
Management Newsletter, Vol. 7, No. 2 (Winter 1995), pp. 25-26.
http://whaIonlab.msu.edu/Newsletter/pdf/7_2.pdf.
’ Goldburg, R., |. Rissler, H. Shand, C. Hassebrook (1990), Biotechnology's Bitter Harvest: Herbicide-Tolerant
Crops and the Threat to Sustainable Agriculture, Biotechnology Working Group, March 1990.
Goldburg, R. (1992). “Environmental concerns with the development of herbicide-tolerant plants," Weed
Technology 6: 647-652.
3
102
ears" due to weeds developing resistance to herbicides.^ Dr. Sindel also explained why
glyphosate had thus far fostered so little weed resistance. Used as a “pre-sowing,
knockdown herbicide” (Australian terminology for pre-emergence burndown use) with
conventional crops, any resistant weeds would likely be killed off by tillage or subsequent
use of other herbicides. Such would not be the case with Roundup Ready crops, where
glyphosate would likely be the only weed control tool applied. Dr. Sindel concluded by
stating that “glyphosate must be retained as an effective herbicide. Integrated weed
management, a combination of weed control techniques, is promoted to avoid the further
emergence of herbicide resistance."i2
In 1997, Dr. Ian Heap, who has long managed an online database that registers the
occurrence of herbicide-resistant weed populations worldwide, also warned of the need for
resistance management with Roundup Ready crops;
"The recently developed glyphosate-resistant crops will need to be used in rotation
with conventional cultivars, and in conjunction with non-chemical weed control
and other herbicides if the selection of glyphosate-resistant weeds is to be avoided."
(emphasis added).!^
Finally, we cite a prescient 1992 article by EPA scientist Dr. Diana Horne in the journal
Weed Technology entitled "EPA's response to resistance management and herbicide-
tolerant crop issues."^'* In 1992, U.S. regulation of genetically engineered (GE) crops was
still in the planning stages, and EPA’s role had not yet been fixed. While it was clear that
EPA would regulate insecticide-producing insect-resistant GE crops by virtue of its
traditional role as pesticide regulator, "EPA’s role in the regulation of herbicide-tolerant
(HTC) varieties is more oblique. EPA has no direct authority over the plant, as herbicide
tolerance does not include production of pesticidal compounds. But, EPA will regulate new
herbicide uses."
Dr. Horne went on to discuss the widespread occurrence of weeds resistant to other
herbicides, and EPA's "strong interest in promoting the development and broader use of
integrated pest management (1PM) technologies" to forestall evolution of resistant insects
and weeds and reduce use of herbicides overall and their adverse environmental impacts.
In a passage that could not have escaped Monsanto, she posed the following question:
"Would it be appropriate, for example, for the Agency to require that transgenic
plants (both of the pesticidal, as well as the herbicide-tolerant varieties), be used
only within the context of a resistance management program?" (emphasis
added)
n Sindel, B. (1996). “Glyphosate resistance discovered in annual ryegrass," Resistant Pest Management
Newsletter, Vol. 8, No. 2 (Winter 1996), pp. 23-24.
“ Ibid.
Heap, 1. (1997). "Occurrence of herbicide-resistant weeds worldwide,” Pesticide Science 51; 235-243.
Horne, D. (1992). "EPA’s response to resistance management and herbicide-tolerant crop issues," Weed
Technology 6: 657-661.
4
103
Unfortunately, Dr. Horne's paper was prescient only in its discernment of the weed
resistance threat posed by HR crop systems. While EPA went on to institute mandatory
resistance management for insect-resistant GE crops, its halting efforts to establish even
weak voluntary weed resistance management plans for glyphosate-resistant and other HR
crops foundered on opposition from HR crop developers and growers.*®
Why were Monsanto scientists virtually alone in denying the threat of glyphosate-resistant
weeds? The answer seems clear. Any resistance management plan with a chance to be
effective would have to limit selection pressure by imposing restrictions on the use of
glyphosate and/or Roundup Ready crops. This is consistent with Dr. Heap's statement
above that RR crops would need to be rotated to conventional cultivars to avert further
weed resistance. We note that EPA’s successful insect resistance management (IRM) plans
for insect-resistant crops involves the requirement that growers plant substantial refugia
of non-Bt corn and cotton alongside their Bt crop plantings.*® In short, resistance
management would have meant a perhaps substantial crimp in Monsanto's profits via
reduced sales of glyphosate and RR crop seed. Another important factor is that farmers
often respond to lower-level glyphosate-resistance in weeds by "increasing the magnitude
and frequency of glyphosate applications”*'* - a counterproductive, but for Monsanto
profitable, response. This helps explain why Monsanto has always recommended using the
"full rate" of glyphosate as its keystone "weed resistance prevention" strategy, despite
rebukes from weed scientists that use of alternatives to glyphosate is the proper
response.18
Still, didn’t Monsanto understand that it had a longer-term financial interest in preventing
the evolution of glyphosate-resistant weeds so as to prolong the useful life of its Roundup
Ready technology? Dr. Gressel in fact appeals to Monsanto with this "enlightened self-
interest" argument in the conclusion of his piece, cited above. CFS believes that such
appeals are based on a misunderstanding of the market forces guiding biotechnology-
pesticide firms such as Monsanto.
First, consider that pesticide industry has long familiarity with weed resistance, which has
been evolving since the 1970s. Second, that the pesticide treadmill phenomenon whereby
a frequently used herbicide fosters resistance, leading to supplementation or replacement
with a new "mode of action" (different type of herbicide), has been a major driver in the
pesticide industry's development and sale of new herbicides. Finally, consider that the
jones, Jim [2010]. Testimony before the Domestic Policy Subcommittee, House Oversight and Government
Reform Committee, Sept. 30, 2010. Mr. Jones is the EPA's Deputy Assistant Administrator for Chemical Safety
and Pollution Prevention.
http://oversighthouse.gov/index.php?option=com_content&view=article&id=5121:webcast'and-testimony-
for-hearing-are-superweeds-an-outgrowth-of-usda-biotech-poiicy-part-ii&catid=66:hearings&Itemid=31.
Jones [2010], op. cit.
NRC [2010). The Impact of Genetically Engineered Crops on Farm Sustainability in the United States,
National Research Council, National Academy of Sciences, 2010 (pr-publication copy), p. 2-15.
18 Hartzler, B. [2004). Weed Science, Iowa State University, December 17, 2004.
http://www.weeds.iastate.edu/mgmt/20Q4/twoforone.shtml: Hartzler, B.etal [2004). "Preserving the
value of glyphosate," Iowa State University, Feb. 20, 2004, a joint statement by 12 leading Midwestern weed
scientists. http://www.weeds.iastate.edu/mgmt/20Q4/preserving.shtml .
5
104
most profitable period for sale of patented HR seeds and their associated herbicides is
limited to the 20-year terms of the associated patents.
Glyphosate went "off-patent” in the year 2000. Despite competition from cheaper generic
versions of glyphosate, Monsanto continued to sell large quantities of its Roundup
formulations of glyphosate after the year 2000 by tying the use of Roundup to its patented
Roundup Ready seeds.i* The major patent on Roundup Ready soybeans (the largest
acreage RR crop) expires in 2014.20 pq^ a variety of reasons, Monsanto has been relatively
unsuccessful in selling farmers on its second generation RR2 soybeans: some object to their
high price; others that they do not provide the promised yield boost; and still others find
the value of the technology eroded by glyphosate-resistant weeds, which require use of
expensive, supplemental herbicides anyway .21 For many, it is a combination of these
factors - more expensive seed plus the expense of additional herbicides to combat GR
weeds. When Roundup Ready 1 soybeans go off-patent in 2014, cheap generic versions
will presumably become available; and farmers will likely have the legal right to save and
replant them, offering further potential savings. Finally, other firms are poised to introduce
their own glyphosate-resistant crops, posing a competitive challenge to the company .22 in
short, Monsanto could be facing the imminent loss of its lucrative Roundup Ready soybean
franchise, followed by loss of market share in Roundup Ready corn and cotton when their
associated patents expire.
What would persuade farmers to continue buying Monsanto soybeans, corn and cotton?
One strong enticement would be the ability to control glyphosate-resistant weeds. Indeed,
Monsanto has developed and is awaiting USDA approval of soybean varieties resistant to
the broad-spectrum herbicide dicamba, which will be "stacked" with resistance to
glyphosate as well .23 These dual HR soybeans are being offered as a tool to help manage
glyphosate-resistant weeds. Triple-stack versions of corn and cotton - which combine
resistance to dicamba, glyphosate and a third herbicide, glufosinate - are not far behind.2'‘
Finally, consider the market potential for these dual and triple-stack HR crops, which will
certainly be more expensive than their Roundup Ready-only predecessors. Clearly, those
farmers with GR and other HR weed-infested fields would be the most likely market, since
Barboza, D. (2001). "The Power of Roundup; A Weed Killer Is a Block For Monsanto To Build On," New
York Times, August 2, 2001. http://www.nytimes.eom/2001/08/02/business/the-power-of-roundup-a-
weed-killer-is-a-block-for-monsanto-to-build-on.html.
™ Pollack, A. (2009). "As patent ends, a seed's use will survive," New York Times, December 18, 2009.
http://www.nvtimes.com/2009/12/18/business/18seed.html .
2' Agrimoney (2010). "Monsanto faces revenue risk if seed drive misfires," Agrimoney, August 16,2010.
http://www.agrimoney.com/news/monsanto-faces-revenue-risk-if-seed-drive-misfires-2111.html; Bennett,
D. (2009). "Conventional soybeans draw interest," Delta Farm Press, April 3, 2009,
http: //del tafarmpress.com /soybeans /conventinnal-.snvhe3ns-04n3/ .
22 See recent entries for glyphosate-tolerant crops - Stine Seed, Bayer CropScience and Pioneer - at
http://www.aphis.usda.gov/biotechnology/not_reg.html.
23 Mon.sant<) (2010a). “Monsanto completes key regulatory submission for soybeans withy dicamba herbicide
2'* Monsanto (2010b). “Monsanto Announces Record 11 Project Advancements in Annual Research and
Development Pipeline Update," News Release, Jan 6, 2010.
6
105
those without resistant weeds would have little incentive to purchase pricier multiple HR
crops if cheaper Roundup Ready-only varieties do the job. Glyphosate-resistant weeds are
currently estimated to infest 6% of the 173 million acres planted to soybeans, corn and
cotton in the U.S., or 10.4 million acres.^s xhis represents roughly four-fold greater acreage
than in late 2007, when CFS collated figures from the same definitive data source on
resistant weeds and found the GR weed-infested acreage totalled just 2.4 million acres.
Though no one can say with certainty how rapidly GR weeds will emerge in the future,
Syngenta's weed resistance manager. Chuck Foresman, estimates that 38 million acres - or
one of every four row crop acres - will be infested with GR weeds in the U.S. by the year
2013.2S This 38 million acres of GR weed-infested fields would represent a substantially
greater market opportunity for the sale of Monsanto’s dual and triple-resistant HR crops
than the current 10 million acres. Clearly, glyphosate-weed evolution opens up substantial
new marketing opportunities for Monsanto. In contrast, serious stewardship measures to
slow or stop GR weed evolution works against the company’s financial interest.
It will perhaps be objected that this is a cynical interpretation of Monsanto’s motives. Not
at all. CFS is intimately familiar with Monsanto’s long-standing voluntary stewardship
efforts with Roundup Ready crops, whose ostensible purpose is indeed to slow the
emergence of GR weeds. While it is beyond the scope of these comments to elaborate, we
have done so elsewhere, demonstrating that some of Monsanto's supposed resistance
management recommendations are not only ineffectual, but exacerbate the problem by
supporting continual planting of Roundup Ready crops every year.^^ However, the bottom
line of rapidly expanding GR weed populations speaks more than any analysis to the
inefficacy of Monsanto’s recommendations. Of course, having such programs in place is
good public relations. And it must be said that biotech-friendly USDA regularly touts such
voluntary, Monsanto-sponsored measures as an excuse not to take regulatory action,
ignoring their failure.^s Recall, however, that the EPA’s Jim Jones has testified that biotech
companies successfully foiled weak attempts by EPA and USDA to introduce voluntary
weed resistance management programs under their auspices in 2001. As virtually the sole
provider of genetically engineered HR crops at that time, the objectors must have included
Monsanto.
Yet in fairness, it should be stated that Monsanto is not alone in anticipating considerable
profits from the GR weed epidemic. As recently reported in the Wall Street Journal,
pesticide-biotechnology companies are investing hundreds of millions of dollars in new HR
crops as a temporary hi-tech "fix" to glyphosate-resistant weeds. Dow Agrosciences
scientist Jim Jachetta stated that these new HR crops represent "a very significant
USDA APHIS (2010). "Draft environmental assessment of supplemental request for partial deregulation of
sugar beet genetically engineered to be tolerant to the herbicide glyphosate," USDA Animal and Plant Health
Inspection Service, October 2010, p. 93.
Syngenta (2009). “Leading the fight against glyphO!>ate resistance,”
http://www.syngentaebiz.com/DotNetEBiz/lmageLlbrary/WR%203%20Leading%20the%20Fight.pdf.
2’ CFS (2010). CFS Science Comments on USDA APHIS's draft environmental assessment for partial
deregulation of Roundup Ready sugar beets,” Dec. 6, 2010. http://www.centerforfoodsafety.org/wp-
content/uploads/2010/12/RRSB-Partial-Dereg-EA-Science-Comments-BF.pdf.
28 USDA APHIS (2010), op. cit
7
106
opportunity" and “a new era” for chemical companies?* Mr. Jachetta was probably thinking in
particular of Dow’s new com and soybeans varieties that resist high doses of 2,4-D, a close
chemical cousin of dicamba that formed part of the Vietnam War defoliant Agent Orange. Dow
took the opportunity of press attention to the GR weed epidemic to issue a press release touting
its 2,4-D tolerant crops as a fix to GR weeds.^**
When should Monsanto have known and reacted to the development of Roundup-resistant
weeds? The short answer is, no later than the introduction of the first Roundup Ready crop in
1996. As documented above, there was widespread concern in the weed science community that
Roundup Ready systems would foster GR weeds, and Monsanto scientists not only ignored the
evidence, but in several publications intentionally gave the false impression that resistant weeds
would not emerge, so as to avoid resistance management regulations that the EPA was seriously
considering, and that would have limited the company’s profits.
However, there is also solid evidence that Monsanto scientists denied the existence of the first
confirmed GR weed population, rigid ryegrass in Australia, in a peer-reviewed scientific
publication. This is the GR weed population referred to by Dr. Gressel (in the above-cited
article), who stated that Australian researchers had confirmed to him its existence in discussions
at a weed science conference in June of 1 996. The Australian press had reported the resistant
ryegrass even before that. In another paper (also cited above) appearing in the same issue of the
same journal as Dr. GresseTs, Dr. Brian Sindel stated that: “Researchers at the Centre for
Conservation Farming at Charles Stuart University at Wagga Wagga confirmed that the ryegrass
was resistant to glyphosate,” and that Monsanto Australia’s Bill Blowes was working with the
University to determine the cause of the resistance. Nevertheless, Monsanto scientists said not a
word about this GR weed in a 1997 paper that appeared in the journal Weed Technology,^' and in
fact repeatedly denied the existence of any “verified” GR weed population in world, despite the
confirmation cited above.^^ Though the editors received the original paper in April of 1995, they
note that a revised version was received on July 1 7, 1 996 - at least weeks and probably months
after University researchers had confirmed the resistance.
This historical footnote, however revealing it may be as to Monsanto’s (lack of) corporate
character, is of minor importance now. Much more significant is the company’s continuing
obiliscation of the glyphosate-resistant weed issue, even today, as it strives to introduce new
Roundup Ready crops (such as alfalfa and sugar beets) free from the regulation that is urgently
As quoted in: Kilman, S. (2010). “Superweed outbreak triggers arms race,” Wall Street Journal, June 4,
2010 .
5“ Kaskey, J (2010). "Dow plans new trait to combat Roundup-resistant weeds,” Bloomberg, May 05, 2010,
http://www.businessweek.eom/news/2010-05-05/dow-plans-new-trait-to-combat-roundup-resistant-
weeds-update2-.html.
Bradshaw, L. et al (1997). “Perspectives on glyphosate resistance," Weed Technology 11: 189-198.
32 In one passage that reveals they know of the resistant population, Bradshaw and colleagues tellingly state
that "evidence of weeds evolving resistance to this herbicide [glyphosate] under field situations has not been
verified," citing two papers from 1993 and 1994. Elsewhere in the paper, they state: "no verified reports of a
glyphosate-resistant plants have arisen following an extensive histoiy of broad-scale glyphosate applications
in the field.” Yet as noted by Dr. Gressel, the population had been confirmed as resistant by no later than June
of 1996.
8
107
needed to prevent further epidemic spread of weed resistance. Monsanto’s position today is that
planting a GR crop every year in the same field is consistent with forestalling GR weed
evolution, provided only that it is not the same GR crop every year. This position - uncritically
adopted by USDA^^ - stands in direct contradiction to the concensus view of every legitimate
member of the weed science community, as expressed in a recent National Research Council
report, which stated explicitly that the value of crop rotation to forestall glyphosate-resistant
weeds is undermined when the crops in the rotation are glyphosate-resistant.^''
Thus, the question of when should Monsanto have known and reacted to the development of
Roundup-resistant weeds is perhaps wrongly put, as it implies that the company has in fact
reacted in an effective manner to glyphosate-resistant weeds. The truth, however, is that
Monsanto continues to employ its considerable expertise not to forestall GR weeds, but rather to
obfuscate the issue. This in turn serves to the interests of avoiding any serious resistance
management, selling as many Roundup Ready seeds and as much Roundup as possible, and
generating (via GR weeds) market demand for its successor herbicide-resistant crops.
Can you elaborate on why multiple-resistant crops are not, as some claim, a solution to
the resistant weed epidemic?
Agrichemical-biotechnology companies have invested hundreds of millions of dollars in the
development of crops resistant to high rates of older, more toxic herbicides as the
supposed "solution” to glyphosate-resistant weeds.^® In most cases, such crops are
resistant to multiple herbicides, often including glyphosate.
Prominent examples include corn, soybeans and cotton resistant to 2,4-D, developed by
Dow Agrosciences; and soybeans, corn and cotton resistant to dicamba, developed by
Monsanto. Dow's 2,4-D resistant corn also resists the "fop" class of ACCase inhibiting
herbicides,36 and will be offered with resistance to glyphosate and/or glufosinate as well
for triple or "quad-stack” resistance to three or four major classes of herbicide. Dow's
soybeans will be resistant to glufosinate and glyphosate as well as 2,4-D, for "triple-stack"
resistance to three herbicide families.^^ Monsanto's dicamba-resistant soybeans will also
be resistant to glyphosate, while the company has triple-stack versions of corn and cotton
in the works that resist dicamba, glufosinate and glyphosate.^® There are many other
33 CFS (2010), op. dt.
NRC (2010), op. dt, pp. 2-19, 2-20. See CFS (2010) for further support
5 Kilman, S. (2010). "Superweed outbreak triggers arms race,” Wall Street Journal, June 4, 2010.
36 Wright, T.R. et al (2010). "Robust crop resistance to broadleaf and grass herbicides provided by
aryloxyalkanoate dioxygenase transgenes/' PNAS 107: 20240-45.
See corresponding entries at USDA's list of genetically engineered crops pending nonregulated status, at
http://www.aphis.usda.gQv/biotechnQlogv/not reg.html . For Dow's plans to "stack" their 2,4-D-resistant
crops with glyphosate resistance, see; Kaskey, | (2010), "Dow plans new trait to combat Roundup-resistant
weeds,” Bloomberg, May 05, 2010, http://www.businessweek.eom/news/2010-05-05/dow-plans-new-trait-
to-combat-roundup-resistant-weeds-update2-.htmJ.
Monsanto (2010a). “Monsanto completes key regulatory submission for soybeans withy dicamba herbicide
tolerance trait,” News Release, )uly 13, 2010. http://monsanto.mediaroom.com/index.Dhn?s=43&item=863 .
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examples from other companies. In fact, fiilly eleven HR crops are awaiting deregulation
(approval for commercial cultivation) by USDA. These include 2,4-D resistant corn and
soybeans and dicamba-resistant soybeans.^?
The agrichemical-biotechnology industry intends for these crops to be sprayed with either
premixed herbicide cocktails containing some or all the herbicides to which the crop is
resistant, or with one or more of them sequentially, on an as-needed basis.*®
The rationale behind these multiple HR crop systems is simple. Weeds resistant to one
herbicide mode of action will be killed by the other(s). Unfortunately, such a simple-
minded approach to weed control will offer at best short-term relief to growers, and even
then only at the cost of sharply increased use of more toxic herbicides, with associated
adverse impacts on the environment and public health. In the medium to longer-term.
Nature will evolve clever responses to the chemical onslaught accompanying multiple-HR
crop systems in the form of multiple herbicide-resistant weeds. Real solutions to resistant
weeds, as opposed to temporary fixes, will have to involve a renewed commitment to
integrated approaches that prioritize non-chemical means of weed control.**
Weed resistance is an evolutionary phenomenon. Frequent, repeated use of an herbicide
selects for the preferential survival of those initially rare individuals with the genetic
predisposition to survive its application. Over time, the resistant individuals propagate and
gradually supplant susceptible weeds, resulting in a resistant weed population. The rate of
evolution is critically dependent on the "selection pressure." The more frequently an
herbicide is used, the more rapidly a resistant weed population will evolve.
Weeds have evolved many different mechanisms for surviving the application of
herbicides. The best studied are so-called "target-site” alterations in the enzyme whose
activity is normally blocked by the herbicide.''^ Disablement of the enzyme, which
performs some critical function in the plant, results in the death of the normal weed. The
target-site alteration makes the enzyme immune to the herbicide, conferring resistance on
the weed. If the herbicide is regarded as a key and the target enzyme as a lock, the normal
susceptible weed is killed when the key fits and opens the lock; the resistant weed has
evolved an altered lock that the herbicidal key no longer opens. Target-site alterations
normally confer resistance only to herbicides (one to many) that have the same “mode of
Monsanto (20 10b), “Monsanto Announces Record 1 1 Project Advancements in Annual Research and
Development Pipeline Update," News Release, Jan 6, 2010.
http://monsanto.mediaroom.com/index.php?s=43&!tem=788.
See USDA’s list of GE crops pending nonregulated status at
http://www.aphis.usda.gov/biotechnQlngv/not reg.html. last updated August 20, 2010.
Green et al (2007). "New multiple-herbicide crop resistance and formulation technology to augment the
utility of glyphosate," Pest Management Science 64(4): 332-9.
PSU (2010). “Suppressing Weeds Using Cover Crops in Pennyslvania," Pennsylvania State University,
College of Agricultural Sciences, Agricultural Research and Cooperative Extension, 2010.
*^2 For a recent review, see: Powles, S.B. & Q. Yu (2010). "Evolution in Action: Plants Resistant to Herbicides,"
Anna. Rev. Plant Biol, 61: 8.1-8.31.
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action.’’^ Each "mode of action" [corresponding to a family or class of herbicides]
represents a key that opens a particular lock."*^ Use of another herbicide with a different
mode of action is usually effective in killing these types of weed.
A weed may also become resistant by evolving the ability to generate many-fold more
copies of the target enzyme than are normally produced. In this case, the usual dose of the
herbicide is only able to shut down a certain small proportion of the much more numerous
enzyme molecules, while the others continue to function, allowing the thereby resistant
weed to survive.'*® In terms of the key-lock analogy, the herbicide still fits the lock, but
there are not enough herbicidal keys to open the more numerous locks.
Weeds may also evolve the ability to prevent or minimize internal movement of the
herbicide, once absorbed by the plant, to the tissues (e.g. roots) it must reach to exert its
killing effect, a mechanism known as reduced translocation. Still another mechanism
involves reduced absorption of the herbicide, for instance via leaves with a thicker or
tougher cuticle.'*® In these cases, the herbicide is unable to reach the lock (or not in
sufficient quantities) to open it and so kill the weed.
In all of these cases, switching to an herbicide with a different mode of action will often
provide control, at least for a time, though as discussed further below there are
complications.
Another different class of resistance mechanisms is called "metabolic degradation" or
"enhanced metabolism." Weeds with this form of resistance have the ability to degrade or
metabolize the herbicide into a form that is not toxic to the plant. Interestingly, this
mechanism often utilizes the plant's natural repertoire of detoxification enzymes, and
involves several classes of enzyme that are quite similar to those present in the livers and
other tissues of mammals, where they perform a similar detoxification function. Weeds
that evolve resistance via metabolic degradation often have the ability to detoxify
herbicides from several different families with different modes of action, making them
particularly difficult to control. Powles and Yu (2010), in the paper already cited, note that
the P450 class of detoxification enzymes represent "a very threatening resistance
mechanism, because P450 enzymes can simultaneously metabolize herbicides of different
modes of action, potentially including never-used herbicides."
For weeds resistant to different modes of action, see links under "Herbicide site of action" at
htt p: //WWW. weed science.nry/in.asp . Note that weeds highlighted in red with "Multiple - 2. 3, 4 or more
MOAs" indicate multiple herbicide resistant weed populations that withstand herbicides from the specified
number of herbicide families (MOAs = modes of action).
« "rhe reality is more complicated. Each herbicide family, corresponding to a distinct mode of action, is
actually comprised of several to dozens of active ingredients with slightly differing versions of the same basic
key which all open the same lock. Resistant weeds may have resistance to all or in some cases only some
members of herbicide family. In terms of our analogy, the lock may be altered such that none of the keys in a
particular family open it, or in such a way that some keys do and others do not fit it.
“5 A population of the most damaging glyphosate-resistant weed. Palmer amaranth, recently evolved this
mode of resistance. See: Gaines, T.A. et al (2010). "Gene amplification confers glyphosate resistance in
Amaranthus palmeri," PNAS 107; 1029-34.
“ For a recent review, see: Powles & Yu (2010), op. cit
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It is extremely important to observe that in most cases of weed resistance, the mechanism
involved remains unknown. It requires extremely sophisticated molecular analysis as well
and lengthy greenhouse testing to ascertain the mechanism of resistance in any particular
case. And weed scientists are rapidly discovering that some weed populations possess two
or more mechanisms of resistance to a single herbicide family, each lending only limited
resistance, but together offering higher and more threatening levels."*^ Nature's evolution
of weed resistance to herbicides takes quite ingenious turns,'*® and has far outpaced our
technical capacities to ascertain the causes. This becomes clearer when one considers the
vast numbers of resistant weeds in the world today.
According to the latest counts, over 400,000 fields in the world are infested with 348
herbicide-resistant biotypes of 194 different weed species."*® A biotype is a particular weed
species-herbicide family combination. The number of resistant biotypes exceeds the
number of resistant species because a particular weed species can have various
populations resistant to different herbicide families. Thus, separate tall waterhemp
populations with resistance to glyphosate alone, or to ALS inhibitors alone, represent two
distinct herbicide-resistant biotypes of a single weed species. The considerable excess of
biotypes to species indicates that a number of weed species have different populations that
are resistant to different herbicide modes of action.
The U.S. is by far the world leader in herbicide-resistant weeds, with 132 confirmed
resistant biotypes infesting roughly 30 million acres.®® Second place belongs to Australia,
with just 54 resistant biotypes.®* The most extensive populations of resistant weeds in the
U.S. involve three major herbicide modes of action: resistance to photosystem 11 inhibitor
class herbicides (chiefly the triazine class), which emerged chiefly in the 1970s; resistance
to ALS inhibitor family herbicides, which evolved mainly in the 1980s and early 1990s
when these herbicides were most heavily used; and resistance to glyphosate, which has
evolved in dramatic fashion over just the past decade.®^
Dinellii, G. et al (2006). “Physiological and molecular insight on the mechanisms of resistance to glyphosate
in Conyza Canadensis (L) Cronq. Biotypes,” Pesticide Biochemistry and Physiology 86: 30-41.
Gressel, J, & A.A. Levy (2006). "Agriculture: The selector of improbable mutations," PNAS 103: 12215-16.
See http://www.weedscience.org/In.asp.
Based on Center for Food Safety's compilation of data on herbicide-resistant weeds in the U.S. from the
International Survey of Herbicide- Resistant Weeds flSHRWl. at www.weedscience.org . on November 30,
2010. 30 million acres is near the upper-bound estimate of 32.3 million acres, which is closer to reality than
the lower bound estimate of 9.4 million acres. One indication of this is that a recent point estimate for
acreage infested by glyphosate-resistant weeds alone, made by Dr. Ian Heap, who manages the ISHRW
website, Is 10.4 milllion acres, exceeding the lower-bound estimate for acreage infested by all herbicide-
resistant weeds.
5’ http://www.weedscience.org/summary/CountrySummary.asp.
52 Benbrook, C. (2009). Impacts of Genetically Engineered Crops on Pesticide Use in the United States: The
First Thirteen Years," The Organic Center, November 2009, pp. 12-13 and Figure 2.4. Note that acreage
infested with glyphosate-resistant weeds as well as ALS inhibitor-resistant weeds has increased greatly since
February of 2009, which is when the figures upon which the figure Is based were compiled from ISHRW.
12
Ill
There are two basic pathways for weeds to evolve multiple herbicide resistance. In one
pathway, weed populations accumulate resistance mechanisms, one by one, to different
families of herbicides over years, while the other pathway (enhanced metabolism) involves
resistance to several families of herbicides all at once.
The one-by-one pathway is made possible by the fact that weed populations, once they
evolve resistance to a particular type of herbicide, often retain that resistance trait
indefinitely. This is not necessarily the case, but it is often so. Weed scientists once
assumed that an herbicide-resistant weed population would gradually disappear if farmers
stopped applying the pertinent herbicide. This notion was based on the theoretical idea
that in the absence of herbicide use, weeds without the resistance trait would always be
more vigorous - grow faster and bigger, produce more seed and pollen - than resistant
weeds. Thus, the latter would thrive only when the herbicide was used, but would be
“outcompeted" by normal weeds in its absence. The theoretical underpinning of this idea is
that the resistance trait imposes a “metabolic cost” or “fitness cost" That is, the resistant
weed expends energy and resources to generate the resistance mechanism, and
consequently has less to devote to growth and reproduction. According to this theory, the
resistant weed, though of course favored when the herbicide is used, is less vigorous and
fecund when not the herbicide is not applied.
As it turns out, this theory fits reality in some cases, but not in others. While some resistant
weeds are indeed less "fit” in the absence of the pertinent herbicide's use, others are as just
as fit or even more vigorous than their herbicide-susceptible brethren. As with
mechanisms of resistance, weed scientists simply have not determined the fitness of the
great majority of herbicide-resistant biotypes. Based on what little is known, however, we
can make the following cautious generalizations about resistance to the three major modes
of action presented above,
In general, weeds resistant to triazines tend to be less fit.ss Some weeds resistant to ALS
inhibitors exhibit lesser fitness, but others appear to have equivalent or even greater
fitness than susceptible weeds.®'* Since glyphosate-resistant biotypes have emerged rapidly
over just the past decade, in most cases their fitness has not been tested, and remains
unknown. Given the importance of glyphosate in world agriculture, and the rapid
emergence of glyphosate-resistant (GR) biotypes, elucidation of the fitness of GR weeds
should be a top research priority.®® Below, we discuss recent research that addresses this
question.
The fitness of a resistant weed population helps determine how well it thrives in situations
where farmers stop using the pertinent herbicide. Where fitness costs obtain, the resistant
weed population will subside. Where there is no fitness cost, or indeed the resistant weed
53 Gronwald, ),W, (1994). "Resistance to photosystem II inhibiting herbicides," in: Powles, S.B. & J.A.M.
Holtum, eds., Herbicide Resistance in Plants: Biology and Biochemistry, Ann Arbor, MI, Lewis, 1994.
S'* Tranei, P.), & T.R. Wright (2002). "Resistance of weeds to ALS-inhibiting herbicides: what have we
learned?" Weed Science 50: 700-712. Further examples are discussed below.
55 Vila-Aiub, M.M. et al (2009). "Fitness costs associated with evolved herbicide resistance alleles in plants,"
New Phytologist 184: 751-767.
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is more vigorous, ending use of the pertinent herbicide will do nothing to reduce resistant
populations. In these cases, resistant weed populations may will persist indefinitely or
perhaps even increase in scope even when the herbicide is not used.
Another important factor is the herbicide regime used by farmers. While we often think
simplistically of farmers switching to a new mode of action when afflicted with weeds
resistant to a particular herbicide, the reality is more complex. Often, herbicide A to which
one or several weeds have evolved resistance will still be effective in controlling other
troublesome weed species. In these cases, a common response of farmers is to supplement
herbicide A with herbicide B rather than stop using A altogether. Thus, weed populations
that have evolved resistance to A will continue to be exposed to it, and will continue to have
an advantage over their susceptible brethren. Even if there is a fitness cost to herbicide A
resistance, weeds resistant to it will continue to be favored.
The hope, of course, is that herbicide B will save the day by killing off weeds resistant to A.
This forms the basis of the agrichemical -biotechnology industry’s strategy of introducing
multiple-herbicide resistant crops. And this will sometimes be an effective strategy.
However, here too the reality is more complex. In those cases where the population of
weeds resistant to A is small, the supplementation (or switching) strategy has a greater
chance of success. However, this strategy is more likely to fail with larger resistant weed
populations, for the following reason.
The larger the population of weeds resistant to herbicide A, the more likely that there
exists among them individual weeds that have the rare genetic predisposition that confers
resistance to herbicide B. Suppose that a small population of herbicide A-resistant weeds
numbers 1,000, while a large population has 1 million individual plants. If on average only
one in a million weeds are resistant, it is unlikely that the small population harbors one,
while quite likely that the larger one does. It’s essentially a numbers game, equivalent to
tickets in a lottery. The small weed population is equivalent to buying Just a few lottery
tickets, while a large population corresponds to buying many tickets. The likelihood that
the A-resistant population has a “winning ticket" (an individual with resistance to B as well
as A) increases with its size. Winning the lottery, of course, is precisely what one wants to
avoid in this case.^^
What this means is that when a farmer either switches from herbicide A to herbicide B, or
supplements A with B, he may well select for weeds that have resistance to both herbicides.
This is the pathway by which weed populations accumulate resistance, one by one, to
different herbicide modes of action.
This is the theory, and of course theory (as we have seen above with fitness) can be wrong.
What do the facts on the ground tell us? One fact is that multiple herbicide-resistant weed
populations are on the rise in the U.S., and have increased sharply over just the past three
years. This is depicted in the table below, which is based on data compiled by Center for
“ This lottery analogy is borrowed (and adapted) from Iowa State University weed scientist Bob Hartzler.
See http://www.weeds.iastate.edu/mgmt/2004/twoforone.shtml.
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Food Safety on resistant weeds from the best available source, the International Survey of
Herbicide-Resistant Weeds (ISHRW)” The ISHRW is an online database that records
populations of herbicide-resistant weeds, and is supported by agrichemical-biotechnology
companies and academic weed scientists. Note that both the number of sites and acreage
infested figures are given in ranges due to the difficulty of estimating the precise
geographic extent of resistant weed populations. While most weed biotypes in the U.S. and
the world today still have confirmed resistance to just one mode of action, the table below
demonstrates a disturbing trend to proliferation of multiple herbicide-resistant (MHR)
weed populations.
Data on Populations of Multiple Herbicide-Resistant Weeds in the U.S Over the Past Three Years
Date
No. of
No. of
No. of States
Sites (n»in.)
Sites (max.)
Acreage
Acreage
Compiled
Species
Populations
(min.)
(max.)
11/21/07
11
20
12
679
1,459
25,829
245,755
11/30/10
14
32
15
1,016
3,078
127,799
1,258,605
% increase
27%
60%
25%
50%
111%
395%
412%
As the table shows, the number of MHR populations has increased by 60%, from 20 to 32,
since November 2007. More concerning is the increase in the aggregate number of sites
and acreage infested by these MHR populations. The number of sites infested has
increased by half to more than double over the past three years, while the acreage infested
has increased by a still more troubling 400%.
Two populations of MHR weeds that have emerged since November 2007 are resistant to
glyphosate and paraquat. However, the most prevalent MHR weeds resist applications of
ALS inhibitors and/or glyphosate. ALS inhibitor-resistant weeds emerged primarily in the
1980s and early 1990s following the introduction of herbicides with this mode of action in
1982. The fact that many weeds resistant to this mode of action have no loss of fitness (and
in some cases have enhanced fitness) means that their populations have tended to persist
or increase even as farmers made a large scale switch from reliance on them to use of
glyphosate in tandem with the adoption of glyphosate-resistant Roundup Ready crops
beginning in 1996. Many populations of ALS inhibitor-resistant weeds are also extremely
large, infesting from hundreds of thousands to millions of acres. Two populations (in
Missouri and Illinois) infest anywhere from 2 to 5 million acres each.
Over the past 14 years, glyphosate has largely displaced ALS inhibitors on the three crops -
soybeans, cotton, and to a lesser extent corn - where Roundup Ready varieties have
become predominant. These are also the three crops that receive the bulk of herbicides
applied in U.S. agriculture as a whole. Consequently, it is no surprise that the majority of
weeds evolving resistance over the past decade have become resistant to glyphosate. As
with ALS inhibitors, glyphosate-resistant weed populations are often large, with several
infesting hundreds of thousands to millions of acres.
As noted above, there has been a sharp rise in populations resistant to both ALS inhibitors
and glyphosate. in November 2007, ISHRW recorded just 3 populations of two species of
57 www.weedscience.org.
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weed infesting at most 10,600 acres that were dual resistant to glyphosate and ALS
inhibitors. By November 2010, just three years later, there were 7 populations of five
species of weeds with dual resistance to these two modes of action, and they infested
hundreds of thousands to as much as 1 million acres. This represents from 10-fold to 100-
fold more infested acreage. The most extensive population of these weeds (tall waterhemp
in Missouri) also resists a third mode of action, PPO inhibitors,^^ that are otherwise being
relied upon by growers to combat resistance to glyphosate and ALS inhibitors. Tall
waterhemp has a demonstrated ability to evolve resistance to two, three or more herbicide
modes of action, and is for that and other reasons particularly feared, s'* University of
Illinois weed scientists recently sounded the alarm about multiple herbicide-resistant tall
waterhemp {Amaranthus tuberculatus) in their state and in Missouri:
“Herbicide resistance in A. tuberculatus appears to be on the threshold of becoming
an unmanageable problem in soybean."™
Noting that glufosinate is one of the few remaining options for control of late season
waterhemp, they fear its loss to resistance as well:
“Furthermore, on the basis of A. tuberculatus's history, there is no reason to expect it
will not evolve resistance to glufosinate if this herbicide is widely used. If this
happens, and no new soybean postemergence herbicides are commercialized,
soybean production may not be practical in many Midwestern fields." (emphasis
added)
The emergence of dual resistance to glyphosate and ALS inhibitors fits the model of one-by-
one accumulation of resistances presented above. Weeds initially evolved ALS inhibitor
resistance in the 1980s and 1990s. Because many of these populations have no apparent
loss of fitness, they have persisted into this decade; because they tend to be large, there
existed among them weeds which had the rare genetic predisposition to survive glyphosate
application. Massive use of glyphosate with Roundup Ready crops beginning in 1996 then
fostered evolution of the dual-resistant biotypes.
To make matters stili worse, a recent study of the most prevalent glyphosate-resistant
weed species, horseweed, suggests that it has fitness equal to or greater than glyphosate-
susceptible horseweed (at least in California), and that the glyphosate-resistant
populations appear to be expanding whether or not glyphosate is applied to them.
"In a survey conducted in 2006 and 2007, the majority of horseweed plants sampled
in the southern SJV [San Joaquin Valley] were GR [glyphosate-resistant], regardless
of nearby cropping systems (Hanson et al. 2009), suggesting the possibility that
increased fitness may have contributed to the very rapid expansion in the range of
See http://www.weedscience.org/Case/Case.asp?ResistID=5269.
5’ Tranel.P.J. (2010). "Introducing QuadStack waterhemp,” Agronomy Day 2010, University of Illinois
Extension.
™ Tranel, P.J. et a! (2010). "Herbicide resistances in Amaranthus tuberculatus: a call for new options," Journal
of Agricultural and Food Chemistry, DOI: 10.1021/jfl03797n.
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the GR biotype, ... Observations of vigorous and productive GR horseweed,
regardless of whether it is growing in treated or untreated areas, suggests that the
GR horseweed in California may be more competitive than the glyphosate-
susceptible (GS) biotype in addition to being resistant to the most commonly used
herbicide in orchards, vineyards, and adjacent noncrop areas (Shrestha, personal
observation).”^!
Still more troubling are the results of recent research on horseweed populations in Indiana
and Ohio variously resistant to glyphosate alone, to ALS inhibitors alone, or to both classes
of herbicides. The authors of this study reported that all three types of resistant horseweed
displayed equal fitness to susceptible horseweed, as measured by "growth and seed
production potential." They further warn that these populations are likely to persist and
even increase in range with continued use of glyphosate and ALS inhibitors - and would be
unlikely to "disappear" even if the growers were to stop using them. This latter possibility
is unlikely, given the fact that these two modes of action are very commonly used to control
many different weed species beyond horseweed in their region.
“.... we conclude that horseweed populations composed of biotypes with single
resistance to glyphosate and ALS-inhibiting herbicides, or multiple resistance to
glyphosate + ALS-inhibiting herbicides have similar growth and seed production
potential. Furthermore, the variation within these herbicide-resistant populations
following exposure to herbicides would suggest that repeated applications will only
increase the ability of these populations to compete and reproduce following
repeated applications of the same herbicide or combination of herbicides. ... To
control these herbicide-resistant horseweed populations, and to offset the evolution
of more herbicide-resistant weeds, multiple integrated weed management practices
need to be implemented with the idea that resistant biotypes will not Just disappear
after growers stop the application of these herbicide modes of action.”®^
Authors from the same team have also done several studies showing the clear potential for
horseweed to evolve resistance to 2,4-D.*3 They note that:
"Multiple-resistant and cross-resistant horseweed populations have evolved to
various combinations of the previous herbicide modes of action in Israel, Michigan,
and Ohio (Heap 2009), providing evidence for the plasticity of this weed.''^<
Importantly, their studies of potential 2,4-D resistance in horseweed have been driven by
concern over the advisability of relying on some of the new herbicide-resistant crops, such
^'Shrestha, A. et a! (2010), "Growth, Phenology, and Intraspecific Competition between Glyphosate-Resistant
and Glyphosate-Susceptible Horseweeds (Conyza canadensis] in the San Joaquin Valley of California," Weed
Science 58: 147-153.
Davis, V.M. et al (2009). "Growth and Seed Production of Horseweed [Conyza canadensis) Populations
Resistant to Glyphosate, ALS-inhibiting, and Multiple (Glyphosate + ALS-inhibiting) Herbicides,” Weed
Science 57; 494-504.
® Kruger, G.R. et al (2008). "Response and Survival of Rosette-Stage Horseweed [Conyza canadensis] after
Exposure to 2,4-0," Weed Science 56; 748-752.
Kruger, G.R. et al (2010). "Growth and Seed Production of Horseweed [Conyza canadensis] Populations
after Exposure to Postemergence 2,4-D," Weed Science 58; 413-419.
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as the 2,4-D and dicamba-resistant varieties mentioned above. Note that 2,4-D and
dicamba are both "growth regulator" type herbicides:
“With the impending commercialization of 2,4-D- and dicamba-resistant crops, it
appears that additional options for control of glyphosate-resistant annual broadleaf
weeds will be available. However, growth regulator herbicide-resistant technologies
may not provide long-term solutions if resistant or tolerant populations currently
exist or if populations become resistant under selection pressure from overreliance
on growth regulators for broadleaf weed management"®
The implications of these various studies and data are clear. Weeds - including some of the
most agronomically damaging and costly species like horseweed and tall waterhemp -
have demonstrated the ability to evolve resistance to single modes of action as well as
multiple herbicides. The single-resistant and in some cases dual-resistant weeds often
suffer no "fitness cost," and thus their populations are likely to persist indefinitely, rather
than conveniently "disappear” if farmers were to stop using them. The persistence of
single- and multiple herbicide-resistant weed populations means that switching to, or
supplementation with, new modes of action like 2,4-D and dicamba - in association with
crops engineered with resistance to them - may backfire. While short-term relief is
possible, these new 2,4-D and dicamba-resistant crops “may not provide long-term
solutions..." if growers rely excessively on them. Rather, the introduction of multiple-
herbicide resistant crops is quite likely to foster increasingly costly and damaging
populations of weeds resistant to ever more herbicides.
The all-at-once pathway of herbicide-resistance is also concerning. As noted above,
metabolic degradation mechanisms employing the plant's natural detoxification systems
can evolve to confer resistance to multiple herbicides at one time - and potentially even to
herbicides that have never before been used. At present, this mechanism of weed
resistance has been observed mostly in grass-type weeds in Europe and Australia. Powles
and Yu (2010) report 11 weed species that have the P450-mediated herbicide degradation
mechanism alluded to above. Of these species, populations of blackgrass {Alopecurus
myosuroides) and rigid ryegrass [Lolium rigidum) are among the worst, with resistance to
multiple herbicides from three and four different herbicide families, respectively.*® There
have thus far been few reports of weeds with this mechanism of resistance in the U.S.,*^
though further investigations may reveal others.
The rapid increase in the number of weed populations resistant to glyphosate and to
multiple herbicides as well as the acreage they infest poses serious problems for U.S.
agriculture. Agronomists are wary of the agrichemical-biotechnology industry's preferred
response to this problem - introduction of new crops resistant to older, more toxic
herbicides, often in stacked versions conferring resistance to multiple herbicides. While
“ Ibid.
** Powles, S.B. & Q. Yu (2010]. "Evolution in Action: Plants Resistant to Herbidde.s,"/lnn!(. Rev, Plant Biol., 61:
8.1-8.31, Table 4.
Park, K.W. et al (2004). "Absorption, translocation, and metabolism of propoxycarba7.one-.sodium in ALS-
inhibitor resistant Bromus tectorum biotypes," Pesticide Biochemistry and Physiology 79: 18-24.
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new technologies may provide some short-term relief, it will come only at the cost of
increased herbicidal pollution of the environment, harm to human health, and greatly
increased weed control costs for farmers. In the medium to longer term, Nature is likely to
win this chemical arms resistance race between crops and weeds.
Do you know of any specific health threats presented by any of the herbicide resistant
crop systems under development?
As noted above, two of the leading herbicide-resistant crop systems involve resistance to
2,4-D and dicamba. According to Pennsylvania State University weed scientist Dr. Dave
Mortensen, widespread deployment of these crop systems will likely lead to a substantial
increase in the use of these herbicides in U.S. agriculture. In testimony before this
Subcommittee on July 28, 2010, Dr. Mortensen estimated that herbicide use on soybeans
would increase by 70% within three years of introduction of 2,4-D and dicamba-resistant
soybeans, assuming rapid adoption,^ an increase of roughly 55 million Ibs.^^
Increased use of these herbicides, especially at that magnitude, would have adverse
impacts on the environment, public health, and in particular the health of farmers.
The toxicity of 2,4-D (dichlorophenoxyacetic acid) has been exhaustively reviewed in a
petition by public interest scientists to EPA requesting that the herbicide's registration be
cancelled.™ Ingestion or inhalation of 2,4-D has adverse effects on the nervous system -
loss of coordination, limb stiffness, stupor, coma. A growing body of evidence points to 2,4-
D as a carcinogen. Studies in the U.S., Italy, Canada, and several other countries link 2,4-D
exposure to non-Hodgkin’s lymphoma, a cancer of the immune system. Studies of farm
workers exposed to 2,4-D revealed higher than normal rates of birth defects in their
children. 2,4-D is also a mutagen and an endocrine disrupter, and can be contaminated
during the production process with the even more toxic compound dioxin, which is highly
carcinogenic, weakens the immune system, decreases fertility, and causes birth defects.^*
2.4- D is banned in Norway.
Dicamba is a chlorinated benzoic acid herbicide similar in structure and mode of action to
2.4- D, and is used in both agriculture (e.g. corn, wheat) and on lawns.™ In 1992, the
National Cancer Institute (NCI) found that farmers exposed to dicamba were twice as likely
® Mortensen, D. (2010). See
http://oversighthouse.gOv/images/stories/Hearings/Domcstic_Policy/2010/072810_Superweeds/072610_
David_Mortensen_Testimony_072810.pdf.
Mercer, D. (2010). "Roundup resistant weeds pose environmental threat,” Associated Press, June 21, 2010.
http://www.usatoday.eom/tech/science/environment/2010-06-21-roundup-weeds_N.htm
Comments to EPA on its 2,4-D Risk Assessment, Docket ID No OPP-2004-0167, submitted by a coalition of
public health groups, including Natural Resources Defense Council and Beyond Pesticides, August 23, 2004.
” Beyond Pesticides (2004). 2,4-D: chemicalWATCH Fact Sheet, updated July 2004, Beyond Pesticides.
http://www.beyondpesticides.org/pesticides/factsheets/2,4-D.pdf,
Cox, C. (1994). "Dicamba factshect," Journal of Pesticide Reform 14(1): 30-35.
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to contract non-Hodgkin's lymphoma^^ A subsequent NCI study reported associations
between dicamba exposure and higher incidence of lung and colon cancer in pesticide
applicators^"* Researchers have also found a 20% percent inhibition of the nervous system
enzyme acetylcholinesterase in a group of certified pesticide applicators whose only
common pesticide used was dicamba.^s Exposure to organophosphate insecticide residues
in food has recently been linked to increased rates of attention-deficit/hyperactivity
disorder in children, and the presumed mechanism is inhibition of acetylcholinesterase, an
enzyme essential for normal brain development^® Dicamba is moderately persistent in soil
and water, and is frequently found contaminating ground water supplies Pregnant mice
that ingested drinking water spiked with low doses of a commercial herbicide product
containing dicamba, 2,4-D and mecoprop had reduced litter size, suggesting that this
herbicide mixture may have developmental toxicity/® A study of the frequency of sister
chromatid exchanges (SCEs) and cell-cycle progression assays revealed that high doses of
dicamba can damage DNA, leading the study authors to warn that dicamba is a "potentially
hazardous compound to humans."^®
Dicamba is also highly volatile, and under the right conditions (hot days, no rainfall) can
revolatilize after application and drift to damage neighboring crops or plants bordering
fields/® This drift can cause significant economic damage to other farmers, and also
destroy habitat for pollinators and other beneficial insects/i The greatly increased use of
dicamba to be expected with dicamba-resistant crops will likely exacerbate these adverse
impacts. South Africa completely prohibited use of dicamba in some districts, and banned
aerial application in others.®^
2,4-D-resistant crops may pose a new food safety risk beyond the risks attributable to the
increased use of 2,4-D to be expected with its adoption. First, one must understand that
monocot plants (cereal crops like corn) have a natural tolerance to low levels of 2,4-D,
facilitating the use of this pesticide on major field crops like wheat and corn. Numerous
Cantor, K.P. (1992). "Pesticides and other agricultural risk factors for non-Hodgkin’s lymphoma among
men in Iowa and Minnesota,” Cancer Res. 52: 2447-2455.
’■* Samanic, C. et al [2006). "Cancer Incidence among Pesticide Applicators Exposed to Dicamba in the
Agricultural Health Study," Environmental Health Perspectives 114: 1521-1526.
Potter, WT, et al. [1993). "Radiometric assay of red cell and plasma cholinesterase in pesticide appliers
from Minnesota.” Toxicology and Applied Pharmacology 119: 150-155.
76 Boiirchard, M. F. et al (2010). “Attention-Deficit/Hyperactivity Disorder and Urinary Metabolites of
Organophosphate Pesticides," Pediatrics 2010; 125:el270-el277.
” Thurman, E.M. et al [2003). "Regional Water-Quality Analysis of 2,4-D and Dicamba in River Water Using
Gas Chromatography-Isotope Dilution Mass Spectrometry," International Journal of Environmental Analytical
Chemistry 79: 185-198.
™ Cavieres, M.F., ]. laeger & W, Porter [2002). "Developmental Toxicity of a Commercial Herbicide Mixture in
Mice: 1. Effects on Embryo Implantation and Litter Size," Environmental Health Perspectives 110: 1081-1085.
Gonzalez, N.V. et al [2006). "Genotoxicity analysis of the phenoxy herbicide dicamba in mammalian cells in
vitro,” Toxicology in Vitro 20: 1481-87.
^"Harteier, B. (2004). “Dicamba Volatility,” Iowa State University posting, July 24, 2001,
http://www.weeds.iastate.edu/mgmt/2001/dicambavolatility.htm
M Mercer, D. [2010, op. cit.
“ "Banned and restricted substances in the republicof South Africa." April 22, 2008. Accessed online July 19,
2010. http://www,nda.agric.za/act36/Banned%20and%20restricted.htm.
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studies have examined precisely how 2,4-D is metabolized by non-genetically engineered
plants so as to render it non-toxic to the plant 2,4-D-resistant plants incorporate a
bacteria-derived gene that metabolizes 2,4-D in a different way, transforming it into 2,4-
dichiorophenol (2,4-DCP}. 2,4-DCP is not produced, or only in very small amounts, when
naturally tolerant plants metabolize 2,4-D.
2,4-DCP is a chlorophenol compound that is individually listed by EPA in its toxics release
inventory of toxic chemicals.83 The European Union also lists 2,4-DCP as a hazardous
substance. Animals dosed with high levels of chlorophenols in their food or drinking water
experienced adverse liver and immune system effects, and did not gain as much weight as
control animals. Some studies have shown increased risk of cancer, as well as acne and
liver damage, among workers in pesticide plants that make chlorophenols, though it is not
clear whether the effects were due to chlorophenols or other chemicals.®"*
Dow AgroSciences uses 2,4-DCP as a raw material to manufacture pesticides. In a material
safety data sheet for 2,4-DCP,®® Dow notes that exposure of just 1% of a worker's body (an
area the size of the palm of a hand) to molten 2,4-DCP may cause death. Dow's industrial
hygiene guideline for 2,4-DCP is 1 part per million, skin. Dow reports that animal testing
has revealed that 2,4-DCP has adverse effects on blood forming organs (bone marrow &
spleen), kidney and liver; that 2,4-DCP may be contaminated by the more toxic 2,4,6-
trichlorophenol (known to the State of California to cause cancer); and that this
contaminant (present at a level of 0.1% in current samples) may explain the inconclusive
results in carcinogenicity tests on animals. Dow further notes that in-vitro genetic toxicity
(mutagenicity) studies with 2,4-DCP were negative in some cases and positive in other
cases, and that it found no relevant information with respect to possible reproductive
effects from 2,4-DCP exposure. Dow found that 2,4-DCP is moderately toxic to aquatic
organisms on an acute basis (LC50 or EC50 between 1 and 10 mg/L in most sensitive
species tested).
French scientists conducted experiments to determine whether the 2,4-DCP generated by
transgenic, 2,4-D-resistant plants after spraying with 2,4-D would be broken down into less
toxic compounds. They found that the basic structure of the 2,4-DCP molecule remained
intact. The French team concluded that 2,4-D-resistant plants sprayed with 2,4-D "may not
be acceptable for human consumption.”®® They further point to the potential for 2,4-DCP
83 EPA [1999], Emergency Planning and Community Right-to-Know Section 313: List of Toxic Chemicals
within the Chlorophenols Category, Environmental Protection Agency, June 1999 (Technical Update
November 2005).
B-^USDHHS (1999). “Toxicological Profile for Chlorophenols,” Agency for Toxic Substances and Disease
Registry, Public Health Sei-vice, US Dept of Health and Human Services, July 1999.
85 Dow (2006). 2,4-Dichlorophenol Material Safety Data Sheet, Product Code: 20636, MSDS Number:
000715, Dow AgroSciences LLC, Effective Date: 7-Sept-06.
Laurent, F. et al (2006). "Metabolism of [14C]-2,4-dichlorophenol in edible plants," Pest Management
Science 62: 558-564.
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residues in foods derived from 2,4-D resistant plants to be transformed in vivo into more
highly chlorinated compounds that have greater toxicity.®^
BASF is awaiting USDA deregulation of genetically engineered, imidazolinone-resistant
soybeans (BPS-CV127-9).®® Imazethapyr, one of the most widely used of the imidazolinone
class of herbicides (a form of heterocyclic aromatic amine), has been associated with
increased risk of bladder and colon cancers in farmers who use this herbicide.®^
Could you elaborate on the external costs imposed on growers and the environment
caused by the cultivation of herbicide-resistant crops?
As explained by Steve Smith in testimony before this Subcommittee on September 30,
2010, herbicide-resistant crops make it possible to apply large quantities of herbicides
much later in the growing season than is possible otherwise. This facilitation of
postemergence herbicide use means that neighboring growers will be vulnerable to crop
injury from herbicide drift to a much greater extent than they were before HR crops were
introduced. Costs incurred from crop injury by growers whose crops are not resistant to
the pertinent herbicide are difficult to estimate, but could be substantial, especially in the
case of a volatile herbicide like dicamba.
In order to defend their crops from herbicide drift damage, some and perhaps very many
growers will purchase seed that is herbicide-resistant for defensive purposes, not because
they want to make use of the trait and associated herbicide for weed control. In fact, this
has already happened with Roundup Ready technology, and is happening now with
Clearfield.
According to Arkansas weed consultant Ford Baldwin:
"A lot of growers planted Roundup Ready corn in the beginning out of self defense. I
looked at enough glyphosate drift on conventional corn to understand why. Most
growers initially used conventional herbicides in the Roundup Ready corn. Over
time though the progression was to glyphosate-based programs and we lost a lot of
the benefit of what could have been a great resistance management tool."’®
Growers who bought Roundup Ready corn "out of self defense” paid a substantial premium
(technology) fee for a trait they did not want. This is an external cost imposed by the
Roundup Ready crop system, as it is used in the real world. Mr. Baldwin's article, however,
focuses on an analogous situation with another herbicide-resistant crop, Clearfield rice.
Wittsiepe, J. et al (2000). "Myeloperoxidase-catalyzed formation of PCDD/F from chlorophenols,"
Chemosphere 40: 963-968.
88 See petition 09-015-01p at http://www.aphis.usda.gov/biotechnology/not_reg.htmi.
” Koutros, S. et ai (2009). "Heterocyclic aromatic amine pesticide use and human cancer risk; Results from
the U.S. Agricultural Health Study,” int [. Cancer 124: 1206-1212.
Baldwin, F.L. (2010). "Herbicide drift damaging rice," Delta Farm Press, lune 7, 2010.
http://deltafarmpress.eom/rice/herbicldc-drift-damaging-rice-0607/ .
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Clearfield is a non-GE type HR crop, resistant to the imidazolinone class of herbicides of the
ALS inhibitor family. Newpath is BASF’s formulation of imazethapyr.
"My university counterparts have received more Newpath drift calls than normal as
well. At present, four out of every five requests to come to a field involve some
problem with Newpath on conventional rice. Most involve drift, but there have also
been several cases of miscommunication between neighbors, and also between
farmers and applicators on whether a particular field was Clearfield or
conventional rice.
These situations are never good. They have led to more talk of "defensive" planting
of Clearfield rice. While it is easy for the good doctor to sit at his desk and say that
is a bad idea, 1 have looked at several fields this year where I must admit I couldn't
blame the farmer for his thinking.”
Baldwin is clearly sympathetic to the crop injuty and losses incurred by growers of
conventional corn (due to Roundup drift from Roundup Ready fields] and conventional rice
(due to Newpath drift from Clearfield rice fields). Yet he is no enemy of either technology.
On the contrary, he regards them as useful tools for farmers, but tools that are having
unfortunate and costly impacts on those who choose not to use them.
But the real thrust of the article has to do with the difficulty of using these herbicide-
resistant crop systems in a sustainable manner, which is exacerbated by the drift issue.
Growers initially bought Roundup Ready corn for defensive reasons: "Over time though the
progression was to glyphosate-based programs and we lost a lot of the benefit of what
could have been a great resistance management tool" What is the “great resistance
management tool" that was lost? First, it was growing conventional corn with
"conventional" [non-glyphosate] herbicides. That is, growers who planted Roundup Ready
soybeans or cotton and then rotated to conventional corn were practicing “resistance
management" by not using glyphosate for at least one year in their rotations. When they
began switching to Roundup Ready corn for defensive reasons, they continued at first to
use non-glyphosate herbicides with it, retaining the resistance management benefit.
However, eventually they switched over to glyphosate with RR corn, increasing selection
pressure for glyphosate-resistant weeds.
While Baldwin does not elaborate, it was probably economics that drove this decision.
When a farmer pays a hefty technology fee for an RR traited seed, it makes economic sense
to make use of it through using inexpensive glyphosate, rather than mostly more expensive
“conventional” herbicides. If they hadn't been forced for "defensive" reasons to buy more
expensive Roundup Ready corn, they probably would have continued planting cheaper
conventional corn, which entails using conventional herbicides, and provides a resistance-
managing "break" from continual glyphosate use.
Baldwin sees the same thing happening with Clearfield rice.
“Most weed scientists i know feel we are growing more Clearfield rice now than is
sustainable over time ~ unless we get a breakthrough in new technology. As we
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continue to increase the acres, most likely we are shortening the life of the
technology. ... If you plant every acre to Clearfield and continue to pound it with
Newpath and Beyond, resistant barnyardgrass will be the most likely end result,"
When adoption of these two HR crops - RR corn and Newpath rice - reached a certain
tipping point, the crop-damaging drift that is a consistent feature of these HR technologies
forced many other growers to unwillingly adopt them. This led to massive overreliance on
the HR crop-associated herbicides, loss of the resistance management benefits provided by
retaining a conventional crop in the rotation, and a spate of new herbicide-resistant weeds.
The resistant weeds drive the demand for "new technology" in the form of a new herbicide
or new herbicide-resistant crop - spurring yet another turn in the vicious spiral of
increasing herbicide use and weed resistance. It’s hard to imagine a more unsustainable
technology than herbicide-resistant crop systems, at least as they are used in the real
world, in the absence of regulation.
The only way to get off this pesticide treadmill is through integrated weed management
that prioritizes non-chemical weed control measures. Unfortunately, mainstream
American agriculture has been so thoroughly fixated on the chemical-only approach that
most farmers, extension agents, and weed scientists have no clue where to begin. The
silver lining in the HR weed epidemic may perhaps be that it is opening minds like that of
Dr. Stanley Culpepper, weed scientist at the University of Georgia.
Culpepper is in the midst of a glyphosate-resistant pigweed epidemic that is rapidly making
cotton-growing an impossible task in Georgia. In 2009, half of Georgia's one million acres
of cotton had to be weeded by hand to remove this GR weed, at a cost of $1 1 million.
Growers who until recently spent $25 per acre on weed control are now forced to spend
$60 to $100 per acre. According to Culpepper: "We're talking survival, at least
economically speaking, in some areas, because some growers aren't going to survive
this."5i
While Culpepper does not advocate giving up herbicides, he understands that the old
approach of relying upon them exclusively is doomed to fail. Culpepper now recommends
deep tillage to bury the resistant pigweed seed so that it will not sprout, which can reduce
seed germination by up to 50%. He also recommends the planting of heavy cover crops
like rye to provide a thick mat between crop rows that likewise reduces weed seed
germination by as much as 50%. Together, the two techniques reduce the emergence of
resistant pigweed that actually emerges, but up to 80%. The much reduced populations of
weeds (resistant or not) that do emerge can then be managed with much lesser quantities
of herbicides.
While Dr. Culpepper appears to be a recent convert to the virtues of cover cropping and
other non-chemical modes of weed control, other scientists have been working to improve
and encourage adoption of such practices for many years, mostly without recognition and
Haire, B. (2010). “Pigweed threaten.s Georgia cotton industry," Southeast Farm Press, )u!y 6, 2010.
http;//southea.stfarmpress.com/Digweed-threatens-Eeor£ia-cotton-inclu$trv .
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with far too little support from our pesticide-friendly U.S. Dept. of Agriculture. Dr, Adam
Davis recently published a study showing the effectiveness of the “cover crop roller-
crimper" for use in no-till soybean cultivation.’^ x},e roller-crimper is a heavy, flanged
cylinder that is attached to a tractor and rolled over a cover crop like rye in the spring to
kill it. The killed cover crop forms a heavy mat into which soybeans can be drilled, and
which physically suppresses weed emergence, as discussed above. Some cover crops also
exude allelopathic compounds into the soil that also inhibit the emergence of weeds.
Dr. Matt Liebman at Iowa State University has shown the great benefits to farmers from
adopting more complex rotations involving three or more crops (including a winter cover
crop or alfalfa}, rather than the standard corn-soybean rotation.’^ in addition to decreasing
use of (and expenditures on) synthetic nitrogen fertilizers by half to three-fourths, the
more complex three- and four-year rotations reduced herbicide use by 76% and 82%,
respectively, with weed suppression equivalent to the herbicide-intensive, conventional
corn/soybean rotation, and yields that were equal or higher. These "low-external input"
(LEI) systems were also more profitable than the conventional rotation, especially when
considered in the absence of subsidies. Our perverted subsidy system, however, reduce the
differences between the systems, and act as an impediment to adoption of such beneficial
systems by American growers. A perhaps even more important factor, however, is the
paucity of support to truly sustainable weed management systems such as this on the part
of the U.S. Dept, of Agriculture, which like the major agrichemical-biotechnology firms is
fixated on chemical-only approaches to weed control and farming in general.
We conclude by citing a very recent paper by Illinois agronomists, who are at ground zero
of an extremely threatening outbreak of multiple herbicide-resistant tall waterhemp
{Amaranthus tuberculatus). Patrick Tranel and colleagues have recently surveyed fields in
Illinois and Missouri, and found a startingly high proportion of tall waterhemp populations
to be resistant to glyphosate as well as one, two or in some cases even three additional
herbicide modes of action.’"* Tall waterhemp is regarded as one of the most threatening
weeds to soybean and to a lesser extent corn cultivation in the Midwest, particularly in
Illinois and Missouri. Waterhemp populations with individuals resistant to only one
herbicide mode of action are practically a thing of the past. The majority of populations
now contain multiple-herbicide resistant plants. Tranel and colleagues state that;
"Herbicide resistance in A. tuberculatus appears to be on the threshold of becoming
an unmanageable problem in soybean."
They further warn that these weed populations will likely evolve resistance to glufosinate,
one of the few postemergence herbicidal options available to growers afflicted with these
multiple herbicide-resistant populations. This would occur with widespread deployment
Davis, A.S. (2010). "Cover-Crop Roller-Crimper Contributes to Weed Management in No-Till Soybean,"
Weed Science 58: 300-309,
’3 Liebman, M. et al (2008). “Agronomic and Economic Performance Characteristics of Conventional and Low-
External-Input Cropping Systems in the Central Corn Belt,' Agronomy Journal 100: 600-610.
Tranel, P.J. (2010). "Herbicide resistances in Amaranthus tuberculatus: A call for new options,” Journal of
Agricultural and Food Chemistry, D01:10.1021/jfl03797n.
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of glufosinate-resistant, LibertyLink soybeans, which at present are very little grown. If
this happens, they warn, and no new soybean postemergence herbicides are
commercialized:
"Soybean production may not be practical in many Midwest U.S. fields,”
The inability to economically cultivate the second most widely grown crop in America, a
mainstay of Midwestern agriculture, would represent a huge cost imposed by unregulated
use of HR crop systems on American farmers and U.S. agriculture as a whole. Clearly, USDA
and land grant university agronomists must begin devoting serious attention to the sorts of
sustainable, integrated weed control practices described above, which make non-chemical
approaches a priority, and deemphasize the use of herbicides.
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October 15, 2010
Mr. Jay Vroom
President and CEO
CropLife America
1156 15'*' St. NW
Washington, DC 20005
Dear Mr. Vroom:
In connection with the September 30, 2010 hearing of the Domestic Policy Subcommittee,
entitled, “Are “Superweeds” an Outgrowth of USDA Biotech Policy? (Part II)”, I hereby request
that you provide answers in writing to the following questions for the hearing record.
1 . Does the industry believe USDA has authority under the Plant Protection Act (codified
at 7 U.S.C. § 7701 et. seq.) and its regulations to regulate GE crops so as to prevent
pesticide-resistant pests (including herbicide-resistant weeds)?
2. Does the industry believe that U.S.E.P.A. has that authority under a different statute?
3. Can the industry point to any purely voluntary stewardship practices that have
successfully prevented or contained the spread of glyphosate resistance in weeds on a
broad basis involving many individual farmers?
4. What regulatory schemes are supported by the industry that would prevent hami to
horticultural crops and landscapes growing in proximity to soybean fields, if Dicamba-
resistant soy is deregulated by USDA?
5. What is the extent of glyphosate-rcsistance in weeds outside of the United States?
Please provide a country-by-country assessment, in tabular form, of glyphosate-
resistant weeds, in terms of glypohsate-resistant species by name and date of
discovery, estimated number of acres of infestation, and date of commercialization of
Roundup-Ready coni, soy or cotton (as is applicable).
Ranking member Jordan submits the following additional questions:
126
Mr. Jay Vrooni
October 15,2010
Page 2
1 . Do you think that introducing multiple modes of action that control weeds in different
ways and appropriate herbicide management techniques can help address the challenge
of herbicide-resistant weeds?
2. How quickly will the issue of herbicide-resistant w'eeds w'orsen in the absence of new
technologies entering the marketplace?
The Oversight and Government Reform Committee is the principal oversight committee in
the House of Representatives and has broad oversiglit jurisdiction as set forth in House Rule X.
We request that you provide written answers to these questions as soon as possible, but in no
case later than 5:00 p.m. on October 30, 2010.
If you have any questions regarding this request, please contact Jaron Bourke, Staff Director
at (202) 225-6427.
Sincerely,
Dennis J. Kucinich
Chairman
Domestic Policy Subcommittee
cc: Jim Jordan
Ranking Minority Member
2
127
November 5, 2010
The Honorable Dennis J. Kucinich
Chairman, Domestic Policy Subcommittee
Committee on Oversight and Government Reform
U. S. House of Representatives
Dear Congressman Kucinich:
CropLife America (CLA) thanks you for the opportunity to provide testimony on
September 30, 2010 during the Domestic Policy Subcommittee hearing entitled, “Are
“Superweeds” an Outgrowth of USDA Biotech Policy? (Part II)”. CropLife America is
the leading trade association representing the U.S. crop protection industry and our
members supply virtually all of the crop protection products used by American farmers.
CropLife America’s member companies, and members of our counterpart association at
rise', proudly discover, manufacture, register and distribute crop protection products for
American agriculture, and specialty use products outside of agriculture, such as those
used for public health protection and commercial pest management inside of homes and
commercial buildings.
During the first hearing, CLA emphasized three major points that are essential to
understanding weed resistance to herbicides and the need for best management practices
to minimize the potential for resistance development:
• Herbicide resistance occurs naturally, and best management practices need to be
applied at the farm level in ensuring that resistance development is avoided or
delayed. Resistance is a scientific reality in virtually all biological systems.
• The market can and will facilitate the development and adoption of solutions to
combat weed resistance in crop production to ensure production of safe,
affordable, and plentiful food.
• The current regulatory framework for herbicides is robust.
As requested, below are our responses to questions for the hearing record.
1. Does the industry believe USDA has authority under the Plant Protection
Act (codified at 7 U.S.C. § 7701 et seq.) and its regulations to regulate GE
crops so as to prevent pesticide-resistant pests (including herbicide-
resistant weeds)?
Recognizing that CLA does not represent the crop protection industry on the specific
matter of regulations for genetically engineered (GE) crops, CLA would consult the
affected agencies for their interpretation of the laws granting them specific authorities.
However, USDA has the authority under Part 340 of the Plant Protection Act to regulate
' Responsible Industry for a Sound Environment (RISE) — www.pestfacts.org
• Representing the Plant Science Industry •
1156 15* St. N.W. • Washington, D.C. 20005 • 202 . 296.1585 • 202 . 463.0474 fax • www.croplifeamerica.org
128
the introduction (importation, interstate movement, or release into the enviromnent) of
GE crops. Unlike crops genetically engineered to produce Bt proteins to control insects,
herbicide-tolerant (HT) crops do not control weeds or any other pests. In addition to
examining potential risks to plant health under the Plant Protection Act, APHIS assesses
the potential effects of its actions on the quality of the environment under the authority of
the National Environmental Policy Act.
Regulation of the herbicides that accomplish weed control is under the jurisdiction of
EPA (see next question.) USDA and EPA work cooperatively as necessary to identify,
develop, and approve best management practices for avoiding and mitigating pest
resistance to pesticides.
2. Does the industry believe that U.S.E.P.A. has that authority under a
different statute?
Recognizing that CLA does not represent industry on regulations for GE crops, CLA
would consult the affected agencies for their interpretation of the laws granting them
specific authorities. However, the safe use of pesticidal substances is regulated by the
Environmental Protection Agency (EPA). GE insect-resistant crops may contain an
introduced pesticidal substance also known as a plant-incorporated protectant (PIP) that
is subject to review by EPA. EPA’s regulatory process for PlPs includes rigorous
environmental assessment. As mentioned earlier, USDA and EPA work cooperatively as
necessary to identify, develop, and approve best management practices for avoiding and
mitigating pest resistance to pesticides.
The use of pesticides in the U.S. is regulated by EPA under the Federal Insecticide,
Fungicide, & Rodenticide Act (FIFRA; codified at 7 USC §136 etseq.) and selected
provisions of the Federal Food, Drug, & Cosmetic Act (FFDCA; codified at 21 USC
§301 et seq.; specifically 21 USC §346a). Implementing regulations are published in 40
CFR Parts 150 to 189. This authority can and does extend to resistance mitigation
strategies. EPA reviews, approves, and regulates every statement and instruction that
goes on the label of every pesticide and herbicide product, according to these laws and
regulations. This responsibility is taken very seriously by EPA and pesticide registrants.
State regulators and enforcement personnel are EPA’s close partners in seeing that
pesticide products carry the correct, valid labels and that farmers use them correctly.
3. Can the industry point to any purely voluntary stewardship practices
that have successfully prevented or contained the spread of glyphosate
resistance in weeds on a broad basis involving many individual famers?
In Arkansas, extension, academic, and government personnel, together with grower
organizations have developed a strong program for management of glyphosate-resistant
weed populations, focusing on “zero tolerance.” Education and outreach efforts are
extensive, and industry is fully cooperating. Member companies represented by the
Industry’s Herbicide Resistance Action Committee (HRAC) and CropLife America have
monitored and researched the herbicide resistance issue on a global basis for 20 years,
129
cooperating closely with academia and government authorities in developing and
implementing resistance management strategies. HRAC has been very active in the
recent developments concerning glyphosate-resistant weeds.
In Arkansas, farmers are strongly encouraged to closely monitor all fields, acre by acre,
row by row, following all herbicide treatments including glyphosate. Any weeds
escaping control are to be removed, by spot treatment with other herbicides, by hoe, or by
hand, if necessary. Other herbicides must be used in combination with or in place of
glyphosate to control the resistant weeds. Other crops may be grown in rotation in
subsequent growing seasons to facilitate a diversity of weed control practices.
Harvesting equipment should be cleaned carefully before it leaves a field where resistant
weeds are known or suspected, to avoid spreading them to other fields. Registrants are
offering financial incentives to convince growers to employ best management practices,
including using a competitor’s product, when necessary.
Such extensive efforts are an example of progress in the fight against glyphosate-resistant
weeds in Arkansas. Similar efforts tailored to local needs are in practice and under
development in other affected Southern states. States not yet affected are watching
closely and learning the lessons that can be implemented to avert losses.
4. What regulatory schemes are supported by the industry that would
prevent harm to horticultural crops and landscapes growing in proximity
to soybean fields, if Dicamba-resistant soy is deregulated by USDA?
EPA evaluates the potential off-site movement of an herbicide when deciding whether to
register a product for a particular use and will require label instructions designed to
minimize off-site movement. EPA-registered herbicides have been used successfully in
agriculture for decades and farmers have extensive experience in managing off-site
movement by strict adherence to label instructions and the application of best
management practice. Industry supports pesticide applicator efforts to minimize off-site
movement by providing education and training resources, and continued research and
development of technologies to further reduce such movement.
5. What is the extent of glyphosate-resistance in weeds outside of the United
States? Please provide a country-by-country assessment, in tabular form,
of glyphosate-resistant weeds, in terms of glyphosate-resistant species by
name and date of discovery, estimated number of acres of infestation, and
date of commercialization of Roundup-Ready corn, soy or cotton (as is
applicable).
CropLife America does not have the infonnation requested on the global status of
glyphosate resistance. However, CLA supports efforts by HRAC to compile reports of
herbicide resistance to all herbicides worldwide.
Additional questions from Ranking Member Jordan are addressed below:
130
1. Do you think that introducing multiple modes of action that control
weeds in different ways and appropriate herbicide management
techniques can help address the challenge of herbicide-resistant weeds?
Yes, use of best management practices in concert with herbicides that have different
modes of action is a component of integrated pest management broadly supported by
public and private sector scientists. Use of multiple modes of action will reduce the
impact of herbicide-resistant weeds. To avoid or delay the onset of resistance, growers
need to be aware of and adopt best management practices. Information regarding best
management practices and integrated weed management is available from multiple
reliable sources including websites sponsored by the Weed Science Society of America
(WSSA)andHRAC.
2. How quickly will the issue of herbicide-resistant weeds worsen in the
absence of new technologies entering the marketplace?
Using a diversity of weed management options is important for managing weed
resistance. New technologies provide growers with more options that make is easier to
implement effective weed management in all cropping systems across the U.S. Adoption
of biotechnology has not caused the rapid onset of resistance in weed species; appropriate
use of a diversity of technologies is fundamental for reducing the impact of resistance.
The market can and will adopt solutions to combat weed resistance in crop production to
ensure production of safe, affordable and plentiful food. Farming is a long-term
investment, and growers will adapt their operations to succeed. They need the flexibility
to manage their farm operations for the current season and for the future. That flexibility
requires access to the tools that enable them to take care of their business interests and
sufficient latitude in terms of how and when they are used. Growers are in the best
position to know their fields, the weeds growing in them, and how to best manage their
farm inputs. Such knowledge will enable them to make the best decisions on what tools
to use, including crop protection products and biotech crop seed, considering relevant
economic factors and their future management plans.
Weed control options will continue to be developed. Crop protection is a competitive
business. If a weakness in a particular weed control option emerges, there will be other
new or existing technologies that wilt seek to fill that void. The market favors
maximization of the tools currently available. The development of new herbicides is an
involved and expensive process. To make that investment worthwhile requires that the
useful life of a product be extended as long as possible with available means. Some
recent marketing programs have included manufacturer rebates for use of competitive
products in combination with the manufacturer’s product, in order to stem the onset of
resistance. This is one example of how the market addresses the issue.
Thank you for the opportunity to provide this information. If we can be of further
assistance, please contact Beau Greenwood, Executive Vice President, Federal Affairs
(bgreenwood@croplifeamerica.org ').
131
Sincerely,
iC>
Jay J. Vroom
President and CEO
cc. Jim Jordon, Ranking Minority Member
132
ONE HUNDRED ELEVENTH CONGRESS
Congrefig of tfje ®ntteli States
5,)ouse of i\cprcscntntiUrs
COMMiTTEE ON OVERSIGHT AND GOVERNMENT REFORM "
2 1 57 Rayburn House Office Building
Washington, DC 2051 5*6 1 43
WrV.-« OV6rSi3ht.hOUSe.gov
October 1 5, 20 1 0
Mr. Steve Smith
Director of Agriculture
Red Gold, Inc.
P.O. Box 83
Elvvood, IN 46036
Dear Mr. Smith:
In connection with the September 30, 2010 hearing of the Domestic Policy Subcommittee,
entitled, “Are “Supenvecds” an Outgrowth of USDA Biotech Policy? (Part il)”, Representative
Jim Jordan, Ranking Member, requests that you provide answers in writing to the following
questions for the hearing record.
1 . You testified that your company and growers faced over S 1 million in cropping losses
from glyphosatc drift. Can you describe specifically what caused those alleged losses?
2. What losses have your growers experienced as a result of dicamba drift and
revolatilization?
The Oversight and Government Reform Committee is the principal oversight committee in
the House of Representatives and has broad oversight jurisdiction as set forth in House Rule X.
We request that you provide written answers to these questions as soon as possible, but in no
case later than 5:00 p.m. on October 30, 2010.
133
Mr. Steve Smith
October 15,2010
Page 2
If you have any questions regarding this request, please contact Jaron Boiirkc. Staff Director
at (202) 225-6427.
Sincerely,
Dennis J. Kucinich
Chairman
Domestic Policy Subcommittee
cc: Jim Jordan
Ranking Minority Member
2
134
Honorable Dennis J. Kuciniob
Chairman
Domestic Policy Subcommittee
2157 Rayburn House Office Btiilding
Washington, DC 20515-6143
Dear Chairman Kucinich,
Thank you for the opportunity to reply to questions concerning my recent testimony
about the effects to the Midwestern tomato industry by the release of dicamba tolerant
soybeans during the Part n hearing entitled, “Are Superweeds an Outgrowth of USDA
Biotech Policy?”
Question #1 referred to my testimony asserting over $ 1 million in cropping losses from
glyphosate drift. I have attached a spreadsheet orrtlinrng our exact crop losses from all
forms of drift and volatizatron for the last four cropping seasons and the eventual
outcome of the losses. As you will see, several are still in litigation which is the reasorting
behind my comments and requests that the tttakers of dicamba and the registrants of
dicamba tolerant soybeans to immediately be financially responsible for losses.
Question #2 asks about our actual experiences as a result of dicamba drift and
revolatization. As you will notice from the spreadsheet, we have had only one dicamba
volatility issue in the last four years and it occurred early enough in the growing cycle
that the field could be replanted, so the large losses to us the processor of not having fruit
available and big yield losses to the grower were mifigated to a great degree. However,
as my testimony said, the use of dicamba in our area is nearly non-existent because of the
potential losses to soybeans. The important point is that revolatization is a known
characteristic of dicamba and when sensitive crops are present, damage will occur, and as
listed, we have had an actual case even with very little actual exposure.
1 would be more than pleased to answer any further questions or explain any other
statements that may arise.
Sincerely,
Steve Smith
(sent electronically)
135
Red Gold Drift Loss Summary 1997-2010
Year Grower
Loss Total
Cause of loss
settlement
outcome
2007 Geifius Farms
$
18,934.00
still in litigation
2008 Janssen Brothers Farms
$
24,915.13
glyphosate
still in litigation
Morrin Farms
$
14,570.44
giylji^o^te
still in litigation
Lievens Brothers Farms
$
702,197.77
gi^hosate
still in litigation
Keesling Farms
$
18,660.00
2,4 d
settled in full
Triple S Smith Farms
$
137,126.57
glyphosate
settled in full
Daily Farms
$
63,085.82
glyphosate
settled at about 90%
Associated Growers
5
4,725.00
dicamba
no settlement, sprayer denied claim, able to replant
Detling Farms
$
3,306.09
glyphosate
settled in full
2009 Howell Farms
$
40.951.82
glyphosate
settled in full
Steve Busch
$
15.907.25
glyphosate
settled in full
King Farms
$
34,370.71
glyphosate
settled in full *grower portion estimated
Plank Farms
$
13,990.29 glyphosate
settled in full
2010 Pribie Farms
$
50,000.00 glyphosate
estimated loss, avtaiting settlement
$1
1,142,740.89
136
ONE HUNDRED ELEVENTH CONGRESS
CongreSiS of tfje ®nttcli States
J[)oiisr of ^AcpiTGirntatiUrs
COMMITTEE ON OVERSIGHT AND GOVERNMENT REFORM
2 1 57 Ra'i^urn House Office Building
Washington, DC 20515-6143
(JC21K-5-6051
F'.'i.us.i { 2021225-4794
(2025225-5074
vvv,v,’.oyer3!-gh{ hctise.goy
October 15, 2010
Mr. Phil Miller
Vice President, Global Regulatory
Monsanto Company
800 North Lindbergh Blvd.
St. Louis, MO 63167
Dear Mr. Miller:
In connection with the September 30, 2010 hearing of the Domestic Policy Subcommittee,
entitled, “Arc “Superweeds” an Outgrowth of USDA Biotech Policy? (Part II)”, I hereby request
that you provide answers in writing to the following questions for the hearing record.
1 . You say in your written testimony that genetically engineered crops increase farmer
profits, yields and carbon sequestration. As you know, the scope of the hearing was
limited to herbicide-resistant crops. Please provide the Subcommittee with all
documents that provide a basis for those three claims as they would relate to herbicide-
resistant crops.
2. At what point was glyphosatc-resistance in weeds first predicted and when was it first
documented by the Company or Company-funded scientists? Please provide all
citations for published research.
3. Are voluntary stewardship measures sufficient to prevent and/or mitigate glyphosate
resistance in weeds? Please provide specific examples of purely voluntary stewardship
practices that have successfully prevented or contained the spread of glyphosate
resistance in weeds on a broad basis involving many individual farmers.
4. Given that including in a rotation non-glyphosate-resistant crops can be important to
preventing glyphosate resistance in weeds, what varieties of non-glyphosate-resistant
com, cotton and soy does Monsanto and its affiliated seed companies offer to fanners?
5. Concerning the development of other herbicide-resistant resistant crops, including
dicaniba-resistant soybeans, what is the scale of Monsanto Company’s research and
development efforts to create other herbicide resistant crops?
Mr. Phil Miller
October 15,2010
Page 2
137
6. Is Dicamba-rcsistance in weeds currently predicted by the Company or any Company-
funded scientist in fields that will be growing Dicamba-resistant soybeans?
7. What lessons has the Company taken from glyphosate-resistance in weeds to apply to
preventing or mitigating Dicamba resistance in w'eeds?
8. Does the Company believe that voluntary stewardship measures alone will be
sufficient to prevent Dicamba resistance in weeds from occiiring after Dicamba-
resistant crops are planted?
9. In light of producer concerns for horticultural crops once Dicamba gains more
widespread use after Dicamba-resistant crops are deregulated, what measures does the
Company believe will prevent producer concerns from being realized?
10. In the hearing, we received testimony expressing concern that Dicamba/Roimdup
tolerant soybean will cause collateral injury to fruit and vegetable farmers and
backyard gardeners. In fact, your testimony acknowledges that concern. In the event
that such injury should materialize, who will be liable for the economic costs of the
affected fanners? Will it be Monsanto or another party?
1 1. Concerning USDA regulation of biotech crops: Specifically, does the Company
believe USDA has authority under the Plant Protection Act {codified at 7 U.S.C. §
7701 et. seq.) and its regulations to regulate GE crops so as to prevent herbicide-
resistant w'eeds? Has the Company ever taken a position on that question? Please
provide all documents expressing a legal opinion on that question.
Ranking member Jordan submits the following additional questions:
1 . Who is responsible for addressing the issue of herbicide-resistant weeds?
2. The advertorial you received during the September 30, 2010 hearing contained a
recommendation for growers to use two modes of action. Can you explain what that
means?
The Oversight and Government Reform Committee is the principal oversight committee in
the House of Representatives and has broad oversight jurisdiction as set forth in House Rule X.
We request that you provide written answers to these questions as soon as possible, but in no
case later than 5:00 p.m. on October 30, 2010.
138
Mr. Phil Miller
October 15,2010
Page 3
If you have any questions regarding this request, please contact Jaron Bourke, Staff Director
at (202) 225-6427.
Sincerely,
Dennis J. Kucinich
Chairman
Domestic Policy Subcommittee
cc: Jim Jordan
Ranking Minority Member
139
MONSANTO
Monsanto Company
800 North Linosergh Buvd.
St. Louis, Missotmt 63167
http;//www.monsanto.com
November 12, 2010
The Hon. Dennis J. Kucinich
Chairman
Domestic Policy Subcommittee
House Committee on Oversight and Government Reform
Dear Chairman Kucinich;
On behalf of Monsanto, thank you for the opportunity to re^nd to questions submitted
for the record following your hearing on September 30"'. I hope the information
provided assists the Subcommittee in its analysis of the issues surrounding
biotechrmlogy regulatory policy and the development of herbicide resistant weeds.
This is an important topic for not only our industry but also for our Nation and formers
around the world as we seek to feed an ever-growing global population.
Please do not hesitate to contact me if I can be of further assistance.
i Monsanto Company
Cc: The Hon. Jim Jordan, Ranking Member
140
QUESTIONS FROM CHAIRMAN KUCINICH
1. You say in your written testimony that genetically engineered crops increase farmer profits, yields
and carbon sequestration. As you know, the scope of the hearing was limited to herbicide-
resistant crops. Please provide the Subcommittee with ail documents that provide a basis for
those three claims as they would relate to herbicide-resistant crops.
Provided below is a list of publications that establish that GE crops increase farmer profits, yields
and carbon sequestration. Because the benefits of herbicide-tolerant and insect-resistant crops are
additive when these traits are combined in the same crop, researchers often assess the cumulative
benefits of these traits. The list of publications provided includes analysis of the benefits of
herbicide-tolerant and insect-resistant crops separately and combined, in a recent comprehensive
analysis, the National Research Council Committee on the Impact of Biotechnology on Farm-Level
Economics and Sustainability concluded, "In general, the committee finds that genetic-engineering
technology has produced substantial net environmental and economic benefits to U.S. farmers
compared with non-6E crops in conventional agriculture."
List of Publications:
Brookes, G. and P. Barfoot. "Global Impact of Biotech Crops: Environmental Effects, 1996-
2008." AgBioForum 13(2010):76-94.
Brookes, G. and P. Barfoot. "Global Impact of Biotech Crops: Income and Production Effects,
1996-2007," AgBioForum 12(2009);184-208.
Brookes, G. and P. Barfoot. "Global Impact of Biotech Crops: Socio-Economic & Environmental
Effects 1996-2007." Outlooks on Pest Management (2009), 1-7.
Brookes, G., T.H. Tse, S. Tokgog, and G. Elobeid. "The Production and Price Impact of Biotech
Corn, Canola, and Soybean Crops." AgBioForum 13(2010):25.52.
CTIC. 2010. Facilitating Conservation Farming Practices and Enhancing Environmental
Sustainability with Agricultural Biotechnology Executive Summary.
http://www.ctic.org/BiotechSustainabilitv .
CTIC. 2009. Top 10 Benefits of Conservation Tillage. Farm and Food Facts '09. Purdue
University Conservation Technology Information Center, West Lafayette, Indiana.
http://www.ilfb.ore/fff2009/37.pdf .
Edgerton, M. 2009, increasing Crop Productivity to Meet Global Needs for Feed, Food, and
Fuel. Plant Physiology. 149: 7-13.
Fawcett, R.,Towry, D. Conservation Tillage and Plant Biotechnology: How New Technologies
Can Improve the Environment by Reducing the Need to Plow, Conservatory Technology
Information Center, West Lafayette, Indiana. (2002) pp. 1-24.
Page 1 of 7
141
Fernandez-Cornejo, J. Mishra, A., Nehring, R., Hendricks, C., Southern, M., Gregory, A. Off-farm
Income, Technology Adoption, and Farm Economic Performance. USDA-ERS Report No. 36
92007. htto://www.ers. usda.gov/Publications/err36/err36 reportsummarv.pdf .
NRC Report. "Impact of Genetically Engineered Crops on Farm Sustainability in the United
States." Committee on the Impact of Biotechnology on Farm-Level Economics and
Sustainability; National Research Council. httD://www.nap.edu/cataloe/12804.html .
Roberts, R.K,, B.C, English, Q, Gao, and J.A. Larson, "Simultaneous Adoption of Herbicide-
Resistance and Conservation-Tillage Cotton Technologies.” Journal of Agricultural and Applied
Economics 38(2006):629-643.
Qaim, M. 2009. The Economics of Genetically Modified Crops. Annu. Rev, Resour. Econ. 1:665-
693.
2. At what point was glyphosate-resistance in weeds first predicted and when was it first
documented by the Company or Company-funded scientists? Please provide all citations for
published research.
Weeds and other organisms can adapt to their environments. The development of weed
populations resistant to any herbicide is in theory an eventual outcome of its use and is influenced
by inherent characteristics of the chemistry and application of agricultural practices. In that sense,
from a scientific perspective, the eventual discovery of weed populations resistant to any herbicide
including glyphosate can be theoretically anticipated based on the principles of population biology
and selection; however it is not possible to anticipate with any specificity or probability when, under
what circumstances, in what geographies or in what species resistance will occur.
The first known and documented case of glyphosate resistance was a population of weeds in
Australia discovered in 1996 in conventional (non-biotech) cropping systems (reference
www.weedscience.ore ) after 15 years of successful glyphosate use in those systems. (Attached is
the original publication). Monsanto did not “predict" this development. Upon discovery of this
population that was potentially resistant, Monsanto collaborated with the public sector scientists
who made the discovery. Attached is a Monsanto authored publication using seed from this first
glyphosate resistant population, regarding efforts to understand the mechanism of resistance.
Powles, S. B., D.F. Lorraine-Colwill, J.J. Dellow, and C. Preston. 1998. Evolved resistance to
glyphosate in rigid ryegrass (Lolium rigidum) in australis. Weed Science, 46; 604-607.
Feng, Paul C.C., James E. Pratley and Josephe A Bohn. 1999. Reistance to glyphosate in Lolium
rgidum. II. Uptake, translocation and metabolism. Weed Sceince, 47: 412-415,
3. Are voluntary stewardship measures sufficient to prevent and/or mitigate glyphosate resistance
in weeds? Please provide specific examples of purely voluntary stewardship practices that have
successfully prevented or contained the spread of glyphosate resistance in weeds on a broad basis
involving many individual farmers.
To be clear, neither the scientific community nor any other community of experts can identify any
Page 2 of 7
142
practice or product that will prevent resistance to any herbicide. However, the conscientious
implementation of agronomic best management practices (BMPs) can delay or mitigate the
development of resistance. Such BMPs can and should be established in market-driven voluntary
stewardship programs.
Specific to herbicide tolerant crops, market research, as described in the following reference,
indicates that growers are increasingly adopting best management practices to manage weed
resistance. These practices are being implemented voluntarily by growers. As an example, in the
2007 market research study approximately 50 % of Roundup Read corn growers use other
herbicides in addition to giyphosate. More recent market research indicates that the percentage of
RR corn growers using other herbicides has increased significantly in 2010.
Frisvold, G. B., T. M. Hurley, and P.D. Mitchell. 2009. Adoption of Best management Practices to
control Weed Resistance by Corn, Cotton, and Soybean Growers. AgBioForun, 12{3&4): 370-381.
4. Given that including in a rotation non-glyphosate-resistant crops can be important to preventing
giyphosate resistance in weeds, what varieties of non-glyphosate-resistant corn, cotton and soy
does Monsanto and its affiliated seed companies offer to farmers?
As previously mentioned, neither the scientific community nor any other community of experts can
identify any practice or product that will prevent resistance to any herbicide. However, the
conscientious implementation of agronomic best management practices (BMPs) can delay or
mitigate the development of resistance. Such BMPs can and should be established in market-driven
voluntary stewardship programs.
Best practices for managing weed resistance involve the use of a diversified weed management
program that can include the use of multiple herbicide modes of action in mixtures, sequences or in
rotation with or without the use of tillage and cultural practices such as crop rotation. Importantly,
it is not the trait present in the crop but rather the herbicide(s) used in the system that provides the
diversity of weed management practices that are important to minimize the chance of the
development of resistant populations. Using herbicide mixtures and sequences even if repeated
over multiple years can be more effective than rotating herbicides across years as highlighted in the
following research papers. Thus, rotating to non-transgenic or transgenic non-glyphosate-tolerant
crops is not critical for implementing a successful, diversified weed management program.
To address your question regarding non-glyphosate tolerant varieties, Monsanto commercially
offers 44 non-glyphosate tolerant corn hybrids, seven cotton varieties and seven soybean varieties.
Non-glyphosate tolerant hybrids and varieties are also offered by other seed companies.
Beckie, H.J. and Xavier Reboud. 2009. Selecting for Weed Resistance: Herbicide Rotation and
Mixture. Weed Technology 23:363-370.
Diggle, A.J., P.B. Neve, and F.P. Smith. 2003. Herbicides used in combination can reduce the
probability of herbicide resistance in finite weed populations. Weed Research 43: 371-382.
Maxwell B.D., M.L. Roush and S.R. Radosevich. 1990, Predicting the evolution and dynamics of
herbicide resistance in weed populations. Weed Technology 4, 2-13.
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143
5. Concerning the development of other herbicide-resistant resistant (sic) crops. Including dicamba-
resistant soybeans, what is the scale of Monsanto Company’s research and development efforts
to create other herbicide resistant crops?
Monsanto's research and development pipeline includes the following projects: dicamba-
glufosinate tolerant cotton, dicamba tolerant soybeans, dicamba-glufosinate tolerant corn, and
FOPS tolerant corn.
6. Is Dicamba-resistance in weeds currently predicted by the Company or any Company funded
scientist in fields that will be growing Dicamba-resistant soybeans?
Weeds and other organisms can adapt to their environments. The development of weed
populations resistant to any herbicide is in theory an eventual outcome of its use and is influenced
by inherent characteristics of the chemistry and application of agricultural practices, in that sense,
from a scientific perspective, the eventual discovery of weed populations resistant to any herbicide
including glyphosate can be theoretically anticipated based on the principles of population biology
and selection; however it is not possible to anticipate with any specificity or probability when, under
what circumstances, in what geographies or in what species resistance will occur.
To date there are two species with known resistance to dicamba in the U.S. after over 40 years of
use; kochia (Kochia scoparia) and prickly lettuce (Lactuca serriola) (www weedscience.org). The use
of dicamba in dicamba tolerant (DT) soybeans is not expected to result in an increase in resistant
populations of species known to be dicamba resistant nor to increase the total number of dicamba
resistant species. In DT soybeans, dicamba will predominantly be used in combination with other
herbicides with different modes of action, principally glyphosate, but also with other soil-active
herbicides (Johnson et al. 2010). The presence of multiple herbicides in the weed management
system greatly diminishes the chance that weed resistance will occur as noted in the references
listed for question 4, above.
Johnson, B., Young, B., Matthews, J., Marquardt, P., Slack, C., Bradley, K,, York, A., Culpepper, S.,
Hager, A., Al-Khatib, K,, Steckei, L., Moechnig, M., Loux, M., Bernards, M., and Smeda, R. 2010. Weed
control in dicamba-resistant soybeans. Online. Crop Management doi;10.1094/CM-2010-0920-01-
RS,
7. What lessons has the Company taken from glyphosate-resistance in weeds to apply to preventing
or mitigating Dicamba resistance in weeds?
Neither the scientific community nor any other community of experts can identify any practice or
product that will prevent resistance to any herbicide. However, the conscientious implementation
of agronomic best management practices (BMPs) can delay or mitigate the development of
resistance. Such BMPs can and should be established in market-driven voluntary stewardship
programs.
We and other scientists have learned that where diversity in weed management systems is
maintained, the use of glyphosate (and other herbicides) for weed control can be sustained (Powles,
2008). A diverse weed management program will be implemented for dicamba-tolerant crop
systems. As noted above in question 6, use of dicamba in dicamba tolerant (DT) soybeans will
predominantly be used in combination with other herbicides with different modes of action.
Page 4 of 7
144
principally giyphosate, but also with other soil-active herbicides (Johnson et al. 2010). In addition,
farmer recommendations will be in place for surveillance and the early identification of dicamba
resistance, should it occur, and for ways to manage the occurrence and to limit the spread of
potential dicamba-resistant weeds in soybeans and crops rotated with soybeans.
Powles, Stephen B. 2008. Evolution in Action: glyphosate-resistant weeds threaten world crops.
Outlooks on Pest Management, December 2008.
8. Does the Company believe that voluntary stewardship measures alone will be sufficient to
prevent Dicamba resistance in weeds from occurring after Dicamba-resistant crops are planted?
Yes, however, and again to be clear, neither the scientific community nor any other community of
experts can identify any practice or product that will prevent resistance to any herbicide. However,
the conscientious implementation of agronomic best management practices (BMPs) can delay or
mitigate the development of resistance. Such BMPs can and should be established in market-driven
voluntary stewardship programs.
As noted in the answer to question 3, voluntary stewardship measures have been effective for
managing weed resistance in agriculture and will be effective for managing weed resistance in
dicamba-tolerant crop systems. As noted above in questions 6-7, in DT soybeans, dicamba will
predominantly be used in combination with other herbicides with different modes of action,
principally giyphosate, but also with other soil-active herbicides (Johnson et al. 2010). Thus the use
of dicamba in dicamba tolerant (DT) soybeans is not expected to result in an increase in resistant
populations of species known to be dicamba resistant nor to increase the number of dicamba
resistant species. The presence of multiple herbicides in the weed management system greatly
diminishes the chance that weed resistance to dicamba will occur.
9. In light of producer concerns for horticultural crops once Dicamba gains more widespread use
after Dicamba-resistant crops are deregulated, what measures does the Company believe will
prevent producer concerns from being realized?
The potential off-site movement of herbicides is not new or unique to dicamba-tolerant crops. The
EPA regulates the use of herbicides, including off-site movement. The EPA-approved label will
include provisions designed to minimize drift. Farmers are required to follow herbicide labels and
are aware of the importance of following BMPs to minimize off-target movement of herbicides.
Monsanto is working with multiple stakeholders, including soybean growers as well as growers of
crops that may be grown nearby, to design appropriate stewardship measures to address the
potential off-site movement of dicamba when used with dicamba-tolerant crops. We are also
working with other companies to develop improved dicamba formulations that reduce the potential
for off-site movement.
10. In the hearing, we received testimony expressing concern that Dicamba/Roundup tolerant
soybean will cause collateral injury to fruit and vegetable farmers and backyard gardeners. In
fact, your testimony acknowledges that concern. In the event that such injury should materialize,
who will be liable for the economic costs of the affected farmers? Will it be Monsanto or another
party?
Page 5 of 7
145
To clarify, it is the application of herbicides (regulated by the EPA), not the soybeans, that has raised
the concern regarding potential off-site movement and injury to neighboring crops. The soybeans
have no characteristics that would result in injury of any kind, including to farmers or gardeners.
Liability for economic costs of persons affected by offsite movement from the application of
pesticides depends on the facts of the situation and the applicable state law. To the extent offsite
movement results from the use of a pesticide in a manner that is not in accordance with the
product's EPA-approved label, such use would be a violation of federal law. EPA's registration of a
pesticide is a determination that when used in accordance with label directions, the pesticide will
cause no unreasonable adverse effects on the environment, a concept comparable to the analysis
under NEPA.
11. Concerning USDA regulation of biotech crops; Specifically, does the Company believe USDA has
authority under the Plant Protection Act (codified at 7 U.S.C. 7701 et. seq.) and its regulations to
regulate GE crops so as to prevent herbicide-resistant weeds? Has the Company ever taken a
position on that question? Please provide all documents expressing a legal opinion on that
question.
No.
As Dr. Miller provided in his written statement, weed resistance is an herbicide issue, not a
biotech crop issue, and is dependent on how herbicides are used. Under the Federal Insecticide,
Fungicide and Rodenticide Act (FIFRA) and the Federal Government's Coordinated Framework
for regulating biotechnology-derived products, EPA is the agency charged with analyzing the
potential environmental impacts from the use of herbicides and other pesticides. The EPA's
determinations are the functional equivalent of a NEPA analysis.
In complying with the National Environmental Policy Act (NEPA), USDA evaluates potential
impacts to the human environment related to its decision to deregulate a biotech crop. The use
of herbicides in conjunction with an herbicide-tolerant crop, and any associated impact on the
potential development of weed resistance, is considered by USDA as part of its NEPA
evaluation. USDA does not, however, have the authority to regulate herbicides or weed
resistance to herbicides under the Plant Protection Act, which regulates plant pests and noxious
weeds.
The Company's position on this question is aligned with the industry as expressed by BIO (the
Biotechnology Industry Organization) and CLA (CropLife America). The opinion of Monsanto in-
house counsel is reflected in these responses.
QUESTIONS FROM RANKING MEMBER JORDAN
1. Who is responsible for addressing the issue of herbicide-resistant weeds?
There is not just one reason why resistance develops, nor is there just one way to best manage it.
Monsanto has a shared responsibility with farmers, university researchers, extension scientists and
others in industry to provide the best possible advice, options and recommendations for how to
Page 6 of 7
146
proactively and reactively manage resistance. The U.S. ERA regulates use of herbicides and its
regulatory position on resistance is set forth in PR Notice 2001-5. Industry, the public sector and
farmers also have the responsibility to monitor for resistance and to provide early identification of
herbicide resistant weeds for farmers. The farmer and/or land owner ultimately decides what weed
management practices are best and most appropriate for use on his crops. Green and Owen, 2010,
provide an overview of key concepts and management programs that need to be considered in
herbicide resistant crops to ensure sustainability of the herbicides used in these crops.
Green, J.M. and M.D.K. Owen. 2010. Herbicide-resistant crops: utilities and limitation for herbicide-
resistant weed management. Online: J. Agric. Food Chem. Doi:10.102/jfl01286h.
2. The advertorial you received during the September 30, 2010 hearing contained a recommendation
for growers to use two modes of action. Can you explain what that means?
Each herbicide is defined in large part by its mode of action for controlling weeds. This provides
information about what plant mechanisms are disrupted when the herbicide is sprayed on a weed.
The mechanism of weed resistance and the associated naturally occurring genes that can confer
resistance to a herbicide is often related to the mode of action of the herbicide. Estimates of the
frequency of resistance genes within weed populations differ by herbicide but are typically very low
for weed populations that remain susceptible to the herbicides. When two herbicides, with
different modes of action, both effective for controlling a weed are used in combination, the
likelihood that herbicide resistant genes for both herbicides occur together in the same plant is very
low. From a management standpoint, the use of mixtures of two or more herbicides with different
modes of action is predicted by model simulations to delay resistance much longer than the use of
either herbicide alone or by rotating herbicides in successive crops. The principle of using multiple
modes of action is also a basic component of resistance management of insects and fungi to
insecticides and fungicides. The following references may be reviewed relative to this discussion.
Gressel, J. and L. A. Segel 1990. Modeling the effectiveness of herbicide rotations and mixtures as
strategies to delay or preclude resistance Weed Technology 4: 186-198.
Wrubel, R.P. and J. Grssel. 1994. Are herbicide mixtures useful for delaying the rapid evolution of
resistance - a case study. Weed Technology 8, 635-648.
Beckie, H. J. 2006. Herbicide-resistant weeds: Management tactics and practices. Weed Technology
20(3): 793-814.
Page 7 of 7
147
AgBioForum, 13(1): 76-94. ©2010 AgBioForum.
Global Impact of Biotech Crops: Environmental Effects, 1996-2008
Graham Brookes and Peter Barfoot This article updates the assessment of the impact commercial-
PG Economics Ltd, Dorchester, UK i^ed agricultural biotechnology is having on global agricutture
from an environmental perspective. It focuses on the impact of
changes in pesticide use and greenhouse gas emissions arising
from the use of biotech crops. The technology has reduced pes-
ticide spraying by 352 million kg (-8.4%) and. as a result,
decreased the environmental impact associated with herbicide
and insecticide use on these crops (as measured by the indica-
ti3r the «ivironmental impact quotient) by 16.3%. The technol-
ogy has also significantiy reduced the release of greenhouse
gas emissions from this cropping area, which, in 2008, was
equivalent to removing 6.9 million cars from the roads.
Key words; pesticide, active ingredient, environmental impact
quotient, carbon sequestration, biotech crops, no tillage.
Introduction
This study presents the findings of research into the
global environmental impact of biotech crops since their
commercial introduction in 1996. It updates the findings
of earlier analyses presented by the authors in AgBioFo-
ram «(2&3), 9(3), and ;/(!).*
The environmental impact analysis undertaken
focuses on the impacts associated with changes in the
amount of insecticides and herbicides applied to the bio-
tech crops relative to conventionally grown alternatives.
The analysis also examines the contribution of biotech
crops towards reducing global greenhouse gas (GHG)
emissions.
The analysis is mostly based on that of existing
farm-level impact data from biotech crops. Primaiy data
for impacts of commercial biotech cultivation on both
pesticide usage and greenhouse gas emissions is, how-
ever, limited and is not available for every crop, In every
year and for each country. Nevertheless, all identified,
representative, previous research has been utilized. This
has been used as the basis for the analysis presented,
although, where relevant, primary analysis has been
undertaken from base data.
1. Readers should note that some data presented in this article
are not directly comparable with data presented in previous
articles because the current article takes into account the
availability of new data and analysis (including revisions to
data for earlier years).
Environmental Impacts from Insecticide
and Herbicide Use Changes
Methodology
Assessment of the impact of biotech crops on insecti-
cide and herbicide use requires comparisons of the
respective weed- and pest-control measures used on bio-
tech versus the ‘conventional alternative’ form of pro-
duction. This presents a number of challenges relating to
availability and representativeness. Comparison data
ideally derives from farm-level surveys, which collect
usage data on the different forms of production. A
search of literature on biotech crop impact on insecti-
cide or herbicide use at the trait, local, regional, or
national level shows that the number of studies explor-
ing these issues is limited (e.g., Pray, Huang, Hu, &
Rozelle, 2002; Qaim & De Janvry, 2005; Qaim & Trax-
ier, 2002) with even fewer (e.g., Brookes, 2003, 2005),
providing data to the pesticide (active ingredient) level.
Second, national-level pesticide usage survey data is
also extremely limited; in fact, there are no published
annual pesticide usage surveys conducted by national
authorities in any of the countries currently growing
biotech traits, and the only country in which pesticide
usage data is collected (by private market-research com-
panies) on an annual basis and which allows a compari-
son between biotech and conventional crops to be made
is the United States.^
2. The US Department of Agriculture also conducts pesticide-
usage surveys, but these are not conducted on an annual basis
(e.g, the last time corn was included was 2005) and do not
disaggregate usage by production type (biotech versus con-
ventional).
148
Unfortunately, even where national survey data is
available on usage, the data on conventional crop usage
may fail to be reasonably representative of what herbi-
cides and insecticides might be expected to be used in
the absence of biotechnology. When biotech traits domi-
nate total production (e.g., for soybeans, com, cotton,
and canola in the United States since the early 2000s),
the conventional cropping dat^et used to identify pesti-
cide use relates to a relatively small share of total crop
area and therefore is likely to underestimate what usage
would probably be in the absence of biotechnology. Tlie
reasons why this conventional cropping dataset is
unrepresentative of the levels of pesticide use that might
reasonably be expected to be used in the absence of bio-
technology include the following.
• While the levels of pest and weed problems/dam-
age vary by year, region, and within region, farm-
ers who continue to farm conventionally are often
those with relatively low levels of pest or weed
problems, and hence see little, if any, economic
benefit from using the biotech traits targeted at
these agronomic problems. Their pesticide usage
levels therefore tend to be below the levels that
would reasonably be expected to be used to con-
trol these weeds and pests on an average farm. A
good example to illustrate this relates to the US
cotton crop where, for example, in 2008, nearly
half of the conventional cotton crop was located in
Texas. Here, levels of bollworm pests (the main
target of biotech insect-resistant cotton) tend to be
consistently low, and cotton farming systems are
traditionally of an extensive, low input nature
(e.g., the average cotton yield in Texas was about
82% of the US average in 2008).
• Some of the farms continuing to use conventional
(non-biotech) seed traditionally use extensive,
low-intensity production methods (including
organic) in which limited (below average) use of
pesticides is a feature (see, for example, the Texas
cotton example above). The usage pattern of this
subset of growera is therefore likely to understate
usage for the majority of farmers if all crops were
conventional.
• Many of the farmers using biotech traits have
experienced improvements in pest and weed con-
trol from using this technology relative to the con-
ventional control methods previously used. If
these farmers were to now switch back to using
conventional techniques — based wholly on pesti-
cides — it is likely that most would wish to main-
AgBioForum, 13(1), 2010 j 77
tain the levels of pest/weed control delivered with
use of the biotech traits and therefore would use
higher levels of pesticide than they did in the pre-
biotech crop days.
To overcome these problems in die analysis of pesti-
cide use changes arising from the adoption of biotech
crops (i.e., where biotech traits account for the majority
of total plantings), presented in this article,^ actual
recorded usage levels for the biotech crops are used
(based on survey data), with the conventional alternative
(counterfactual situation) identified based on opinion
from extension advisors and industry specialists as to
what farmers might reasonably be expected to use in
terms of crop protection practices and usage levels of
pesticide.'* This methodology has been used by others,
for example Johnson and Strom (2007). Details of how
this methodology has been applied to the 2008 calcula-
tions, sources used for each trait/country combination
examined and examples of typical conventional versus
biotech pesticide applications are provided in Appendi-
ces A and B.
The most common way in which changes in pesti-
cide use with biotech crops has been presented in the lit-
erature has been in terms of the volume (quantity) of
pesticide applied. While comparisons of total pesticide
volume used in biotech and conventional crop produc-
tion systems are a useful indicator of associated envi-
ronmental impacts, amount of active ingredient used is
an imperfect measure because it does not account for
differences in the specific pest-control programs used in
biotech and conventional cropping systems. For exam-
ple, different specific products used in biotech versus
conventional crop systems, differences in the rate of
pesticides used for efficacy, and differences in the envi-
ronmental characteristics (mobility, persistence, etc.) are
masked in general comparisons of total pesticide vol-
umes used.
In this article, the pesticide-related environmental
impact changes associated with biotech crop adoption
S. Also see earlier work by the authors (Brookes & Barfoot,
2006. 2007. 2008, 2009b).
4. In other words, Brookes and Barfoot draw on the findings of
work by various researchers at the National Center for Food
and Agriculture Policy (Carpenter & Gianessi, 1999; John-
son & 5Jtrom, 2007; Sankula & Blumenthal, 2003, 2006; also
see http://www.ncfap.org). This work consults with in excess
of 50 extension advisors in almost all of the states growing
corn, cotton, and soybeans and therefore provides a reason-
ably representative perspective on likely usage patterns.
Brookes & Barfoot — Global Impact of Biotech Crops: Environmental Effects, 1996-2008
149
AgBioForum, 13(1), 2010 1 78
Table 1. Impact of changes in the use of herbicides and insecticide growing biotech crops globally 1996-2008.
Trait
'.'■o -m
Chango in field 0Q
im|>act (in terms of
million field EIQftia
units)
% change in
^ use on
biotech crops
GM HT soybeans
-50.45
-5,314.8
-3.0
-16.6
62-47
GM HT maize
-111.58
-2,724.2
-7.5
-8,5
22.40
GM HT canola
-13.74
^37,2
-17.6
-24.3
5.83
GM HT cotton
-6,29
-188.4
-3.4
-5.5
2,41
GM IR maize
-29.89
-1,007.0
-35.3
-29.4
36-04
GM IR cotton
-6,555.7
-21.9
-24.8
13.20
GM HT sugar beet
+0.13
-0.46
+10
-2
0,26
Totals
-352.42
-16,227.76
-8.4
-16.3
142.61
are examined in terms of changes in the volume
(amount) of active ingredient applied but supplemented
by the use of an alternative indicator, developed at Cor-
nell University in the 1990s: the environmental impact
quotient (EIQ). The EIQ indicator, developed by
Kovach, Petzoidt, and Degni, and Tette (1992) and
updated annually, effectively integrates the various envi-
ronmental impacts of individual pesticides into a single
‘field value per hectare.' ITie EIQ value is multiplied by
the amount of pesticide active ingredient (ai) used per
hectare to produce a field EIQ value. For example, the
EIQ rating for glyphosate is 15.33. By using this rating
multiplied by the amount of glyphosate used per hectare
(e.g., a hypothetical example of 1.1 kg applied per ha),
the field EIQ value for glyphosate would be equivalent
to 16.86/ha.
The EIQ indicator used is therefore a comparison of
the field ElQ/ha for conventional versus biotech crop
production systems, with the total environmental impact
or load of each system, a direct function of respective
field ElQ/ha values and the area planted to each type of
production (biotech versus conventional). The use of
environmental indicators is commonly used by
researchers, and the EIQ indicator has been, for exam-
ple, cited by Brimner, Gallivan, and Stephenson
(2004) — in a study comparing the environmental
impacts of biotech and conventional canola — and by
Kleiter et al. (2005).
The EIQ indicator provides an improved assessment
of the impact of biotech crops on the environment when
compared to only examining changes in volume of
active ingredient applied, because it draws on some of
the key toxicity and environmental exposure data
related to individual products, as applicable to impacts
on farm workers, consumers, and ecology. Readers
should, however, note that the EIQ is an indicator only
and does not take into account all environmental issues
and impacts. It is therefore not a comprehensive indica-
tor. Detailed examples of the relevant amounts of active
ingredient used and their associated field EIQ values for
biotech versus conventional crops for the year 2008 are
presented in Appendix B.
Results
Biotech traits have contributed to a significant reduction
in the environmental impact associated with insecticide
and herbicide use on the areas devoted to biotech crops
(Table I). Since 1996, the use of pesticides on the bio-
tech crop area was reduced by 352 million kg of active
ingredient (8.4% reduction), and the environmental
impact associated with herbicide and insecticide use on
these crops — as measured by the EIQ indicator — fell by
1 6.3%. In absolute terms, the iai^est environmental gain
has been associated with the adoption of GM IR cotton
and reflects the significant reduction in insecticide use
that the technology has allowed, in what has tradition-
ally been an intensive user of insecticides. The volume
of herbicides used in biotech soybean crops also
decreased by 50 million kg (1996-2008), a 3% reduc-
tion, while the overall environmental impact associated
with herbicide use on these crops decreased by a signifi-
cantly larger 16.6%. This highlights the switch in herbi-
cides used with most GM FIT crops to active ingredients
with a more environmentally benign profile than the
ones generally used on conventional crops.
Important environmental gains have also arisen in
the maize and canola sectors. In the maize sector, herbi-
cide and insecticide use decreased by 141.5 million kg
and the associated environmental impact of pesticide
use on this crop area decreased due to a combination of
reduced insecticide use (29.4%) and a switch to more
environmentally benign herbicides (8.5%). In the canola
sector, farmers reduced herbicide use by 13.7 million kg
(a 17.6% reduction) and the associated environmental
Brookes & Barfoot — Globed Impact of Biotech Crops: Environmental Effects, 1996-2008
150
Table 2. Biotech crop environmental benefits from lower
insecticide and herbicide use 1996-2008: Developing ver-
sus developed countries.
Change in field
EIQ impact (in
terms of million
field ElQ/ha units):
Developod
countries
Change in field
EIQ Impact On
tenns of miitran
field EIQ/ha units)
Developing
countnos
GM HT soybeans
3,692.8
1,622.0
GM HT maize
2.674,9
49.3
GM HT cotton
153.5
34.9
GM HT canola
437.2
0
GM IR corn
983,8
23.2
GM IR cotton
443.3
6,112.4
GM HT sugar beet
0-46
0
Total
8,385.96
7,841.8
impact of herbicide use on this crop area fell by 24.3%
due to a switch to more environmentally benign herbi-
cides.
In terms of the division of the environmental bene-
fits associated with less insecticide and herbicide use for
farmers in developing countries relative to farmers in
developed countries. Table 2 shows roughly a 50% split
of the environmental benefits (1996-2008) in developed
and developing countries. Three quarters of the environ-
mental gains in developing countries have been from the
use of GM IR cotton.
Impact on Greenhouse Gas Emissions
Methodology
The methodology used to assess impact on greenhouse
gas emissions combines reviews of literature relating to
changes in fuel and tillage systems and carbon emis-
sions coupled with evidence from the development of
relevant biotech crops and their impact on both fuel use
and tillage systems. Reductions in the level of GHG
emissions associated with the adoption of biotech crops
is acknowledged in a wide body of literature (CTIC,
2002; Fabrizzi, Moronc, & Garcia, 2003; Jasa, 2002;
Johnson et ai., 2005; Lazarus & Selley, 2005; Liebig et
ai., 2005; Reicosky, 1995; Robertson, Paul, & Harwood,
2000; West & Post, 2002). First, biotech crops contrib-
ute to a reduction in fuel use due to less frequent herbi-
cide or insecticide applications and a reduction in the
energy use in soil cultivation. For example, Lazarus and
Selley (2005) estimated that one pesticide spray applica-
tion uses 1.045 liters of fuel, which is equivalent to 2.87
kg^ha of carbon dioxide emissions. In this analysis, we
AgBioForum. 13(1), 2010 | 79
used the conservative assumption that only GM IR
crops reduced spray applications with the number of
spray applications of herbicides remaining the same for
conventional production systems.^
In addition, there has been a shift from conventional
tillage to reduced/no till. This has had a marked impact
on tractor fuel consumption due to energy-intensive cul-
tivation methods being replaced with no/reduced tillage
and herbicide-based weed control systems. The GM HT
crop where this is most evident is GM HT soybeans.
Here, adoption of the technology has made an important
contribution to facilitating the adoption of reduced or
no-til!age farming.^' Before the introduction of GM HT
soybean cultivars, no-tillage (NT) systems were prac-
ticed by some farmers using a number of herbicides and
with vaiydng degrees of success. The opportunity for
growers to control weeds with a non-residual foliar her-
bicide as a “burndown" pre-seeding treatment followed
by a post-emergent treatment when the soybean crop
became established has made the NT systems more reli-
able. technically viable, and commercially attractive.
These technical advantages combined with the cost
advantages have contributed to the rapid adoption of
GM HT cultivars and the near doubling of the NT soy-
bean area in the United States (also more than a five-
fold increase in Argentina). In both countries, GM HT
soybeans are estimated to account for more than 95% of
the NT soybean crop area in 2007/8.
Substantial growth in NT production systems have
also occurred in Canada, where the NT canola area
increased from 0.8 million ha to 2.6 million ha (equal to
about half of the total canola area) between 1996 and
2005 (95% of the NT canola area is planted with GM
HT cultivars). Similarly the area planted to NT in the
US cotton crop increased from 0.2 million ha to 1 mil-
lion ha over the same period (of which 86% is planted to
GM HT cultivars) and has remained at this share of the
total crop in 2007 and 2008.
The fuel savings resulting from changes in tillage
systems used in this article are drawn from estimates
from studies by Jasa (2002), CTIC (2002), and the Uni-
versity of Illinois (2006). The adoption of NT farming
systems is estimated to reduce cultivation fuel usage by
32.3 liters/ha compared with traditional conventional
5. Evidence from different countries varies, with some countries
exhibiting on average no change and others showing a small
net reduction in the number of spray runs.
6. See, for example. CTIC (2002) and American Soybean Asso-
ciation (2001).
Brookes & Barfoot — Global Impact of Biotech Crops: Environmental Effects, 1996-2008
151
tillage (CT; which has an average usage of 43.7 liters/
ha) and by 19.33 liters/ha compared with (the average
of) reduced tillage (RT) cultivation methods (which has
an average usage of 30.72 liters/ha). In turn, this results
in reductions of carbon dioxide emissions of 88.81 kg/
ha for NT relative to CT and 35.66 kg/ha for RT relative
to ct7
Secondly, the use of ‘no-tilT and ‘reduced-till’ farm-
ing systems that utilize less ploughing increase the
amount of organic carbon in tlie form of crop residue
that is stored or sequestered in the soil. This carfxin
sequestration reduces carbon dioxide emissions into the
environment. Rates of carbon sequestration have been
calculated for cropping systems using normal tillage and
reduced tillage and these were incorporated in the analy-
sis on how GM crop adoption has played an important
facilitating role in increasing carbon sequestration, and
ultimately, on reducing the release of carbon dioxide
into the atmosphere. Of course, the amount of carbon
sequestered varies by soil type, cropping system, and
eco-region. In North America, the Intergovernmental
Panel on Climate Change (IPCC, 2006) estimates that
the conversion from conventional-tillage to no-tillagc
systems stores between 50 kg carbon/ha'* yr and 1,300
kg carbon/ha'^ yr (average 300 kg carbon/ha'^ yr). In the
analysis presented below, a conservative saving of 300
kg carbon/ha"’ yr was applied to all NT agriculture and
100 kg carbon/ha'* yr was applied to RT agriculture.
Where some countries aggregate their no- and reduced-
till data (e.g,, Argentina), the reduced-tillage saving
value of 100 kg carbon/ha'' yr was used. One kg of car-
bon sequestered is equivalent to 3.67 kg of carbon diox-
ide. These assumptions were applied to the reduced
pesticide spray applications data on GM IR crops,
derived from separate analysis and reviews of farm
income literature impacts by the authors (see Brookes &
Barfoot, 2009a) and the GM HT crop areas using no/
reduced tillage (limited to the GM HT soybean crops in
North and South America and GM HT canola crop in
Canada).^
Results
Herbicide-tolerant Soybeans
The United States: Over the 1996-2008 period, the area
of soybeans cultivated in the United Slates increased
7. Based on one-Uler fuel results in a carbon dioxide saving of
2. 75 kg/ha from Lazarus and Selly (2005).
AgBioForum, 13(1), 2010 { 80
rapidly from 25.98 million ha to 30.21 million ha. Over
the same period, the area planted using conventional till-
age is estimated to have fallen by 21.3% (from 7.5 mil-
lion ha to 5.9 million ha), while the area planted using
NT has increased by 62.3% (from 7.7 million ha to 12.5
million ha).
TTie most rapid rate of adoption of the GM HT tech-
nolo^ has been by growers using NT systems (GM HT
cultivars accounting for an estimated 99% of total NT
soybeans in 2008). This compares with conventional-
tillage systems for soybeans, where GM HT cultivars
account for about 79% of total conventional-tillage soy-
bean plantings. The importance of GM HT soybeans in
the adoption of a NT system has also been confirmed by
an American Soybean Association study (ASA, 2001)
of conservation tillage. This study found that the avail-
ability of GM HT soybeans has facilitated and encour-
aged fanners to implement reduced-tillage practices; a
majority of growers surveyed indicated that GM HT
soybean technology had been the factor of greatest
influence in their adoption of RT practices.
Based on the soybean crop area planted by tillage
system, type of seed planted (GM and conventional) and
applying the fuel usage consumption rates referred to in
the methodology section,^ the total consumption of trac-
tor fuel has increased by only 2.1% (15.9 million
liters) — from 746.4 to 762.4 million liter-s (1996 to
2008) — while the area planted increased by 16.3%,
some 4.3 million ha. Over the same period, the average
fuel usage fell ,12.2% — from 28.7 liters/ha to 25.2 liters/
ha. A comparison of biotech versus conventional pro-
8. Due to the likely small-scale impact and/or lack of tillage-
specific data relating to GM HT mate and cotton crops (and
the US GM HT canola crop), analysis of possible GHG emis-
sion reductions in these crops ha\>e not been included. The no/
reduced-tillage areas to -which these soil carbon reductions
were applied were limited to the increase in the area planted
to no/reduced tillage in each countri,> since GM HT technol-
ogy’ has been commercially available. In this ira}-’ the authors
have tried to avoid attributing no/reduced-tillage soil carbon
sequestration gains to CM HT technology’ on cropping areas
that were using naaeduced-lillage cultivation techniques
before CM HT technology became available. Also, the devel-
opment of the no-tillage soybean crops have not keen attrib-
uted to the plantings of GM HT crops in Brazil due to the
rapid development of this production system before GM HT
soybean technology nw permitted in 2003.
9. Our estimates are based on the following m'eragefuel con-
sumption rales: NT II. 4 liler/ha. RT 30. 73 Utersdra (the aver-
age of fuel consumption for chisel ploughing and disking) and
conventional tillage 43. 7 liiers/ha.
Brookes & Barhot — Globallmpact of Biotech Crops: Environmental Effects, 1996-2008
152
AgBioForum, 13(1), 2010 1 81
Table 3. US soybeans: Permanent reduction in tractor fuel consumption and CO 2 emissions 1996-2008.
AnniuU rocluclion based on
1996 average (ilters/ha)
Crop area
(million ha)
Total fuel saving
(million liters)
Carbon dioxide
(miiifon kg)
1996
0,0
26.0
0.0
0,00
1997
0.5
28.3
13,7
37.71
1998
1.0
29.1
28.2
77,60
1999
1.0
29.8
30.8
84.73
2000
1.1
30.1
33.1
90.95
2001
1.4
30.0
41.7
114.63
2002
1.7
29.5
49.7
136.70
2003
2.3
29.7
67.5
185,52
2004
2.9
30.3
86.6
238.05
2005
4,2
28.9
120.4
331.18
2006
5.5
30.6
167.5
460,67
2007
3.5
25.8
90.0
247,40
2008
3.5
30.2
105,5
290.20
Total
834.7
2,295.3
Assumption: Baseline fuel usage is the 1996 level of 28.7 liters/ha
Table 4. US soybeans: Potential soil carbon sequestration
{1996 to 2008).
Total carbon sequestered
(million kg)
Ararage
(kg caiiion/haj
1996
2.640.96
101.7
1997
3,061.99
108.1
1998
3,337,46
114.5
1999
3,431.70
115.0
2000
3,482.75
115.5
2001
3.569.75
119,0
2002
3,619.85
122.5
2003
3,855,54
129.8
2004
4.148,86
137.0
2005
4.432,87
153.5
2006
5,194,42
170.0
2007
3.707.41
144.0
2008
4,348.85
144,0
duction systems shows that in 2008, the average tillage
fuel consumption on the biotech planted area was 24.3
liters/lia compared to 36.5 liters/ha for the conventional
crop (primarily because of differences in the share of
NT plantings).
The cumulative permanent reduction in tillage fuel
use in US soybeans is summarized in Table 3. This
amounted to a reduction in tillage fuel usage of 834.7
million liters, which equates to a reduction in carbon
dioxide emission of 2.295.3 million kg.
Based on the crop area planted by tillage system and
type of seed planted (biotech and conventional) and
using estimates of the soil carbon sequestered by tillage
system for com and soybeans in continuous rotation (the
NT system is assumed to store 300 kg of carbon/ha/year,
the RT system assumed to slore 100 kg carbon/ha/year,
and the CT system assumed to release 100 kg carbon/
ha/Vear).^^ our estimates of total soil carbon sequestered
are (Table 4):
• an increase of 1,707.9 million kg carbon/year
(from 2,641 million kg in 1996 to 4,349 million
kg carbon/year in 2008 due to increases in both
crop area planted and the NT soybean area);
• the average level of carbon sequestered per ha
increased by 42.3 kg carbon/ha/year (from 101.7
to 144 kg carbon/ha/year).
Cumulatively, since 1996 the increase in soil carbon
due to the increase in NT and RT in US soybean produc-
tion systems has been 10,370 million kg of carbon
which, in terms of carbon dioxide emission equates to a
saving of 38,057 million kg of carbon dioxide that
would otherwise have been released into the atmosphere
(Table 5). This estimate does not, however, take into
consideration the potential loss in carbon sequestration
that arises when some fanners return to conventional
10. The actual rate of soil carbon sequestered by tillage system is.
however dependent upon soil type, soil organic content, quan-
tity. and type of crop residue, so these estimates are indicative
averages.
Brookes & Barfoot — Global Impact of Biotech Crops: Environmental Effects, 1996-2008
153
AgBioForum, 13(1), 2010 ! 82
Table 5. US soybeans: Potential additional soil carbon sequestration attributable to NT/RT systems (1996 to 2008).
Annual increase in carbon sequestered Crap area
based on 1996 average (kg carbon/ha) (miffion ha)
Total carbon sequestered
(million kg)
Carbon dioxide
(miiiion kg)
1996
0.0
26.0
0.00
0.00
1997
6.4
28,3
181.93
667,69
1998
12.8
29.1
374.36
1,373.89
1999
13.4
29.8
398.45
1,462.32
2000
13.9
30.1
417.99
1,534.01
2001
17,4
30.0
521.04
1,912.23
2002
20.9
29.5
616.89
2,264.00
2003
28.1
29.7
835.71
3,067.05
2004
35,4
30.3
1,071.19
3,931,26
2005
51.8
28.9
1.497.10
5,494.36
2006
68.3
30.6
2.087.44
7,660.89
2007
42,3
25.8
1.089.62
3,998.89
2008
42.3
30.2
1.278.14
4,690.77
Total
10,369.86
38,057.37
Assumption: Carbon sequestration remains at the 1996 level of 101.7 kg carbon/ha/year.
Table 6. Argentine soybeans: Permanent reduction in tractor fuel consumption and reduction in CO 2 emissions.
Annual reduction based on 1996 average Croparqa
of 3S.8(i/ha> , ^
Total fuel saving
C million titers
Carbon dioxide
(million kg)
1996
0,0
5.9
0.0
0.00
1997
1,1
6.4
7.2
19.90
1998
3.4
7,0
23.6
64.93
1999
7.9
8.2
64.8
178.21
2000
10,2
10.6
107,8
296.59
2001
10.2
11.5
117,1
322.12
2002
11.3
13.0
146,7
403.50
2003
11.3
13.5
152.8
420.16
2004
11.3
14.3
162.3
446.46
2005
12.4
15.2
189.2
520.38
2008
13.4
16,2
215.7
593.11
2007
13,4
16.6
221,5
609,10
2008
13.4
17.0
227,0
624,33
Total
1,635.7
4,498.79
Note: Based on 21.07 liters/ha for NT and RT and 43.7 liters/ha
forCT
tillage and therefore should be treated as a maximuin
potential rather than an achieved level.
Argentina: Since 1996, the area planted to soybeans in
Argentina has increased by 188% (from 5.9 to 17 mil-
lion ha). Over the same period, the area planted using
NT and RT practices also increased by an estimated
672%, from 2.07 to 15.98 million ha, while the area
planted using CT decreased 73%, from 3.8 to 1.02 mil-
lion ha.
As in the United States, a key driver for the growth
in NT soybean production has been the availability of
GM HT soybean cultivars, which, in 2008, accounted
for 97.8% of the total Argentine soybean area.
Between 1996 and 2008 total fuel consumption
associated with soybean cultivation increased by an esti-
mated 169.6 million liters (80.2%), from 211.6 to 381.2
million lilers/year. However, during this period the aver-
age quantity of fuel used per ha fell 37.34% from 35.8 to
22.4 liters/ha, due predominantly to the widespread use
of GM HT soybean cultivare and NX'RT systems. If the
Bfvokes & Barfyot — Gfoba/ Impact of Biotech Crops: Environmental Effects, 1996-2008
154
AgBioForum, 13(1), 2010 | S3
Tab!o 7. Argentine soybeans: Potential additional soil caft>on sequestration (1336 to 2008).
Annua! increase In carbon sequestered
based on 1996 average (kg carboniha)
Cre^ area
(miilton ha)
Total carbon soquostored
(million kg)
Carbon dioxide
(million kg)
1336
0.0
5.9
0.0
0.00
1937
-0.9
6.4
-5.9
-21.57
1998
12.8
7.0
89.1
327.00
1999
52.8
8.2
432.0
1,585.47
2000
72.8
10.6
771.0
2,829.42
2001
72.8
11.5
837.3
3.073.07
2002
82.8
13.0
1,073.6
3,940.24
2003
82.8
13.5
1,118.0
4,102.96
2004
82-8
14.3
1,187.9
4,359.75
2005
92.8
15.2
1,410.8
5,177.47
2006
100.8
16.2
1.628.1
5,975.23
2007
100.8
16.6
1,672.0
6,136.31
2008
100.8
17.0
1713.8
6,289.71
Total
11,927.7
43,775.07
Assumption: NT= +150 kg carbon/ha/yr; CT = -100 kg carbonAia/yr.
proportion of NT/RT soybeans in 2008 (applicable to
the total 2008 area planted) had remained at the 19%
level, an additional 1,635.9 million liters of fuel would
have been used. At this level of fuel usage, an additional
4,498.79 million kg of carbon dio.xide would have oth-
erwise been released into the atmosphere (Table 6).
Applying a conservative estimate of soil carbon
retention of 150 kg/carbon/ha/yr for NT/RT soybean
cropping in Argentina (tillage data in Argentina does not
differentiate between NT and RT), a cumulative total of
1 1,927.8 million kg of carbon — which equates to a sav-
ing of 43,775.1 million kg of carbon dioxide — has been
retained in the soil that would otherwise have been
released into the atmosphere (Table 7).
Paraguay and Uruguay: NT/RT systems have also
become important in soybean production in both Para-
guay and Uruguay, where the majority of production in
both countries are reported by industry sources to use
NT/RT systems.
Using the findings and assumptions applied to
Argentina (see above), the savings in fuel consumption
for soybean production between 1996 and 2008 (associ-
ated with changes in NT/RT systems, the adoption of
GM HT technology and comparing the proportion of
NT/RT soybeans in 2008 relative to the 1996 level) has
possibly amounted to 19.5.9 million liters. At this level
of fuel saving, the reduction in the level of carbon diox-
ide released into the atmosphere has probably been
538.7 million kg. Applying the same rale of soil carbon
retention for NT/RT soybeans as Argentina, the cumula-
tive increase in soil carbon since 1996 — due to the
increase in NT/RT in Paraguay and Uruguay soybean
production systems— has been 2,163.2 million kg of
carbon. In terms of carbon dioxide emission, this
equates to a saving of 7,938.94 million kg of carbon
dioxide that may otherwise have been released into the
atmosphere.
Herbicide-tolerant Canola
The analysis presented below relates to Canada only and
does not include the US GM HT canola crop. This
reflects the lack of infomiation about the level ofNT/RT
in the US canola crop. Also, the area devoted to GM HT
canola in the United States is relatively small by com-
parison to the corresponding area In Canada (0.39 mil-
lion ha in the United States in 2008 compared to 5.4
million ha in Canada).
Since 1996 the cumulative permanent reduction in
tillage fuel use in Canadian canola is estimated at 347.5
million liters, which equates to reduction in carbon
dioxide emission of 955.39 million kg (Table 8).
In terms of the increase in soil carbon associated
with the increase in NT and RT in Canadian canola pro-
duction, the estimated values are summarized in Table 9.
The cumulative increase in soil carbon equals 3,227 mil-
lion kg of carbon, which in terms of carbon dioxide
emission equates to a saving of ! 1,842 million kg of car-
bon dioxide that would otherwise have been released
into the atmosphere.
Brookes & Barfoot — GlobaUmpact of Biotech Crops: Environmental Effects, 1996-2008
155
AgBioForum, 13(1), 2010 \ 84
Table 8. Canadian canola: Permanent reduction in tractor fuel consumption and CO 2 emissions 1996-2008.
I
Crtqtarea
(miflionba)
1996
0-0
3.5
0.0
■■{[■■■I
1997
1.6
4-9
7.9
21.63
1998
1,6
5.4
8.8
24.11
1999
1,6
5.6
9-0
24.71
2000
1.6
4,9
7,8
21-58
2001
3-2
3.8
12.2
33.62
2002
4.8
3.3
15.8
43.46
2003
6.5
4.7
30.3
83.30
2004
8.1
4.9
39.9
109.68
2005
8,1
5.5
44.3
121.93
2006
9,7
5.2
50.8
139.59
2007
9.7
5.9
57.3
157.51
2008
10.3
6.5
63.4
174.27
Total
347.5
955.39
Note: Fuel usage NT = 11.4 liters/ha; CT = 43.7 liters/ha.
Table 9. Canada canola: Potential additional soil carbon sequestration (1996 to 2008).
Annual increase In carbon sequestered
based on 1996 average (kg carbon/ha) \
Crop area
(mlilion ha)
1996
0.0
3.5
0.0
0.00
1997
15.0
4.9
73.1
268.09
1998
15,0
5.4
81,4
298.86
1999
15,0
5.6
83.5
306.31
2000
15.0
4.9
72.9
267.50
2001
30.0
3.8
113.6
416.75
2002
45.0
3.3
146,8
538.67
2003
60.0
4.7
281-4
1,032.56
2004
75.0
4.9
370.4
1,359.46
2005
75.0
5,5
411,8
1,511.40
2006
90.0
5.2
471,4
1,730.21
2007
90.0
5.9
532.0
1,952.39
2008
95.9
6.5
588.6
2,160,18
Total
3,226.9
11,842.36
Note: NT/RT = *200 kg carbon/ha/yr; CT ~ -100 kg carbonA^a/yr.
Herbicide-tolerant Cotton and Maize
The contribution to reduced levels of carbon release
arising from the adoption of GM HT maize and cotton is
likely to have been marginal, and hence no assessments
are presented. This conclusion is based on the follow-
ing.
• Although the area of NT/RT cotton has increased
significantly in countries such as the United
States, it still only represented an estimated
21%" of the total cotton crop in 2007.
As the soybean-maize rotation system is com-
monplace in the United States, the benefits of
switching to a NT system have largely been
examined above for soybeans.
No significant changes to the average number of
spray runs under a GM HT production system rel-
U. Source: Consei-vation Technology Information Center.
National Crop Residue, Management Stirx’ey (2007a, 2007b).
Brookes & Bar^t — Global Impact of Biotech Crops: Environmental Effects. 1996-2008
156
AgBioForum, 13(1), 2010 \ 85
Table 1 0. Permanent induction in global tractor fuel consumption and CO 2 emissions resulting from the cultivation of GM IR
cotton 1996-2008.
GMIRarea
(million ha)
excluding India
and China
Total spray runs
saved
imillion ha)
fe:;:
1996
7.49
0.86
3.45
3-60
9.91
1997
7.09
0.92
3.67
3-84
1998
7.24
1.05
4.20
4.39
12.08
1999
7.46
2.11
8.44
8.82
24.25
2000
7.34
2.43
9.72
10.16
27.94
2001
7.29
2.55
10.65
29.28
2002
6.36
2.18
8-71
9.10
25.04
2003
5.34
2.19
8-74
9.14
25.13
2004
6-03
2.80
11.20
11.70
32.18
2005
6.34
3.22
12.88
13.46
37.02
2006
7.90
3.94
15.75
16.46
45.27
2007
6.07
3.25
13.00
13.59
37.37
2008
4.99
2.41
9.65
10.08
27.72
Total
119.60
124.99
343.75
Note: Assumptions: 4 tractor passes per ha; 1.045 liters/ha of fuel per insecticide application.
Insect-resistant Maize
No analysis of the possible contribution to reduced level
of carbon sequestration from the adoption of GM IR
maize (via fewer insecticide spray runs) and the adop-
tion of com rootwonn (CRW) resistant maize is pre-
sented. This is because the impact of using these
technologies on carbon sequestration is likely to have
been small for the following reasons.
• In some countries (e.g., Argentina), insecticide
use for the control of pests such as the corn borer
has traditionally been negligible.
• Even in countries where insecticide use for the
control of corn-boring pests has been practiced
(e.g., the United States), the share of the total crop
treated has been fairly low (under 10% of the
crc»p) and varies by region and year according to
pest pressure.
• Nomina! application savings have occurred in
relation to the adoption of GM CRW maize where
more than 13.7 million ha were planted in 2008.
The adoption of the GM CRW may become
increasingly important with wider adoption of NT
cultivation systems due to the potential increase
in soil-borne pests.
ative to a conventional production system have
been reported.
insect-resistant Cotton
The cultivation of GM IR cotton has resulted in a signif-
icant reduction in the number of insecticide spray appli-
cations (e.g., Gianessi & Carpenter, 1999). During the
period 1996 to 2008, the global cotton area planted with
GM IR cultivars (excluding China and India)’" has
increased from 0.86 million ha to 3.94 million ha in
2006 before falling back to 2.41 million ha in 2008.
Based on a conservative estimate of four fewer insecti-
cide sprays being required for the cultivation of GM IR
cotton relative to conventional cotton and applying this
to the global area (excluding China and India) of GM IR
cotton over the period 1 996-2008 suggests that there has
been a reduction of 119.6 million ha of cotton being
sprayed. The cumulative saving in tractor fuel consump-
tion has been 124.99 million liters. This represents a
permanent reduction in carbon dioxide emissions of 344
million kg (Table 10).
12. These are excluded because all spraying in lhe.se Pro coun-
tries is assumed to be undertaken by hand.
13. This is in line with the general fall in total cotton plantings.
Brookes & Barioot — GtobaJ Impact of Biotech Crops: Environmental Effects, 1996-2008
157
AgBioForum, 13(1), 2010 | 86
Table 11. Summary of carbon soaucstratlon impact 1996-2008.
Potent!^ additional carbon
dioxide saving from fuel saving
(million kg)
US; GM HT soybeans
835
2,295
38,057
Argentina: GM HT
soybeans
1,636
4,499
43,775
Other countries: GM HT
soybeans
196
539
7,939
Canada: GM HT canola
347
955
11,842
Global GM IR cotton
125
344
0
Total
3,139
8,632
101,613
Note: Other countries: GM HT soybeans Paraguay and Uruguay (applying US carton sequestration assumptions). Brazil not
included because of NT/RT adoption largely in the absence of GM HT technology.
Discussion and Conclusions
The analysis of pesticide use changes arising from the
adoption of biotech crops shows that there have been
important environmental benefits, amounting to 352
million kg less pesticide use by growers (an 8.4% reduc-
tion in the amount of active ingredient applied). As
weight of active ingredient applied is a fairly crude mea-
sure of environmental impact, the analysis considered
impacts using an alternative (more rounded) measure,
known as the EIQ. Based on this, the environmental
benefits have been more significant at a 16.3% reduc-
tion in the environmental impact associated with insecti-
cide and herbicide use on the global crop area planted to
biotech traits (1996-2008). The most significant envi-
ronmental benefits derived have been associated with
the adoption of GM IR cotton, which has resulted in a
substantial reduction in insecticide applications on cot-
ton. There have also been important environmental
gains associated with the adoption of GM HT technol-
ogy, which has seen a switch to the use of more environ-
mentally benign active ingredients.
The analysis also shows that biotechnology trait
adoption has made important contributions to reducing
GHG emissions associated with cropping agriculture,
and a summary of the total carbon sequestration impact
of GM crops is presented in Table IT This shows that
the permanent savings in carbon dioxide emissions
(arising from reduced fuel use of 3,137 million liters of
fuel) since 1996 have been about 8,632 million kg and
the additional amount of soil carbon sequestered since
1996 has been equivalent to 101,613 million tonnes of
carbon dioxide that has not been released into the global
atmosphere.^"' The reader should, however, note that
these soil carbon savings are based on saving arising
from the rapid adoption of NT/RT farming systems in
North and South America for which the availability of
GM HT technology has been cited by many farmers as
an important facilitator. GM HT technology has there-
fore probably been an important contributor to this
increase in soil carbon sequestration but is not the only
factor of influence. Other influences, such as the avail-
ability of relatively cheap generic glyphosate (the real
price of glyphosate fell threefold between 1995 and
2000 once patent protection for the product expired),
have also been important, as illustrated by the rapid
adoption of NT/RT production systems in the Brazilian
soybean sector, largely in the absence of the GM HT
technology.'-'’ Cumulatively the amount of carbon
sequestered may be higher than these estimates due to
year-on-year benefits to soil quality; however, equally
with only an estimated 1 5-25% of the crop area in con-
tinuous NT systems, it is likely that the total cumulative
soil sequestration gains have been lower. Nevertheless,
it is not possible to estimate cumulative soil sequestra-
tion gains that take into account reversions to conven-
tional tillage because of the lack of detailed,
disaggregated farm- and field-level tillage data for the
14. JTicse estimates are based on fairly conservative assumptions
and therefore the true values could be higher. Also, some of
the additional soil carbon sequestration gains from RT/NT
systems may he lost if subsequent ploughing of the land
occurs. Estimating the possible losses that may arise from
subsequent ploughing would be complex and difficult to
undertake. This factor should be taken into account when
using the estimates pre.sented in this section of the report
15. The reader should note that the estimates of soil carbon
sequestrafion savings presented do no! include any for
beans in Brazil because we have assumed that the increase in
NT/RT area has not been primarily related to the availahiUty
of GM HT technolog}- in Brazil.
Brookes & Barfoot — Global Impact of Biotech Crops: Environmental Effects, 1996-2008
158
AgBioForum, 13(1), 2010 | 87
Tabic 12. Context of carbon sequestration impact 2008: Car equivalents.
Average femity car
equivalents rMnoved
from the roadfor a year
from the permanent
fuel savings
US: GM HT soybeans
290
129
4.691
2,085
Argentina: GM HT
soybeans
624
277
6,290
2,795
Other countries: GM
HT soybeans
82
37
1,214
539
Canada: GM HT
canola
179
80
2,223
988
Global GM IR cotton
28
12
0
0
Total
1,205
534
14,417
6,408
Note; Assumption: An average family car produces 150 grams of carbon dioxide of km. A car does an average of 15.000 km/year
and therefore produces 2,250 kg of carbon dioxide/year.
1996-2008 period. Consequently, the estimate provided
above of 101,613 million tonnes of carbon dioxide not
released into the atmosphere should be treated with cau-
tion and clearly represents a potential maximum rather
than a realized level.
Further examining the context of the carbon seques-
tration benefits, Table 12 shows the carbon dioxide
equivalent savings associated with planting of biotech
crops for the latest year (2008) in terms of the number of
car-use equivalents. This shows that in 2008, the perma-
nent carbon dioxide savings from reduced fuel use was
the equivalent of removing nearly 0.534 million cars
from the road for a year, and the additional soil carbon
sequestration gains were equivalent to removing nearly
6.4 million cars from the roads. In total, biotech crop-
related carbon dioxide emission savings in 2008 were
equal to the removal from the roads of nearly 6.9 million
cars, equal to about 26% of all registered private cars in
the United Kingdom.
The impacts identified in this article are, however,
probably conservative, reflecting the limited availability
of relevant data and conservative assumptions used. In
addition, the analysis examines only a limited number of
environmental indicators. As such, subsequent research
of the environmental impact might usefully include
additional environmental indicators such as impact on
soil erosion.
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Appendix A: Details of Methodology as Applied to 2008 Calculations of Environmental
Impact Associated with Pesticide Use Changes
Table A1. GM IR corn (targeting corn-boring pests} 2008.
Country
Area Of
trait
(‘000 ha}
Maximum area
treated for com
bOTlng pests; Prel]
GM IR {‘000 ha) 1
Average
ai useGM
crop
(kg/ha) >
Average ai
use if
conventional
(kg/ha)
Average
field EIQ/
haGM
crop
US
18,140
3,182
0.23
0-83
12,8
32.8
-1,909
-63,6
Canada
750
60,2
0.04
0.64
4.8
24.8
-36.12
-1,25
Argentina
1,150
0
0
0
0
0
0
0
Philippines
280
Very low -
assumed zero
0
0
0
0
0
0
South Africa
1,668
1,768
0
0.094
0
3.42
-156.8
-5,71
Spain
79.3
36.3
0.36
1.32
0.9
26.9
-34.9
-0.94
Uruguay
110
Assumed to be
zero: as Atpentina
0
0
0
0
0
0
Brazil
1,450
No! known
Not known
Not known
Not known
Not known
None applied
None applied
Note: Brazil: 2008 was first year of use of GM IR com technology. Insufficient data currently available to make an assessment. Other
countries: Honduras and EU countries: Areas planted to GM IR com under 10,000 ha in each country: not examined.
Brookes 8 Barfoot — Globallmpact of Biotech Crops: Environmental Effects, 1996-2008
161
AgBioForum, 13(1), 2010 | 90
Tabic A2. GM !R corn (targeting corn rootworm) 2008.
M
B
1 — ^
n^imi
iiggggi
iimgiyiii
Note: There are no Canadian-specific data available. Analysis has ffierefyre not been included for the Canadian crop of 119,000 ha
planted to seed containing GM IR traits targeted at com rootworm pests.
Table A3. GM IR cotton 2008.
v;
Average ai
Avorago al use
'Average
Average field
w
■ ■■m
use GM crop
if conventional
field EiQ/ha
ElCVha If
Country
(k<j/ha}
(kg/haj
GM crop
conventional
US
1,930
0.92
1.06
29.1
38.0
-276.6
-17.1
China
3,828
1.84
2.80
83.22
127,96
-3,675
-171.3
Australia
121.2
2,2
11.0
39
220
-1,066.9
-21.94
Mexico
70
3,6
5.22
120.4
177.0
-113.5
- 3.96
Argentina
213
0.64
1.15
21.0
53.0
-108.6
-6.82
India
6,973
1.06
1.86
34.43
70.07
-5,565.1
-248.5
Brazil
170
0.64
1.15
21-0
53.0
-86.7
-5.44
Note: Due to the widespread and regular nature ofbollwotm and budworm pest problems in cotton crops. GM IR areas planted are
assumed to be equal to the area traditionally receiving some form of conventional insecticide treatment
South Africa (7,700 ha). Burkino Faso (8,500 ha), and Columbia (28,000 ha) not included in analysis due to lack of data and small
size of plantings relative to total area of trait
Brazil: due to a lack of data, usage patterns from Argentina have been assumed.
Table A4. GM HT soybeans 2008.
Area of
Average al
Average al use :
Average
Average field
Aggregate
trait
use GM crop ff conventional
field EIQ/ha
EiQ/ha If
change in aiuse
Country
COOO ha)
(kg/ha) i
(kg/ha)
GM
conventional
( 000 kg)
US
27,790
1,63
1.62
26.29
36.16
+277.9
-274.3
Canada
880
1.32
1.43
20.88
34,20
-96.8
-11.73
Argentina
16,830
2,68
2.53
41.38
43.64
+2., 524
-38.05
Brazil
13,320
2.37
1.94
36.34
32.96
+5,705 .
+45.0
Paraguay
2,430
1.16
0.99
18,8
20.05
+413.1
-3.04
South Africa
184
1.89
1.566
28,97
32.08
+61,4
-0,57
Uruguay
569
2.68
2.53
41,38
43,64
+85.4
-1,29
Mexico
7.3
1.62
1.76
24.83
41.02
-1
-0,12
Bolivia
454
1.16
0.99
18.8
20.05
+77.11
-0.57
Note: Due to lack of country-specific data, usage patterns in Paraguay assumed for Bolivia and usage in Argentina assumed for Uru-
guay.
Brookes & Barfoat— Ghbaf Impact of Biotech Crops: Environmental Effects, 1996-2008
162
AgBioForum. 13(1), 2010 I 91
Table AS. GM HT com 2008.
Average ai use
tf conventional
(kg/ha)
Average
•cidliO hj
GM urop
Average hold
EIQ/ha if
convent lorul
Aggregate
change in ai
use ('000 kg]
pwi
US giyphosate
tolerant
18,847
2.06
43.08
77.15
-26,802
■642.0
US giufosinate
tolerant
1,203
2,04
3.48
44.76
77.15
-1.738
-39.0
Canada
giyphosate
tolerant
477
1.83
2.71
37.01
61.10
-418.9
-11.44
Canada
giufosinate
tolerant
136
1.64
2.71
36.01
61,01
-145.3
-3,41
Argentina
805
2.36
2.77
43.80
57.82
-330.0
-11.3
South Africa
646
2.754
3.103
46.17
65.87
-225.3
-12.7
Note: The Philippines is not included due to lack of data on weed-control methods and product use.
Table A6. GM HT cotton 2008.
Country
Area of
trait
(‘000 ha)
Average ai
use GM crop
(kg/ha)
Average ai use
If conventional
(kg/ha)
Average field
EIQ/haGM
crop
Aveiage field
EiO h.i if
conventional
US
2,082.8
2.83
3.26
50.6
60.08
-896
-19.74
South Africa
11.0
1.80
1.81
27.59
31.86
-0.11
-0,05
Australia
122,5
4,0
6.29
67.28
113,50
-281.4
-5.66
Argentina
210
1,80
3.48
27.60
68.04
-358.7
-8,6
Note: Mexico is not included due to lack of data on herbicide use.
Table A7. GM HT canola 2008.
Country
Area of
trait
(‘000 ha)
Average a)
use GM crop
(kgfha)
|Average field
EIQ/ha If
conventional
Aggregate
change In al
use (‘000 kg)
Aggregate change
In field EIQ/ha
units
US giyphosate
tolerant
180.1
0.649
1.12
9.95
25.71
-84.8
-2.84
US giufosinate
tolerant
200.1
0.383
1.12
7.78
25.71
-147.5
-3.59
Canada
giyphosate
tolerant
2,943
0.7
0.56
10.68
11,52
+403.2
-2,47
Canada
giufosinate
tolerant
2,681
0.35
0.56
7.07
11.52
-569.1
-11,93
Table A8. GM herbicide-tolerant sugar beet 2008.
Area of
trait
Country (‘000 ha)
Average ai
use GM crop
(kg/ha)
Average at use
if conventtonal
(kg/ha)
. Avafag*
taldEKUia..'
'' GM crap
Avongii field
aOdiair
conventional
Aggregate
change In ai
u^o ( 000 kg)
aggregate change
in field EIQ'ha
units
US
258
1.90
1.40
2913
--
-0.45
Brookes & Barfooi — GlobaUmpact of Biotech Crops: Enviror^mental Effects, 1996-2008
163
Appendix B: Examples of EIQ Calculations
Table B1 . Estimated typical herbicide regimes for conven-
tional reduced/no till soybean production systems thatwil
provide an equal level of weed control to the GM HT syst«n
in Argentina 2008.
Active ingredient
Field eiQ^a
Glyphosate
Option 1
0.864
13.25
Metsulfuron
0.03
0.50
2 4 d amine
0.3
6.21
Imazethapyr
0.08
1.57
Difiufenican
0.05
0.88
Clethodim
0.144
2.45
Total
1.468
24.85
Glyphosate
Option 2
1.35
20-70
Dicamba
0.0576
1.46
Acetochlor
1.08
21.49
haloxifop *
0.096
2.13
Sulfentrazone
0-0875
1.02
Total
2.67
46.80
Glyphosate
Option 3
1.62
24.83
Atrazine
0.384
8.79
Bentazon
0,6
11,22
2 4 db ester
0,04
0.61
Imazaquin
0.024
0-37
Total
2.67
45.83
Glyphosate
Option 4
1,8
27.59
2 4 d amine
0-384
7.95
Flumetulam
0.06
0.94
Fomesafen
0,25
6.13
Chtorimuron
0,015
0.29
Fluazifop
0.12
3.44
Total
2.63
46.34
Glyphosate
Option 5
1.8
27.59
Metsulfuron
0.05
0.84
2 4 d amine
0.75
15.53
Imazethapyr
0,1
1.96
haloxifop
0.096
2.13
Total
2.80
48.05
Glyphosate
Option 6
1.8
27,59
Metsulfuron
0,05
0,84
2 4 d amine
0.75
15.53
Imazethapyr
0,1
1.96
Clethodim
0.24
4.08
Total
2.94
49.99
Average all
2.53
43.64
Sources; AAPRESID (Argentine No-Till Farmers Association,
personal communication) and Monsanto Argentina (personal
communications, 2006, 2007, & 2009).
AgBioForum. 13(1), 2010 j 92
Table B2 GM HT soybeans Argentina 2008.
Derived from AMIS Global farm
survey market research data
—
Table 63. GM HT versus conventional corn Argentina 2008.
Conventional
Acetechior
Option 1
1.68
33,43
Atrazine
1.0
22.90
Misotrione
0.14
2-52
Total
2.82
58.85
Acetechior
Option 2
1.68
33.43
Atrazine
1.0
22.90
Foramsuiam
0.03
0.46
Total
2.71
56.79
Average
2.77
57,82
conventional
GM HT corn
Acetochlor
0,84
16.72
Atrazine
0,5
11,45
Glyphosate
1.02
15,64
Total
2.36
43.80
Sources: AMIS Global and Monsanto Argentina (personal
communication).
Brookes & Barfoot — Global Impact of Biotech Crops: Environmental Effects, 1996-2008
164
AgBioForum, 13(1), 2010 t 93
Table B4. Typical herbicide regimes for GM HT soybeans in Table 66. Typical insecticide regimes for cotton in India
South Africa.
2008.
Amount
Amount
Active Ingredient
(kg/ha of crop)
Field EIQ/ha
Active ingrodtent
(kg/ha of crop)
Field EIQ/ha
Conventional soybeans
Option 1
Conventional cotton
Option 1
Alochlor
1.536
27.49
imidacioprid
0.0356
1.31
Chlorimuron
0.01
0.19
Thiomethoxam
0.05
1.67
Total
1.546
27.69
Acetamiprid
0,05
1.44
Option 2
Diafenthiuron
0.1
2,53
S Metalochlor
1.536
33.79
Triazophos
0.5
17.80
tmazethapyr
0.07
0.78
Profenfos
0.625
37,19
Total
1.576
34.58
Acephate
0.6
14.94
Option 3
Spinosad
0,384
5.53
S Metalochlor
1.536
33.79
Metaflumizone
0.025
0.82
Chlorimuron
0.01
0.78
Flubendiamide
0.048
0.93
Total
1.546
34.58
Total
2.42
84.15
Average
1.556
32.08
Option 2
Imidacioprid
0.0356
1.31
GM HT soybeans
Thiomethoxam
0.05
1.67
Glyphosate
1.89
28.97
Acetamiprid
0.05
1.44
Source. Monsanto South Africa (personal communication).
Diafenthiuron
0-1
2,53
Table 65. Typical herbicide regimes for GM KT maize in
Canada.
Profenfos
Chloripyrifos
0.625
0.4
37.19
10.76
Active mgradiont
Amount
(kg/ha of crop)
Field ElQ/hTI
Metaflumizone
Emamectin
0,011
0.29
Conventional maize
Total
1.30
56.00
Metaiochior
1.3566
29.84
Average conventional
1.86
70,07
Atrazine
1.1912
27.28
Primsuifuron
0.0244
0.41
GM IR cotton
Dicamba
0.14
3.54
Imidacioprid
0.0356
1.31
Total
2.7122
61.07
Thiomethoxam
0.05
1.67
Acetamiprid
0.05
1.44
GM glyphosate-toierant maize
Diafenthiuron
0.1
2,53
Metalochlor
0.678
14.92
Triazophos
0,5
17.80
Atrazine
0.594
13.60
Profenfos
0.625
37.19
Glyphosate
0.56
8.58
Total
1.36
61.92
Total
1.832
37.10
Option 2
imidacioprid
0.0356
1.31
GM glufosinate-tolerant maize
Thiomethoxam
0.05
1.67
Metalochlor
0.678
14.92
Acetamiprid
0.05
1.44
Atrazine
0.594
13.60
Diafenthiuron
0.1
2,53
Glufosinate
0.37
7.49
Total
0.24
6.94
Total
1.642
36.01
Average GM IR cotton
1.06
34.43
Sources: Ontario Ministry of Agriculture, Food, and Rural
Source: Monsanto India (personal communication).
Affairs (2002), industry (personal communication with various
seed industry sources).
Brookes & Barfoot — Global Impact of Biotech Crops: Environmental Effects. 1996-2008
165
AgBioForum. 13(1). 2010 j 94
Table B7. Data sources (for pesticide usage data).
Sources of data for assumptions
US Gianessi and Carpenter (1999)
Carpenter and Gianessi (2002)
Sankula and Blumenthai (2003, 2006)
Johnson and Strom (2007)
All of the above mainly for conventional regime (based on surveys of extension advisors across the United States)
DMR Kynetec— private market research data on pestieWe usage, is the most comprehensive dataset on crop
pesticide usage at the farm ievef and allows for disaggregation to cover biotech versus conventional crops. This
source primarily used for usage on biotedi fraite.
Argentina AMIS Global-private market researdi data on pesticide use. Is the most detailed dataset on crop pesticide use.
AAPRESID (farmer producers association) — personal communication (2007)
Monsanto Argentina (persona! communication, 2005, 2007, 2009)
Qaim and De Janvry (2005)
Qaim and Traxler (2002)
Brazil AMIS Global
Galveo (2009) and personal communication
Monsanto Brazil (2008)
Monsanto Brazil (personal communication, 2007, 2009)
Uruguay As Argentina: No country-specific data identified
Paraguay As Argentina for conventional soybeans (over-the-top usage), AMIS Global for GM HT soybeans
Bolivia As Paraguay; No country-specific data identified
Canada George Morris Centre (2004)
Canola Council of Canada (2001)
Gusta. Smyth, Belcher. Phillips, and Castle (2009)
Ontario Ministry of Agriculture, Food, & Rural Affairs (2002 and updated annually)
South Africa Monsanto South Africa (personal communication, 2005. 2007. 2009)
Ismael, Bennett. Morse, and Buthelezi (2002)
Romania Brookes (2005)
Australia Doyle et ai. (2003)
Commonwealth Scientific and industrial Research Organisation (CSIRO, 2005)
Monsanto Australia (personal communication, 2005, 2007, 2009)
Spain Brookes (2003, 2008)
China Pray etal. (2002)
Monsanto China (personal communication. 2007, 2009)
Mexico Monsanto Comercial Mexico (2005, 2007, 2008)
Traxler. Godoy-Avilla, Falck-Zepeda, and Espinoza-Arellano (2001)
India Asia-Pacific Consortium on Agricultural Biotechnology (APCOA8, 2006)
IMRB International (2007)
Monsanto India (persona! communication. 2007, 2008, 2009)
Brookes & Barfoot— Global Impact of Biotech Crops: Environmental Effects, 1996-2008
166
AgBioForum, 12(2): 1S4-20B. 9)2009 AgBioForum.
Global Impact of Biotech Crops: Income and Production Effects,
1996-2007
Graham Brookes and Peter Barfoof
PG Economics, Ltd. Dorchester, UK
Introduction
This article presents the findings of research on the
global economic impact of GM crops since their com-
mercial introduction in 1 996. It updates part of the find-
ings of earlier analysis presented by the authors in
AgBioForum 8{2Sc3), P{3), and i/(l).*
The analysi.s concentrates on farm income effects
because this is a primary driver of adoption amongst
farmers (both large commercial and small-scale subsis-
tence). It also considers more indirect farm income or
non-pecuniary benefits, and quantifies the (net) produc-
tion impact of the technology.
Methodology
The report is based largely on extensive analysis of
existing fann-level impact data for biotech crops. While
primary data for impacts of commercial cultivation were
not available for every crop, in every year, and for each
country, a substantia! body of representative research
and analysis is available, and this has been used as the
basis for the analysis presented.
Since the economic performance and impact of this
technology at the farm level varies widely — both
between, and within regions/countries (as applies to any
technology used in agriculture) —the measurement of
/. Readers should note that same data presented in this article
are not directly comparable with data jrresenied in the previ-
ous three articles because the current articles takes into
account the availability ofneM- data and analysis (including
revisions to data for earlier years).
This article updates the assessment of the impact of commer-
cialized agricultural biotechnology on global agriculture from an
economic perspective. It examines specific global economic
impacts on farm income, indirect (non-pecuniary) farm-level
incwne effects and impacts on the production base of the four
main crops—soybeans, corn, cotton, and canola. The analysis
shov« that there have been substantial net economic benefits at
the farm level, amounting to $10.1 billion in 2007 and $44,1 bil-
lion for the 12-year period (in nominal terms). The non-pecuni-
ary benefits associated with the use of the technology have also
had a positive impact on adoption (in the US accounting for the
equivalent of 25% of the total direct farm income benefit). Bio-
tech crops have also made important contributions to increasing
global production levels of the four main crops — adding, for
example, 68 million tonnes and 62 million tonnes respectively to
global production of soybeans and corn.
Key words: yield, cost, income, non-pecuniary benefit,
production, biotech crops.
performance and impact is considered on a case-by-case
basis in terms of crop and trait combinations. The analy-
sis presented is based on the average performance and
impact recorded in different crops by the studies
reviewed; the average performance is the most common
way in which the identified literature has reported
impact. Where several pieces of relevant research (e.g.,
on the impact of using a GM trait on the yield of a crop
in one country in a particular year) have been identified,
the findings used have been based largely on the average
of these findings.
This approach may both overstate and understate the
real impact of GM technology for some trait, crop, and
country combinations, especially in cases where the
technology has provided yield enhancements. However,
since impact data for every trait, crop, location, and year
is not available, the authors have had to extrapolate
available impact data from identified studies to years for
which no data are available. Therefore, the authors
acknowledge that this represents a weakness in the
research. To reduce the possibilities of over/understating
impact, the analysis:
• directly applies impacts identified from the liter-
ature to the years that have been studied. As a
result, the impacts used vary in many cases
according to the findings of literature covering
different years.^ Hence, the analysis takes into
account variation in the impact of the technology
on yield according to its effectiveness in dealing
167
with (annual) fluctuations in pest and weed infes-
tation levels as identified by research;
• uses current farm-level crop prices and bases any
yield impacts on (adjusted — see below) current
average yields. In this way some degree of
dynamics has been introduced into the analysis
that would otherwise be missing if constant
prices and average yields indentified in year-spe-
cific studies had been used;
• includes some changes and updates to the impact
assumptions identified in the literature based on
consultation with local sources (analysts, indus-
try representatives) so as to better reflect prevail-
ing/changing conditions (e.g., pest and weed
pressure, cost of technology);
• includes some sensitivity analysis in which the
impacts based on average performance are sup-
plemented by a range incorporating 'below aver-
age' and ‘above average' performance
assumptions (see Appendix 2 for details); and
• adjusts downward the average base yield (in
cases where GM technology has been identified
as having delivered yield improvements) on
which the yield enhancement has been applied.
In this w'ay, the impact on total production is not
overstated.
Detailed examples of how the methodology has been
applied to the calculation of the 2007 year results are
presented in Appendix 1. Appendix 2 also provides
details of the impacts and assumptions applied and their
sources.
Other aspects of the methodology used lo estimate
the impact on direct farm income are as follows.
• Impact is quantified at the trait and crop level,
including where stacked traits are available to
farmers. Where stacked traits have been used, the
individual trait components were analyzed sepa-
rately to ensure estimates of all traits were calcu-
lated.
• All values presented are nominal for the year
shown and the base currency used is the US dol-
2. Examples M here such data is available include the impact of
GM insect-resiskmt cotton: in India, see Bennett. Ismael,
Kamhhampaii. and Morse (2004) and IMRB (2006. 2007): in
.Mexico, see Traxter. Godoy-Avtlla, Falck-Zepeda. andEspi-
noza-Arellann (2001) and Monsanto Mexico (2005. 2007):
and in the US. see Sankula and Blumenthal (2003, 2006) and
Mullins and Hudson (2004).
AgBioForum, 12(2), 2009 \ 185
lar. All financial impacts in other currencies have
been converted lo US dollars at prevailing annual
average exchange rates for each year.
• The analysis focuses on changes in farm income
in each year arising from impact of GM technol-
ogy on yields, key costs of production (notably
seed cost and crop protection expenditure, but
also impact on costs such as fuel and labor),
crop quality (e.g., improvements in quality aris-
ing from less pest damage or lower levels of
weed impurities, which result in price premia
being obtained from buyers), and the scope for
facilitating the planting of a second crop in a sea-
son (e.g., second crop soybeans in Argentina fol-
lowing wheat that would, in the absence of the
GM herbicide-tolerant [HT] seed, probably not
have been planted). Thus, the farm income effect
measured is essentially a gross margin impact
(impact on gross revenue less variable costs of
production) rather than a full net cost of produc-
tion assessment. Through the inclusion of yield
impacts and the application of actual (average)
farm prices for each year, the analysis also indi-
rectly takes into account the possible impact of
biotech crop adoption on global crop supply and
world prices.
The article also examines some of the more intangi-
ble (more difficult to quantify) economic impacts of GM
lechnology. The literature in this area is much more lim-
ited and, in terms of aiming to quantify these impacts,
largely restricted to the US-specific studies. The find-
ings of this research are summarized'^ and extrapolated
to the cumulative biotech crop planted areas in the
United States in the 1996-2007 period.
Lastly, the article includes estimates of the produc-
tion impacts of GM technology at the crop level. These
have been aggregated to provide the reader with a global
perspective of the broader production impact of the
technology. These impacts derive from the yield impacts
(where identified), but also from the facilitation of addi-
3. Impacts on these categories of cost are. however, more limited
than the impacts on seed and crop protection costs because
only a few of the papers reviewed have included consideration
of such co.sts in their analyses. Therefore, in most cases the
analysis relates to impact of crop protection and seed cost
only.
4. Notably relating to the US—Marra and Piggoft (2006).
Brookes S Barfoot — GM>sd Impact of Biotech Crops: Income and Production Effects 1996-2007
168
AgBioForum, 12(2), 2009 | 186
Table 1. Global farm income benefits from growing biotech cro|^, 1996-2007 (US $ million).
1996<2007
increase in farm
income
2007 farm income benefit ns '.o ;<f
total value of production of thosn
crops in biotech adopting countr*cs
liliMI
GM HT soybeans
3,935.5
21.814.1
7.2
6.4
GM HT maize
442.3
1.507.6
0.7
0.4
GM HT cotton
24.5
848.2
0.1
0.1
GM HT canola
345.6
1,438.6
7.65
1.4
GM IR maize
2,075-3
5,673.6
3.2
1.9
GM IR cotton
3,204.0
12.576.2
16.5
10.2
Others
54.4
208.8
n/a
n/a
Totals
10,081.6
44,067.1
6.9
4.4
Note. All values are nominal Others - Virus-resistant papaya and squash. Totals for the value shares exclude “other crops" (i.e.,
relate to the four main crops of soybeans, maize, canola, and cotton). Farm income calculations are net farm income changes after
inclusion of impacts on yield, crop quality, and key variable costs of production (e.g., payment of seed premia, impact on crop protec-
tion expenditure).
tional cropping within a season {notably in relation to
soybeans in South America). Details of how these val-
ues were calculated (for 2007) are shown in Appendix I.
Results
GM technology has had a significant positive impact on
fami income derived from a combination of enhanced
productivity and efficiency gains (Table 1). In 2007, the
direct global farm income benefit from biotech crops
was $10.1 billion. This is equivalent to having added
4.4% to the value of global production of the four main
crops of soybeans, maize, canola, and cotton. Since
1996, farm incomes have increased by S44.1 billion.
The lai^est gains in fann income have arisen in the
soybean sector, largely from cost savings. The $3.9 bil-
lion additional income generated by GM HT soybeans
in 2007 has been equivalent to adding 7.2% to the value
of the crop in biotech-growing countries, or adding the
equivalent of 6.4% to the $60 billion value of the global
soybean crop in 2007. These economic benefits should,
however be placed within the context of a significant
increase in the level of soybean production in the main
biotech-adopting countries. Since 1996, the soybean
area in the leading soybean-producing countries —
United States, Brazil, and Argentina — increased by
58%.
Substantial gains also have arisen in the cotton sec-
tor through a combination of higher yields and lower
costs. In 2007, cotton farm income levels in the biotech-
adopting countries increased by $3.2 billion, and since
1996, the sector has benefited from an additional $12.6
billion. The 2007 income gains are equivalent to adding
1 6.5% to the value of the cotton crop in these countries,
or iO.2% to the $27.5 billion value of tola! global cotton
production. This is a substantial increase in value-added
terms for two new cotton seed technologies.
Significant increases to fann incomes have also
occurred in the maize and canola sectors. The combina-
tion of GM insect-resistant (GM IR) and GM HT tech-
nology in maize has boosted farm incomes by S7.2
billion since 1996. In the North American canola sector,
an additional $ 1 .4 billion has been generated.
Table 2 summarizes farm income impacts in key bio-
tech-adopting countries. This highlights the important
farm income benefit arising from GM HT soybeans in
South America (Argentina, Brazil, Paraguay, and Uru-
guay), GM IR cotton in China and India, and a range of
GM cultivars in the United States. It also illustrates the
growing level of farm income benefits being obtained in
South Africa, the Philippines, and Mexico.
In terms of the division of the economic benefits
obtained by farmers in developing countries relative to
farmers in developed countries, Table 3 shows that in
2007, 58% of the farm income benefits were earned by
developing-country farmers. The vast majority of these
income gains for developing-countty' fanners have been
from GM IR cotton and GM HT soybeans.^ Over the
twelve years — 1996-2007 — the cumulative farm income
gain derived by developing country farmers was $22. 1
billion (50. 1% of the total).
Examining the cost farmers pay for accessing GM
technology. Table 4 shows that across the four main bio-
5. The authors acknowledge that the classiftcafion of differern
countries into developing or developed country^ status affects
the distribution of benefits between these tvo categories of
country. The definition used in this article is consistent v-ith
the definition used by James (200 7).
Brookes & Barioot — Global Impact of Biotech Crops: Income and Production Effects 1996-2007
169
AgBioForum, 12(2), 2009 | 187
Table 2. GM crop farm income benefits in selected countries, 1996-2007 ($ million).
GM HT soybeans
GM HT maize
OMHTc<^
GM HT canola
GMIR maize
GM IR cotton
Total
US
10,422
1 , 402-9
804
149.2
4 , 778.9
2 , 232.7
19 , 789-7
Argentina
7,815
46
28.6
n/a
226.8
67.9
8 , 184,3
Brazil
2,868
n/a
n/a
n/a
n/a
65.5
2 , 933.5
Paraguay
459
n/a
n/a
n/a
n/a
n/a
459
Canada
103.5
42
n/a
1,289
208.5
n/a
1,643
South Africa
3.8
5,2
0.2
n/a
354.9
19.3
383.4
China
n/a
n/a
n/a
n/a
n/a
6 , 740.8
6 , 740,8
India
n/a
n/a
n/a
n/a
n/a
3 , 181.0
3 , 181.0
Australia
n/a
n/a
5.2
n/a
n/a
190.6
195-8
Mexico
8.8
n/a
10.3
n/a
n/a
65.9
85
Philippines
n/a
11.4
n/a
rVa
33.2
n/a
44,6
Romania
92.7
n/a
n/a
n/a
n/a
n/a
92.7
Uruguay
42-4
n/a
n/a
n/a
2.7
n/a
45.1
Spain
n/a
n/a
n/a
n/a
60.0
n/a
60
Other EU
n/a
n/a
n/a
n/a
8.6
n/a
8.6
Colombia
n/a
n/a
n/a
n/a
n/a
12.6
12.6
Note. All values are nominal. Farm income calculations are net farm income changes after inclusion of impacts on yield, crop quality,
and key variable costs of production (e.g., payment of seed premia, impact on crop protection expenditure), n/a = not applicable. US
figures exclude benefits from virus-resistant crops.
Table 3. GM crop farm income benefits in developing ver-
sus developed countries, 2007 ($ million).
^ Developing
GM HT soybeans
1,375,1
2.560.5
GM IR maize
1.773.4
301.9
GM HT maize
401.6
40.8
GM IR cotton
285.8
2,918.1
GM HT cotton
16.3
8,2
GM HT canola
345.6
0
GM virus-resfstant
papaya and squash
54,4
0
Total
4,252,2
5,829.5
Note. Developing countries » all countries in South America,
Mexico. India, China, the Philippines, and South Africa.
tech crops, the total cost in 2007 was equal to 24% of
the total technology gains (inclusive of farm income
gains plus the cost of the technology payable to the seed
supply chain).^
For farmers in developing countries the total cost
was equal to 14% of total technology gains, while for
farmers in developed countries the cost was 34% of the
total technology gains. While circumstances vary
6. The cost of the technology accrues to the seed supply chain,
including sellers of seed to fanners, seed multipliers, plant
breeders, distributors, and the GM technology' providers.
between countries, the higher share of total technology
gains accounted for by farm income gains in developing
countries relative to the farm income share in developed
countries reflects factors such as weaker provision and
enforcement of intellectual property rights in develop-
ing countries and the higher average level of farm
income gain on a per-hectare basis derived by develop-
ing country farmers relative to developed country farm-
ers.
As indicated in the methodology section, the analy-
sis presented abtwe is largely based on estimates of
average impact in all years. Recognizing that pest and
weed pressure varies by region and year, additional sen-
sitivity analysis was conducted for the crop/trait combi-
nations where yield impacts were identified in the
literature. This sensitivity analysis (see Appendi.x 2 for
details) was undertaken for two levels of impact
assumption: one in which all yield effects in all years
were assumed to be Mower than average’ (levels of
impact that reflected yield impacts in years of low pest/
weed pressure), and one in which all yield effects in all
years w'ere assumed to be 'higher than average’ (levels
of impact that reflected yield impacts in years of high
pest%eed pressure). The results of this analysis suggest
a range of positive direct farm income gains in 2007 of
+$8.5 to +$12.9 billion and, over the 1996-2007 period,
a range of +S38.2 to +$52.2 billion (Table 5). This range
Brookes & Barfoot — Global Impact Biotech Crops: Income and Production Effects 1996-2007
170
AgBioForum. 12(2), 2009 j 188
Table 4. Cost of accessing GM technology relative to the total foim mcome benefits, 2007 ($ million).
'M
Total benefit of
technology to
farmers and seed
supply chain
Cost of
technology:
Developing
counmes
GM HT soybeans
3,935.5
4.866.3
326
2,560.5
2.886.5
GM IR maize
714.3
2,075.3
2,789.6
79.1
301.9
381
GM HT maize
530.8
442.3
973.1
20.2
40.8
61
GM IR cotton
670.4
3,204.0
3,874.4
535.1
2,918.1
3,453.2
GM HT cotton
226.4
24.5
8.5
8.2
16.7
GM HT canola
102.2
345.6
447.8
n/a
n/a
n/a
Total
3,174.9
10,027.2
13,202.1
968.9
5,829.5
6,798.4
Note, n/a = not applicable. Cost of accessing technology based on the seed premia paid by farmers for using GM technology relative
to its conventional equivalents. Total farm income gain excludes $54.4 million associated with virus-resistant crops in the United
States.
Table 5. Direct farm income benefits 1996-2007 under differ-
ent impact
assumptions ($
nillion).
Consistent
Average post/
weocl
Consistent
befowavorage
pressure
above average
pest/ weed
(main study
pest/weed
Crop
pressure
analysts)
pressure
Soybeans
21.796.0
21,829.0
Corn
4,571.0
7,181.2
12,152.0
Cotton
10,920
13,424.4
15.962.0
Canola
818.7
1,438.6
2.013.0
Others
101.4
208.8
224.3
Total
38,207.1
44,067.1
52,180.3
Note. No significant change to soybean production under all
three scenarios as almost all gains due to cost savings and
second crop facilitation.
is broadly within 85% to 1 20% of the main estimates of
fann income presented above.
Indirect (Non-Pecuniary) Farm-Level
impacts
In addition to the tangible and quantifiable impacts on
farm profitability presented above, there are other
important, more intangible (difficult to quantify)
impacts of an economic nature.
Many of the studies^ of the impact of biotech crops
have identified the following reasons as being important
infiuences for adoption of the technology.
For example, ix’latingto HI .wyheam. USDA (1999), Gianessi
and Carpenter (1999), and Qaim and Traxler (2002): relating to
IR maize. Rice (2004) and Brookes (2008): relating to !R cotton.
Ismael, Bennett. Morse, and Butheh'zi (2002) and Pray eta!.
( 2002 ).
Herbicide Tolerant Crops
• HT crops allow for increased management flexi-
bility and convenience that comes from a combi-
nation of the ease of u.se associated with broad-
spectrum, post-emergent herbicides like gly-
pliosate and the increased/longer time window
for spraying. This not only frees up management
time for other farming activities but also allows
additional scope for undertaking otT-farm,
income-earning activities.
• In a conventional crop, post-emergent weed con-
trol relies on herbicide applications before the
weeds and crop are well established. As a result,
the crop may suffer ‘knock-back’ to its growth
from the ettects of the herbicide. In the GM HT
crop, this problem is avoided because the crop is
both tolerant to the herbicide and spraying can
occur at a later stage when the crop is better able
to withstand any possible “knock-back” effects.
• These crops facilitate the adoption of conserva-
tion or no-tillage systems. This provides for
additional cost savings such as reduced labor and
fuel costs associated with plowing, additional
moisture retention, and reductions in soil erosion
levels.
• Improved weed control has contributed to
reduced harvesting costs — cleaner crops have
resulted in reduced times for harvesting. It has
also improved harvest quality and led to higher
levels of quality price bonuses in some regions
and years (e.g., HT soybeans and HT canola in
the early years of adoption, respectively, in
Romania and Canada).
• Elimination of potential damage caused by soil-
incorporated residual herbicides in follow-on
Brookes & Barfoot — Global !mpad of Biotech Crops: Income and Production Effects 1996-2007
171
crops and less need to apply herbicides in a fol-
low-on crop because of the improved levels of
weed control;
• HT crops also contribute to a general improve-
ment in human safety (as manifest in ^eater
peace of mind about own and worker safety)
from reduced exposure to herbicides and a
switch to more environmentally benign products.
Insect Resistant Crops
• IR crops offer benefits in the areas of production
risk management and insurance. The technology-
takes away much of the worry of significant pest
damage occurring and is, therefore, highly val-
ued. Although not applicable in 2007 (piloted in
2008 and likely to be more widely operational
from 2009), US fanners using stacked com traits
(containing IR and HT traits) are being offered
discounts on crop insurance premiums equal to
S7.41 /hectare.
• These crops have a ‘convenience’ benefit
derived from having to devote less time to crop
walking and/or applying insecticides.
• IR crops offer savings in energy use — mainly
associated with less use of aerial spraying and
less tillage.
• Planting IR crops can produce savings in
machinery use (for spraying and possibly
reduced harvesting times).
• IR crops produce a higher quality of crop. There
is a growing body of research evidence relating
to the superior quality of GM IR com relative to
conventional and organic corn from the perspec-
tive of having lower levels of mycotoxlns. Evi-
dence from Europe (as summarized in Brookes
[2008]) has shown a consistent pattern in which
GM IR com exhibits significantly reduced levels
of mycotoxins compared to conventional and
oiganic alternatives. In temis of revenue from
sales of corn, however, no premia for delivering
product with lower levels of mycotoxins have
been reported to date; however, where the adop-
tion of the technology has resulted in reduced
frequency of crops falling to meet maximum per-
missible fumonisin levels in grain maize (e.g., in
Spain), this delivers an important economic gain
to fanners selling their grain to the food-using
sector. In one study (Yorobe, 2004), GM IR com
farmers in the Philippines have also been
reported to have obtained price premia of 10%
AgBioForum, 12(2), 2009 \ 189
relative to conventional corn because of better
quality, less damage to cobs, and lower levels of
impurities.
• They also offer improved health and safety for
farmers and fann workers — from reduced han-
dling and use of pesticides, especially in devel-
oping countries where many apply pesticides
with little or no use of protective clothing and
equipment.
• Shorter growing seasons (e.g., for some cotton
growers in India) allow some farmers to plant a
second crop in the same season.^ Also, some
Indian cotton growers have reported benefits for
bee keepers, as fewer bees are now lost to insec-
ticide spraying.
Some of the economic impact studies have
attempted to quantify some of these benefits. For exam-
ple, Qaim and Traxler (2002) quantified some of these
in Argentina— a $3.65/hectare saving (-7.8%) in labor
costs and a $6.82/ha (-28%) saving in machinery/fuel
costs associated with the adoption of GM HT soybeans.
Where identified, these cost savings have been included
in the analysis presented above. Nevertheless, it is
important to recognize that these largely intangible ben-
efits are considered by many farmers as a primary rea-
son for adoption of GM technology, and in some cases
farmers have been willing to adopt for these reasons
alone, even when the measurable impacts on yield and
direct costs of production suggest marginal or no direct
economic gain.
Since the early 2000s, a number of farmer-survey-
based studies in the United States have also attempted to
better quantify these non-pecuniary benefits. These
studies have usually employed contingent valuation
techniques*^ to obtain farmer valuations of non-pecuni-
ary benefits.
• A 2002 survey of 600 US com farmers explored
opinions and valuations of the then new IR com
trait resistant to com rootwoim, which was intro-
duced in the following year (2003). Respondents
were asked to value any potential lime and
equipment savings, additional farmer and worker
8. Nolably maize in India.
9. Survey-based method of obtaining valuations of non-market
goods that aim to identify willingness to pay’ for specific
goods (e.g.. environmental goods, j.yeace of mind, etc.) or will-
ingness to pay to avoid something being tost.
Brookes & Barfyot — Gfc^aflmpact of Biotech Crops: income and Production Effects 1996-2007
172
safety, additiona! environmental benefits, and
production risk management benefits (irom more
consistent control of rootwomi) that diey thought
might arise from use of the technology relative to
existing corn rootwonn control methods. Hie
production risk management benefit was mostly
highly valued by farmers, followed by operator/
worker safety and environmental gains. TTie
average value of all the non-pecuniary benefits
was $ 17.89/hectare for likely adopters, $9.54/
hectare for unlikely adopters, and an overall
average of $16.33/liectare across all farmers sur-
veyed.
• A 2002 survey of 610 US soybean farmers
sought farmers' views on the benefits associated
with their use (since 1996) of GM HT soybeans.
Respondents were asked to value additional
farmer and worker safety, the environmental
impact of the technology and the additional con-
venience and flexibility the technology provided
for weed control relative to the conventional
alternatives. All of these benefits were valued by
the soybean farmers, with convenience given the
highest value. Overall, the average benefit attrib-
uted to these three categories of non-pecuniary
benefits was $27/hectare (58% of which came
from the convenience benefit).
• A 2003 survey of nearly 300 farmers of GM HT
crops (soybeans, corn, and cotton) asked respon-
dents to value additional farmer and worker
safety, the environmental impact of the technol-
ogy, and the additional convenience and flexibil-
ity the technology provided for weed control
relative to the conventional alternatives. Results
obtained were similar to those in the 2002 soy-
bean fanner survey referred to above. In terms of
valuations, the average benefit attributed to these
three categories of non-pecuniary benefits were,
respectively, $32/hectare for HT com farmers,
$35. 70/hectare for HT soybean farmers, and
$39.40,''heclare for HT cotton farmers.
The values for non-pecuniary benefits identified in
these surv'eys are, however, usually subject to bi^ due
to factors such as the hypothetical nature of the contin-
gent valuation technique, the framing of questions, and
what is referred to as part-whole bias.^^ Marra and Pig-
gotl (2006) examined bias (notably part-whole bias) in
the three surveys referred to above and found most
respondents tended to overstate the value of parts by
more than 60% compared with the separately stated
AgBioForum, 12(2). 2009 I 190
Table 6. Re-scaled values of non-pecuniary benefits.
Survey
Median value ($/hectare)
2(H)2 fR {to rootworm) com
growers survey
7.41
2002 soybean (HT) farmers
survey
12.35
2003 HT cropping survey
{com, cotton & soybeans) —
North Carolina
24.71
2006 HT (flex) cotton survey
12.35 (relative to first
generation HT cotton)
Source: Marra and Piggot (2006. 2007).
total values for all non-pecuniary benefits. They subse-
quently rescaled’* the sum of the values given by
respondents to each separate non-pecuniary benefit and
identified revised average (median) values for the non-
pecuniary benefits in each sur\'ey (Table 6). This sug-
gests that US formers who make widespread use of bio-
tech HT traits value the non-pecuniary benefits of the
technology at between $ 12.35/hectare and $24. 71/hect-
are, with cotton farmers valuing the non-pecuniar>'
aspects highest and com farmers having the lowest valu-
ation. In terms of attributes most valued, convenience is
perceived to provide between 50% and 66% of the total
non-pecuniary benefit of the HT technology. It is also
interesting to note that the most recent survey of cotton
farmers using HT (flex) technology have valued this
technology as delivering an additional S 12/hectare in
ttemis of benefit from extra convenience relative to the
first generation of biotech HT cotton technology. Com
producers value the non-pecuniary benefits of the IR
((rootworm resistance) technology at about $7.40/hect-
are, of which the risk reduction component accounted
for the largest single share (about a third).
Aggregating the Impact to US Crops 1996-2007
The approach used to estimate the non-pecuniary bene-
fits derived by US farmers from biotech crops over the
period 1996-2007 has been to draw on the re-scaled val-
ues identifed by Marra and Piggot (2006, 2007, Table 6)
and to apply these to the biotech-crop planted areas dur-
ing this ! 2-year period. Figure 1 summarizes the values
for non-pecuniary benefits derived from biotech crops
JO. In tfte case of non-pecuniary- benefit.^, the sum of values given
by farmers to individual categories of benefit is greater than
their stated total value of all non-pecuniaty benefits (farmers
being asked to value each type of benefit separately in addi-
tion to separately valuing total non-pecuniaiy benefits).
II. See Marra and Piggotf (2006).
Brookes & Barfoot— Global Impact of Bk^h Crops: Income and Production Effects 1996-2007
173
AgBioForum, 12(2), 2009 | 191
HT soy iRcorn HTCom IR cotton HT cotton HT canola IRCRW
I »2007 *Cumuiativ8
Figure 1. Non-pecuniary benefits derived by US farmers by trait, 1996-2007 ($ million).
in the United States (1 996-2007) and shows an esti-
mated (nominal value) benefit of $792 million in 2007
and a cumulative total benefit (1996-2007) of $5.11 bil-
lion. Relative to the value of direct farm income benefits
presented above, the non-pecuniary benefits were equal
to 21% of the total direct income benefits in 2007 and
25% of the total cumulative (1996-2007) direct farm
income. This highlights the important contribution this
category of benefit has had on biotech trait adoption lev-
els in the United States, especially w'here the direct farm
income benefits have been identfied to be relatively
small (e.g., HT cotton).
Estimating the Impact in Other Countries
It is evident from the literature review that GM technol-
ogy-using fanners in other countries also value the tech-
nology for a variety of non-pecuniary/intangiblc
reasons. The most appropriate methodology for identi-
fying these non-pecuniary benefit valuations in other
countries would be to repeat the type of US farmer sur-
veys in other countries. Unfortunately, the authors are
not aw^e of any such studies undertaken to date.
Production Effects of the Technology
Based on the yield assumptions used in the direct farm
income benefit calculations presented above (see
Appendix 1 ) and taking into account the second soybean
crop facilitation in South America, biotech crops have
added important volumes to global production of com,
cotton, canola, and soybeans since 1996 (Table 7).
Table 7. Additional crop production arising from positive
yield effects of biotech crops.
-199&^20O7 additional
production (million
tonnst)
2007 additional
production (million
tonnes)
Soybeans
67,80
14.46
Corn
62.42
15.08
Cotton
6.85
2.01
Canola
4.44
0.54
The biotech IR traits — used in the corn and cotton
sectors — have accounted for 99% of the additional com
production and almost all of the additional cotton prod-
dduction. Positive yield impacts from the use of this
technology have occurred in all user countries (except
GM IR cotton in Australia)*^ when compared to average
yields derived from crops using conventional technol-
ogy (such as application of insecticides and seed treat-
ments). Since, 1996 the average yield impact across the
total area planted to these traits over the 12 year period
has been +6.1% for com traits and +13.4% for cotton
traits (Figure 2).
Although the primary Impact of biotech HT technol-
ogy has been to provide more cost-effective (less expen-
sive) and easier weed control— versus improving yields
12. This reflects the levels of Heliothis pest control previously
obtained with intensive insecticide use. The main benefit and
reason for adoption of this technolog)- in .Australia has arisen
firm significant ajst sa\’ings (on insecticides) and the associ-
ated environmental gains from reduced insecticide use.
Brookes & Barktoi — Global Impact of Biotech Crops: Income and Production Effects 1996-2007
174
AgBioForum, 12(2), 2009 1 192
»1RCB »IRCRW mR Cotton
Figure 2. Average yield impact of biotech IR traits by country and trait. 1996-2007.
Note. IRCB = resistant to corn-boring pests. IRCRW ~ resistant to com rootworm.
Table 8. Additional crop production arising from positive
yield effects of biotech crops under different pestAveed
pressure assumptions and impacts of the technology, 1996-
2007 (million tonnes).
Crop
Consistont
below average
pesthweed
pressure
Average pest/
: weed pressure
(main study
analysis)
Consistent
above average
pest/weed S
pressure
Com
46.0
62,42
109,5
Cotton
4.61
6,86
9,03
Canola
2.09
4,44
6,26
Note. No significant change to soybean production under all
three scenarios as 99% of production gain due to second crop-
ping facilitation of the technology
from better weed control (relative to weed control
obtained from conventional technology) — improved
weed control has, nevertheless occurred, delivering
higher yields in some countries. Specifically, HT soy-
beans in Romania improved the average yield by more
than 30%, and biotech HT com in Argentina and the
Philippines delivered yield improvements of +9% and
+ 15%, respectively.
Biotech HT soybeans have also facilitated the adop-
tion of no-tillage production systems, shortening the
production cycle. This advantage enables many farmers
in South America to plant a crop of soybeans immedi-
ately after a wheat crop in the same growing season.
This second crop, additional to traditional soybean pro-
duction, has added 67,5 million tonnes to soybean pro-
duction in Afgentina and Paraguay between 1996 and
2006 — accounting for 99% of the total biotech-related
additional soybean production.
Using the same sensitivity analysis as applied to the
farm income estimates presented above to the produc-
tion impacts (one scenario of consistent lower-than-
average pest/weed pressure and one of consistent
higher-lhan-average pesl/weed pressure), Table 8.
Concluding Comments
This study quantified tlie cumulative global impact of
GM technology between 1996 and 2007 on farm income
and production. The analysis shows that there have been
substantial direct economic benefits at the farm level,
amounting to a cumulative total of $44.1 billion; half of
this has been derived by farmers in developing coun-
tries. Important non-pecuniary benefits have also been
derived by many farmers, which in the case of US farm-
ers added a further $5.1 billion to the farm income bene-
fits derived from the technology. GM technology has
also resulted in additional production of important
crops, equal to an extra 68 million tonnes of .soybeans
and 62 million tonnes of com (1996-2007).
The impacts identified are based on estimates of
average impact, reflecting the limitations of the method-
ologies used and the limited availability of relevant data.
Brookes & Barfoot — Global Impact of Biotech Crops: Income and Production Effects 1996-2007
175
Applying alternative assumptions that reflect the
extremes of low weed and pest pressure in all years and
high weed and pest pressure in all years suggests that
the impact on farm income probably falls w'ithin a range
of -15% to +20% around the cumulative estimate of
S44.1 billion referred to above. Subsequent research at
the trait- and country-level might usefully extend this
analysis to incorporate more sophisticated consideration
of dynamic economic impacts and broader (outside the
United States) examination of the less tangible (non-
pecuniary) economic impacts.
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Brookes & Barfoot — Global Impact of Biotech Crops: Income and Production Effects 1996-2007
177
AgBioForum, 12(2). 2009 | 195
Appendix 1: Details of Methodology as Applied to 2007 Farm Income Calculations
Table A1. GM IR corn (targeting corn boring peste), 2007.
s
Yield
.ir,r.iimption
% Change
Base yield
(tonnes/
ha)
Fann.
level
price
($/
tonne)
Cost of
technology
{$/ha)
Impact on
costs, net
of cost of
technology
($/ha)
E
•SSiv'ai” ■
United States
18,561
+5
9.25
135.4
-17.3
-1.42
61.22
+1,136,212
Canada
831
+5
8.29
165.44
-19.3
+1.68
+70.26
+58,382
+344,4
Argentina
2,509
+5.5
6-8
113.0
-19.9
-19,9
+22.41
+56,220
+938.4
Philippines
194
+24.15
2-52
215.12
-36.2
-22.14
+ 108.78
+21,091
+118
South Africa
1,234
+ 15
4-0
304.47
-16.19
-2.29
+180,39
+222,601
Spain
75.1
+10
9-34
283.77
-47.75
+9.55
+274.59
+20,634
+70.2
Uruguay
105
+5.5
5.61
125
-19.9
-19.9
+ 18.63
+1,956.6
+32.4
France
22.1
+ 10
9.4
256.48
-54.57
+13.64
+254,73
+5,638.5
+20.8
Germany
2.7
+4
9.09
285.13
-54,57
+13.64
+117.32
+315
+ 1
Portugal
4.3
+ 12-5
5-51
278.31
-47.75
-47.75
+143.95
+613.6
+2.9
Czech Republic
5
+10
5-75
294.68
-47.75
-23.19
+146,25
+713.2
+2.9
Slovakia
0.9
+12.3
4.28
285.13
47.75
47,75
+102.35
+97.1
+0.5
Poland
+12.5
5.28
259-21
47.75
47.75
+123.33
+40
Romania
0.3
+7.1
3.50
315.14
43.66
+ 12
Note. Impact on costs net of cost of technology - cost savings from reductions in pesticide costs, labor use, fuel use, etc., from
which the additional cost (premium) of the technology has been deducted. For example (above), US cost savings from reduced
expenditure on insecticides, etc. = -^SIS.SB/ha, from which cost of technology (-$17. S/ha) is deducted to leave a net impact of costs
0f-$1.42.
There are no Canadian-specific studies available, so we have applied US study findings to the Canadian context (since it is the
nearest country for which relevant data is available).
Table A2. GM IR corn (targeting corn rootworm), 2007.
Area of
YiekI
Farm
level Cost of '
Impacton
costs, nel of
^ cost of
Change
in farm
Change >n
farm incomo
at national
Production
impact
trait
assumption
price V technology
technology
income
level
Country
(‘000 ha)
% change
{fOA/W^)
($/tonne)
($/ha)
($/ha)
($/ha)
(‘000 5)
US
8.417.6
+5
9.25
135.4
-35
+2.47
+65.10
+547,991
+3,893.2
Canada
39,3
+5
8.29
165.44
-35
+2.47
+71.04
+2,788.7
+16.3
Note. There are no Canadian-specific studies available, hence application of US study fndings to the Canadian context (since it is
the nearest country for which relevant data is available).
Brookes & Barfoot — Global Impact of Biotech Crops: Income and Production Effects 1 996-2007
178
AgBioForum, 12(2). 2009 I 196
Table A3. GM IR cotton, 2007.
Base yield
(tonnes/ha)
Impact on
Farni costs, net
lev^ Cost of of cost ct
price technology technology
tonnes) ($/ha) ((/ha)
Change
in farm
income
(S/ha)
Change in
farm income
at national
level (‘000 $)
Production
Impact
(‘000
tonnes)
US
2.585.2
+ 10
0.93
1,202
-46.95
-5.77
+ 106.02
+274,078
+240.4
China
3,800
+10
1.18
807.4
-48.07
+152.48
+248.08
+942,695
+449.9
South Africa
9.9
+24
0.692
1,172.0
-49.43
-31 .23
+ 163.42
+1,617.8
+1.6
Australia
55.3
0
1.91
1,458
-251.3
+212.0
+212.09
+ 11,734.3
0
Mexico
60.0
+9.28
1.18
1088.7
-70.41
+20.49
+139.71
+8,382.1
+6.6
Argentina
162.3
+30
0.418
1.455
-37.85
-21.17
+ 161.31
+26,180.8
+20.3
India
5,868
+50
0.43
1,536.9
-55.29
-8.86
+321.57
+1,886,986
+1,261,6
Colombia
20,0
+9.28
0.95
1,900
-70.41
+20.49
+ 187.99
+3.749.8
+1,8
Brazil
358
+6,23
1.32
1,316.6
-43.94
+71.21
+ 135.54
+48,524
+29.4
Table A4. GM HT soybeans, 2007 (excluding second crop soybeans— see separate table).
Area of
Ytokl
Base
yield
r arm
Cost of
Imi^ctoii
cc s b net
of cost ol
Change in
farm
Chiinge m
farm income
Production
inipjLi
trait
issum^ion (tonnes/
level prirn technology technology
income
at national
(000
Country
{‘000 ha)
rhanga
ha)
(Vtonnes).
(Wha)
(S.IU)
($<ha}
level (‘000 $\
tonnes)
US
23.433.5
0
2,77
331
'24.71
+57.96
+57,96
+1,358.206.4
0
Canada
688
0
2.3
395
-37.47
+24.52
+24.52
+16,871.2
0
Argentina
16,419.5
0
2.83
221.7
-2.5
+26.11
+29.23
+480.012.1
0
Brazil
13,662.5
0
2,85
282.4
-18.77
+57.2
+61.2
+830,022.6
0
Paraguay
2,600
0
2.41
261.3
-9,64
+18.97
+22,11
+57,476.6
0
South Africa
144
0
1.12
356.6
-27.94
+5.01
+5.01
+722,1
0
Uruguay
443.5
0
2.19
256.1
-2.5
+26.11
+28,9
+12,819,2
0
Mexico
5
+9.1
1,48
360
-34.5
+120
+168,48
+842
+0.7
Romania
0
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
Note. Quelity premium for cleaner crops assumed at 0.5% of base price (price shown is inclusive of premium) in South American
countries.
Romania— n/a = not applicable, as no longer permitted to plant GM HT soybeans on entry into the EU.
Brookes & Barfbot — Globalimpact of Biotech Crops: Income and Production Effects 1996-2007
179
AgBioForum. 12(2). 2009 | 197
Table A5. GM HT corn, 2007.
n
1
Base yield
(totme^ha)
Farm
levef
price
($rtonne)
Impfict on
costs, net
Cost of of cost of
technology technology
($ma) ($/ha)
Change
in farm
income
($/ha)
I
Production
impact
{‘000
tonnes)
US
19,697.3
0%
135
-24.71
+19.89
+19.89
+391,779.1
0
Canada
751
0%
8.51
165.44
-31.8
+13.01
+13,01
+9,771,3
0
Argentina
369
+3% com belt
+22%
marginal
regions
7.68 corn bell
4.31 marginal
areas
113
-19.9
0
+26.1
corn belt
+107.43
marginal
regions
+27,637.1
+244.1
South
Africa
453
0%
4.29
304.47
-17.19
+6.02
+2,725.8
0
Philippines
191.3
+15
2.52
215.12
-26.69
-26.69
+54.47
+72.2
Note. Where no positive yield effect due to this technology is applied, the base yields shown are the indicative average yields for the
crops and differ (are higher) than those used for the GM IR base yield analysis, which have been adjusted downwards to reflect the
impact of the yield enhancing technology (see below).
Argentina: com belt assumed to account for 70% of trait plantings and marginal regions to the balance.
Table A6. GM HT cotton. 2007.
mm
Impart on
Change iii
Farm
costs nut
Change
farm income
Pfoduaioii
Area of
Yield
Base yield
, level
Cost of
of cost of
in farm
.It national
impact
trait
assumption
(tortnos/
' price
technology
tnctinology
income
Ipvcl
(000
Country
(‘000 ha)
% change
ha)
($/tonne)
($/ha) ^ {ilha)
CMOS)
tonnosl
US
3.067,1
0
0.985
1.202
-70-35
+5.2
+5.2
+15,949
0
South Africa
9.7
0
0,8
1,172
-23.6
-22.9
-0.72
-7
0
Australia
50.5
0
1.91
1,458
-42.71
+7.54
+7,54
+380.4
0
Argentina
124
Farm saved
0,453
1,455
-39,86
-17.67
+99,57
-3,876.5
+2.0
seed area
certified
certified
certified
0%
seed
seed
seed
Certified
-8 faim
+14.19 farm
+14.19
seed area
saved seed
saved seed
farm
+ 17.4%
saved
seed
Mexico
50
+3.6
1,208
1.089
-66.4
+39.67
+87,02
+4,350.8
+2.2
Note. Where no positive yield effect due to this technology is applied, the base yields shown are the indicative average yields for the
crops and differ (are higher) than those used for the GM IR base yield analysis, which have been adjusted downwards to reflect the
impact of the yield enhancing technology (see below).
Argentina: 20% of area assumed to use certified seed with 80% farm-saved seed.
Brookes & Barfoot
Global Impact of Biotech Crops: Income and Production Effects 1996-200'/
180
AgBioFomm, 12(2), 2009 \ 198
Table A7. GM HT canola, 2007.
Impact on
Farm costs, net
Yh'lif Bjseyietd level ' Cost of of cost of
asbumpticii (tonnes.* price technology technology
‘v 1 M.ingr* ha) (%Honnes) ($/ha) (S/ha)
1
M
USglyphosate 271.9
tolerant
+4
1.65
359.36
-12.36
+27.73
+51.45
+13.990.1
+5.2
USglufosinate 182.9
tolerant
+ 10
1,65
359-36
-12.36
+22.28
+81,57
+14,918.4
+8.7
Canada
glyphosate
tolerant
2,840.9
+4
1,41
508.27
-34.01
+6.82
+35,49
+100,823.3
+160.2
Canada
glufosinate
tolerant
2,588-4
+ 10
1.41
508.27
0
+11.72
+83.38
+215,830.1
+365,0
Note. Baseline (conventional) comparison in Canada with HT (non GM) ‘Clearheld’ varieties
Table A8. GM virus-resistant crops.
Country
Yield
Area of a<)siimpt)on
trait (ha) % change
Bci^e yield
(tonnes/
ha)
Firm
IuaI Cost of
prtcp tcchnoloQV
{$/tonriPt ($/ho)
Impact on
costs net of Ch inge in
cost of f tnii
tochnoloqy income
(S/ha) tS'ha)
JL.*.,.’
US papaya
778
+15
22.86
864-36
-148
-148
+2,816.1
+2,190
+2.7
US squash
3002
+100
31.4
566.90
-398
-398 +17,402.9
+52,252,3
+94.3
Second Soybean Crop Benefits: Argentina
An additional fann income benefit that many Argentine
soybean growers have derived comes from the addi-
tional scope for second cropping of soybeans. This has
arisen because of the simplicity, ease, and weed manage-
ment flexibility provided by the (GM) technology which
has been an important factor facilitating the use of no-
and reduced-tillage production systems. In turn, the
adoption of low/no-li!lage production systems has
reduced the time required for harvesting and drilling
subsequent crops and, hence, has enabled many Argen-
tine farmers to cultivate two crops (wheal followed by
soybeans) in one season. As such, the proportion of soy-
bean production in Argentina using no- or low-tillage
methods has increased from 34% in 1996 to 90% by
2005. Also, 30% of the total Argentine soybean crop
was second crop in 2007, compared to 8% in 1996.
Based on the additional gross margin income derived
from second crop soybeans (see below), this has contrib-
uted a further boost to national soybean farm income of
$l.i billion in 2007 and $4.4 billion cumulatively since
1996.
Base Yields Used Where GM Technology
Delivers a Positive Yield Gain
In order to avoid over-stating the positive yield
effect of GM technology (where studies have identified
such an impact) when applied at a national level, aver-
age (national level) yields used have been adjusted
downwards (see example in Table AlO). Production lev-
els based on these adjusted levels were then cross
checked with total production values based on reported
average yields across the total crop.
Brookes & Barfyot — Gk^ai Impact of Biotech Crops: Income and Production Effects 1996~2007
181
AgBioForum, 12(2), 2009 1 199
Table A9. Farm-leve! income impact of using GM HT soybeans in Argentina, 1996-2007 (2): Second crop soybeans.
Second crop area
(mittion ha)
Average gr(»s ib|i9rgin/ha for
second crop s^beans ($/ha)
1996
0.45
128.78
Negligible
1997
0,65
127.20
25.4
1998
0.8
125.24
43.8
1999
1.4
122.76
116.6
2000
1,6
125.38
144.2
2001
2.4
124.00
272.8
2002
2.7
143.32
372.6
2003
2.8
151.33
416.1
2004
3.0
226.04
678,1
2005
2.3
228.99
526.7
2006
3.2
218.40
698.9
2007
4.94
229.36
1,133.6
Note. Crop areas and gross margin data based on data supplied by Grupo CEO (no data available before 2000, hence 2001 data
applied to earlier years but adjusted, based on GDP deflator rates).
The second cropping benefits are based on the gross margin derived from second crop soybeans multiplied by the total area of sec-
ond crop soybeans (less an assumed area of second crop soybeans that equals the second crop area in 1 996— this was discontin-
ued from 2004 because of the importance farmers attach to the GM HT system in facilitating them remaining in no-tillage production
systems).
Table A10. Example: GM IR cotton (2007).
Average
Adjusted
yieidacross
Totaf
^ Total
^ Assumed
base yield
GMIR
ail forms of
cotton
'production
GMIR
Conventional yield effect
for
vr,.' r';
production
area
(‘000
area
''"'...''area
ofGM iR
conventional
Country
(tfha)
('000 ha)
tonnes)
(*000 ha)
(‘000 ha)
technology
cotton it/ha)
United
States
0,985
4.381,6
4.315,9
2,585.2
1,796.5
+10%
0.93
2,644.7
1,670.7
China
1,257
6,200,0
7.793,4
3,800.0
2,400.0
+10%
1.184
4,949.1
2.841.6
Note. Figures subject to rounding.
Brookes & Barfoot — GIdsal Impact of Biotech Crops: Income and Production Effects 1996-2007
182
AgBioForum, 12(2}, 2009 | 200
Appendix 2: Impacts, Assumptions, Rationale, and Sources for All Trait/Country
Combinations
Table 1. IR corn (resistant to corn-boring pests).
mm
-mi-
Sensitivity
analysis
Cost of
.
applied to
technology
assump.
yiekt
data/
premium)
used
Rationale
Yteid references
assump.
assump.
assump.
Cost references
GM IR corn resistant to corn
boring pests
US&
+5% ai!
Broad
Carpenter and Gianessi (2002)
+3% to +9%
1996 &
Ail years to
The same
Canada
years
average of
found yield impacts of +9,4% in
1997: $25
2004;
reference
impact
1997, +3% in 1998. +2.5% in 1999
$15.50
sources as yield
identified from
Marra et al. (2002) average impact
1998 &
were used.
several
of +5.04% 1997-2000 based a
1999: $20
2005
Industry sources
studies/
review of five studies. James (2003)
onwards;
also confirmed
papers
average impact of +5.2% 1996-
2000-2004:
$15.90
costs of
2002, Sankula and Blumenthal
$22
technology and
(2003, 2006} rarrge of +3. 1 % to
estimated cost-
+9.9%
2005 &
saving values for
Canada— no studies identified —as
onwards;
Canada.
US — impjaefs qualitatively confirmed
by industry sources (personal
communication, 2005, 2007).
$17
Argentina
+9% all
Average of
James (2003) cites two unpublished
+5% ait
Same as US
None, as
Cost of
years to
reported
industry survey reports; one for
years to
to 2005 then
maize crops
technology
2004 +5.5%
impacts in first
1996-1999 showing an average
+9% alt
60 Pesos
not
drawn from Trigo
2005
seven years,
yield gain of + 10 % and one for
years
2006
traditionally
et ai, (2002) and
onwards
later revised
2000-2003 showing a yield gain of
onwards
treated with
Trigo and Cap
downwards
+8%. Tiigo, Chudnovsky, Cap, and
insecticides
(2006), i,e„
for more
Lopez (2002), Trigo and Cap (2006)
for corn
costed/priced at
recent years
+10%. Trigo (personal
boring pest
same level as
to reflect
communication. 2007. 2008)
damage
US (Trigo,
professional
estimates average yield impact
personal
opinion
since 2005 to be lower at between
communication.
+5% and +6%.
2007, 2008).
Philippines
+24,6% ail
Average of
Gonsalves (2005) found average
All years
All years;
All years:
Based on
years
three studies
yield impact of +23% dry season
+14% to
1,673 Pesos
651 Pesos
Gonsalves
used all years
crops and +20% wet season crops;
+34%
(2005)— the only
source to break
Yorobe (2004) +38% dry season
down these
crops and +35% wet season crops;
costs. For 2006
and 2007, this
Ramon (2005) found +15.3% dry
level of cost and
season crof^ and +13.3% wet
average cost
season crops.
savings were
confirmed by
industry sources.
South
2000-2001;
Reported
Gouse, Pray. Kirsten, and
+5% to
(In Rand)
Alt years 97
Based on the
Africa
+11%
average
Schimmelpfenning (2005), Gouse,
+32% all
2000 &
Rand
same papers as
2002: +32%
impacts used
Piesse. and Thirtie (2006), and
years
2001: 84
used for yield.
2003: +16%
for years
Gouse, Pray, Sctiimmelpfenning,
2002: 90
plus confirmation
2004: +5%
availabie
and Kirelen (2006) reported yield
2004 &
in 2006 and 2007
2005
(2000-2004),
impacts as shown (range of +11% to
2005: 94
that these are
onwards:
2005 onwards
+32%).
2006 and
representative
+15%
based on
onwards:
values from
average of
other years.
113
industry sources.
Brookes & Barfoot — Global Impact of Biotech Crops: Income and Production Effects, 1996-2007
183
Spain
Other EU
Uruguay
AgBioForum, 12(2), 2009 | 201
1998-2004:
Impact based
Brookes (2003) identified an
+3% to
(in Euros)
42 Euros all
Based on
+6.3%
on author’s
average of +6.3% using the Bt 176
+15% ail
1998 &
years
Brookes (2003),
own detailed.
trait mainly used in the period 1998-
years
1999: 30
the only source
2005
representative
2004 (range +1 % to +40% to the
to break down
onwards:
analysis for
period 1998-2002). From 2005, 10%
2000: 28
these costs. The
+10%
period 1998-
used based on Brookes (2tK)8).
more recent cost
2002 then
which derived frcwn industry
2001-2005:
of technology
updated to
(unpublish-ed sources) ccwnmerdal-
18.5
costs derive from
reflect
scale trials and monitoring of impact
industry sources
improved
of the newer, dominant trait Mon 810
2006 and
(reflecting the
technology
in the period 2003-2007. G<»nez-
onwards: 35
use of Mon 810
based on
Barbero and Rodriguez-Cerezo
technology).
industry
(2006) reported an average impact
Industry sources
analysis.
of +5% to Bt 176 used in 2002-
also confirm
2004.
value for
insecticide cost
savings as being
representative.
France:
impacts
Based on BnDokes (2008). which
Not applied
France and
France and
Data derived
+10%
based on
drew on a number of sources. For
in context of
Germany, 40
Germany. 50
from the same
Germany:
average of
France, four sources with average
total study
Euros
Euros;
sources referred
+4%
available
yield impacts of +5% to +17%; for
due to very
to for yield.
Portugal:
impact data in
Geimany the sole source had
small scale
Portugal,
Portugal,
+12.5%
each country.
average annual impacts of +3.5%
ofproduction
Czech and
Slovakia,
Czech
and +9.5% over a two year period;
(i.e., would
Slovak
Poland and
Rep.: +10%
for Czech Republic, three studies
pnsduc^ an
Republics,
Romania, 0;
Slovakia:
identified average impacts in 2005
insignificant
and Poland,
+12.3%
of an average of 10 % and a range of
impact range
35 Euros
Czech
Poland:
+5% to +20%; for Portugal.
in the
Republic, 18
+12.5%
commercial trial and plot monitoring
context of
Romania, 32
Euros
Romania;
reported +12% in 2005 and between
the whole
Euros
+7.1%
+8% and +17% in 2006; in Slovakia
based on trials for 2003-2007 and
2006/07 plantings with yield gains
averaging between +10% and
+14.7%; in Poland based on variety
trial tests 2005 and commercial trials
2006 which had a range of +2% to
+26%; Romania based on estimated
impact by industry sources for the
2007 year.
study).
Same as
Same as
No country-specific studies
Same as
Same as
Same as
Same as
Argentina
Argentina
identified, so impact analysis from
Argentina:
Argentina
Argentina
Argentina
nearest country of relevance
+5% to +9%
(Argentina) applied.
Brookes & Barfoot~ Globa! Impact of Biotech Crops: Income and Production Effects, 1996-2007
184
AgBioForum, 12(2), 2009 | 202
GM IR com (resi^ht iQ Com rootworm)
US&
+5% ail
Based on the
Sankula and Blumerdhal {2003, +3% to +9%
2003 &
2003; $33
Data derived from
Canada
years
impact used
2006) used +5% in anal^is, dting
2004: $42
2004
Sankula and
by the
this as conservative, themselves
onwards;
Blumenthal (2006}
references
having cited impacts of +12%-+19%
2005
$37
and Johnson and
cited.
in 2005 in Iowa, +26% in illinois in
onwards;
Strom (2007).
2005. and +4%-+8% in illinois in
$35
Canada — no
2004. Johnson and Strom (2(X)7)
studies identified —
used the same basis as Sankula
as US — impacts
and Blumenthal.
qualitatively
Rice (2004) range of +1 .4% to
confirmed by
+4.5% {based on trials)
industry sources
Canada — no studies identified — as
(persona!
US — impacts qualitati\«ly confitmed
communication.
by industry sources (persona!
2005, 2007).
communication, 2006, 2007).
GM HT cotton
US
0%
Not relevant
Not relevant
Not relevant
$12.85 1996-
$34.12 1996-
Carpenter and Gianessi
2000
2000
(2002)
$21.32 2001-
$66.59 2001-
Sankula and Blumenthal
2003
2003
(2003, 2006)
$34.55 2004
$83,35 2004
Johnson and Strom (2007)—
$68.22 2005
$71.12 2005
these are the only available
$70.35 2006
$75,55 2006
studies breaking down impact
onwards
onwards
into disaggregated parts.
Australia
0%
Not relevant
Not relevant
Not relevant
Aus $50 all
Aus $60 ail
Doyle et al, (2003)
years
years
Monsanto Australia (personal
communication, 2005. 2007,
2008)
South
0%
Not relevant
Not relevant
Not relevant
133 Rand
160 Rand all
No studies identified— based
Africa
2001-2004
years
on Monsanto South Africa
101 Rand
(personal communication,
2005
165 Rand
2006
onwards
2005. 2007, 2008)
Argentina
0% on area
Based on
No studies
+10% to
122 Pesos all
68 Pesos all
No studies Identified—based
using farm
only available
identified —
+20% on
years
years
on personal communications
saved seed.
data —
based on
certified seed
with Grupo CEO and
+17.4% on
company
personal
area
Monsanto Argentina (2007,
area using
monitoring of
communic-
2008),
certified seed
commercial
ations with
plots.
GaipoCEOS
Monsanto
Argentina
(2007, 2008).
Mexico
+3.6%
Based on
Same as
0% to +6% all
All years;
All years:
No studies identified — based
only available
source for
years
720 Pesos
1,150 Pesos
on personal communications
data—
cost data
with Monsanto Mexico
company
monitoring of
commercial
plots.
(2007).
Brookes & Barfoot — Global Impact of Biotech Crops: Income and Production Effects. 1996-2007
185
AgBioForum, 12(2), 2009 | 203
!R cotton
US 1996-2002: Based on Sankula and Blumenthal (2003, +5% to
+9% the 2006)drewonearlierworkfrom +15%
(conserv- Carpenter and Gianessi (2002)
2003 & 2004; ative) impact in which they estimated the
+11% usedbythe average yield benefit in the
references 1 996-2000 period was +9%.
2005 cited Marra et al. (2002) examined
onwards; the findings of over 40 state-
+1 0% specific studies covering the
period 1996 up to 2000, the
approximate a\rerage yield
impact was +11%. The loww of
these two values was used for
the period to 2002. The higher
values applied from 2003 reflect
values used by Sankula and
Blumenthal (2006) and Johnson
and Strom (2CK)7) that take into
account the Increasing use of
Bollgard I! technology, and
draws on work by Mullins and
Hudson (2004) that identified a
yield gain of +12% relative to
conventional cotton. The values
applied 2005 onwards were
adjusted dovmwards to reflect
the fact that some of the GM IR
cotton area has still been
planted to Bollgard I.
China 1997-2001: Average of Pray, Huang, Hu. and Rozelle +6% to
+8% studies used (2002) surveyed farm level +12%
to 2001 . impact for the years 1 999-2001
2002 Increase to and identified yield impacts of
onwards; 1 0% on +5.8% in 1 999, +8% in 2000,
+10% basis of and +10.9% in 2001
industry
assess- Monsanto China (personal
ments of communication, 2007, 2008)
impact and
reporting of
unpublished
work by
Schuchan.
Australia None Studies Fitt (2001) None
have usually Doyle (2005) applied
identified no James (2002)
significant Commonwealth Scientific and
average Industrial Research
yield gain. Organisation (CSIRO. 2005)
1 996-2002; 1 996-2002; Data derived from
$58.27 $63-26 the same sources
referred to for
2003 & 2004: 2003-2005: yield,
$68.32 $74.10
2005 2006
onwards; onwards:
$49,60 $41-18
All years to
2005;
$46.30
2006
onwards:
366 Yuan
2000: $261 Data derived from
200 1 : $438 the same sources
average of referred to for
these used yield,
all other
years to
2004
2005
onwards;
1,530 Yuan
(in Australian 1 996: $1 51 Data derived from
dollars) 1 997: $1 57 the same sources
1996 & 1997: 1998; $188 referred to for
$245 1999: $172 yield (Fitt, 2001)
1998:8155 2000-2002: covering earlier
1999: $138 $267 years of adoption,
2000-2001 : 2003: $598 then CSIRO for
$155 2004:8509 later years. For
2002: $167 2005 2006 and 2007
2003: $190 onwards: cost of technology
2004: $250 $553 values confirmed
2005 by personal
onwards: communication
$300 from Monsanto
Australia.
Brookes S Barfoot — Global Impact of Biotech Crops: Income and Production Effects, 1 996-2007
186
Argentina
South
Africa
Mexico
India
Brazil
AgBioForum, 12(2), 2009 | 204
+30% all
More
Qaim and De Janwy (2002,
+25% to
All years to
51 Pesos all
Data derived from
years
conservative
2005) analysis based ferm
+35%
2004: S86
years
the same sources
of the two
level analysts in 1999AX) arxJ
referred to for
pieces of
2000/01 +35% yield gain, Trigo
2005
yield. Cost of
research
and Cap {20{^) us«l an
onwards: 116
technology in
used
average gain of +30% based on
Pesos
2006 and 2007
work by Elena (2{X)1).
also confirmed
from industry
sources.
+24% all
Lower end
Ismael et at. (2002) identified
+15% to
All years to
127 Rand
Data derived from
years
of estimates
yield gain of +24% for the years
+40%
2005: 149
all years
the same sources
applied
1998/99 & 1999/2000. Kirsten,
Rand
referred to for
Gouse, and Jenkins (2002) fw
yield. Values for
2000/01 season found a range
2006
cost of technology
of +14% (dry crops/lar^ farms)
onwards: 345
and cost of
to +49% (small farmers). James
Rand
insecticide cost
(2002) also cited a range of
savings also
impact betwieen +27% and
provided/
+48% during the years 1999-
confirmed from
2001.
industry sources.
1996: +37%
Recorded
The yield impact data tor 1997
None
Al! years to
1996 &
Data derived from
1997: +3%
yield impact
and 1998 is drawn from the
applied as
2005: 540
1999
the same sources
1998; +20%
data used as
findings of farm level survey
almost all
Pesos
onwards:
referred to for
1999: +27%
available for
work by Traxler et al. (2001).
years are
985 Pesos
yield
2000: +17%
almost all
For all other years the data is
crop-
2006
2001: +9%
years
based on the commercial crop
specific
onwards: 760
1997: $121
2002; +6.7%
monitoring reports required to
estimates
Pesos
2003; +6,4%
be submitted to the Mexican
1998: $94
2004: +7.6%
government (Monsanto Mexico.
2005:
2005, 2007). As data from this
+9.25%
source was not available for
2006: +9%
2007, the yield applied in 2007
2007: +9.28
is the average for the period
2000-2006.
2002: +46%
Recorded
Yield impact data 2002 and
All years
(in Rupees)
(in Rupees)
Data derived from
yield impact
2003 is drawn from Bennett et
45% to
2002; 2,636
2002: 2,032
the same sources
2003: +63%
used for
at. (2004). for 2004 the average
65%
referred to for
almost all
of 2002 arrd 2003 was used.
2003: 2,512
2003: 1,767
yield. 2007 cost of
2004; +54%
years
2005 and 2006 are derived from
technology
IMRB (2006, 2007). 2007
2004:2,521
2004: 1,900
confirmed from
2005; +64%
impact data based on lower end
industry sources
of range of impacts identified in
2005: $2,307
2005; 1,362
and cost savings
2006 & 2007:
previous three years (2007
for 2007 taken as
+50%
being a year of similar pest
2006 & 2007;
2006: 2,308
average of past
pressure to 2006— lower than
average).
2,211
2007: 1,857
three years
+6.23%
The only data source identified
All years;
2006
141 Real
Data derived from
(unpublished farm survey
+4% to
onwards; $40
the same source
data — Monsanto Brazil, 2008)
+8%
referred to for
has been used covering the
yield.
2006 season. This has also
been used for 2007.
B/X)okes & Batioot — Global Impact of Biotech Crops: Irrcome and Production Effects, 1996-2007
187
AgBioForum, 12(2). 2009 ! 205
GM HT soybeans
US
0%
Not relevant
Not relevant
Not relevant
1996-2002:
1996-97; $25,20
Marra, Pardey, and
S14-82
1998-2002;
Alston (2002)
2003: $17.30
$33-90
Gianessi and Carpenter
2004: $19.77
2003; $78-50
(1999)
2005 onwards;
2004; $60.10
Carpenter and Gianessi
$24.71
2005; $69.40
(2002)
2006 onwards;
Sankula and Blumentha!
$81,70
(2003, 2006)
Johnson and Strom
(2007)
Canada
0%
Not relevant
Not relevant
Not relevant
(Canadian $)
Range of Can
George Morris Centre
1997-2002; $32
$66-891997-
(2004)
2003: $48
2007 converted
2004 & 2005: $45
to US $ at
2006 onwards;
prevailing
$41
exchange rate
Argentina
0% but
Not relevant
Not relevant
Not relevant
$3-$4 all years to
$24-$30; varies
Qaim and Traxler (2002,
second crop except 2'*°
2001
each year
2005). Tiigo and Cap
benefits
crop — see
$1.20 2002-2005
according to
(2006).
separate
(reflecting ali use
exchange rate
table
of farm saved
seed)
$2.50 2006
onwards
(Monsanto royalty
rate)
Brazil
0%
Not relevant
Not relevant
Not relevant
Same as
$88 in 2004
Data from the Parana
Argentina to 2002
applied to all
Department of Agriculture
(illegal plantings)
other years at
(2004). Also agreed
2003: $9
prevailing
royalty rates from 2004.
2004; $15
2005; $16
2006; $19.80
2007; $18.80
exchange rate
Paraguay
0% but
Not relevant
Not relevant
Not relevant
Same as
Same as
Same as Argentina: no
second crop except 2"^“
Argentina to 2004
Argentina
country-specific analysis
benefits
crop
2005; $4.86
identified. Impacts
2006; $3.09
confirmed from industry
2007; $9.64
sources (personal
communication, 2006,
2008).
South
0%
Not relevant
Not relevant
Not relevant
All years to 2005:
230 Rand each
No studies identified—
Africa
170 Rand
year converted to
based on Monsanto
2006 onwards;
US Sat
South Africa (personal
1 95 Rand
prevailing
communication. 2005,
exchange rate
2007, 2008).
Uruguay
0%
Not relevant
Not relevant
Not relevant
Same as
Same as
Same as Argentina; no
Argentina
Argentina
country-specific analysis
identified, impacts
confirmed from industry
sources (personal
communication, 2006,
2008),
Brookes & Barfoot — Global Impact of Biotech Crops; Income and Production Effects. 1996-2007
188
AgBioForum, 12(2), 2009 | 206
Mexico
+9.1%
Recorded
From
None
$34.50 all years
$154.50
No studies identified
yield impact
Monsanto
applied—
based on Monsanto
from studies
(2007)
small scale
(2007) and updated by
unpublished
plantings
personal communication
study — ^the
only
identified
data
(2008).
Romania
+31%
Based on
For
+20% to
1999-20(X): $160
1999-2006;
Brookes (2005)
only
previous
+40%
20)1: $148
$150-S192
available
year—
2002: $135
depending on
study
based on
2003 & 2004:
Euro to S
covering
Brookes
$130
exchange rate
1999-2003
(2005)— the
2005; $121
2007 not
(note not
only
20(^;$100
applicable— trait
grown in
published
Not pennitted for
not permitted for
2007),
source
use in EU 2007
growing in EU
identified
All years includes
4 liters of
herbicide
GMVR crops US
Papaya
Between +15%
Based on
Draws on only
+15% all years
S0 1999 to 2003
None— no
Sankula and
and +50%
average yield in
published
to +50% ail
$42 2004
effective
Blumenthal
1999-2007—
relative to base
yield of 22.86 1/
ha
three years
before first use.
source
disaggregating
to this aspect of
impact.
years
$148 2005
onwards
conventional
method of
protection.
(2003, 2006)
Johnson and
Strom (2007)
Squash
+100% on area
planted
Assumes virus
otherwise
destroys crop
on planted
area.
Draws on only
published
source
disaggregating
to this aspect of
impact.
+50% all years
$398 alt years
None — no
effective
conventional
method of
treatment.
Sankula and
Blumenthal
(2003, 2006)
Johnson and
Strom (2007)
Brookes & Barfoot — Globa! Impact of Biotech Crops: Income and Production Effects. 1996-2007
189
AgBioForum, 12(2), 2009 \ 207
GM HT com
US
0%
Not relevant
Not relevant
Not relevant
$14.80 all
$39.90 all
Carpenter and Gianessi
years to 2004
years to 2003 (2002)
$17.30 2005
$40.55 2004
Sankula and Blumenthai
$24.71 2006
$40.75 2005
(2003, 2006)
onwards
$44.60 2006
Johnson and Strom
onwards
(2007) — these are the
only available studies
breaking down impact
into disaggregated parts.
Canada
0%
Not relevant
Not relevant
Not relevant
Can $27
Can $48.75
No studies identified™
1999-2005
all years
based on personal
Can $35
communications with
2006
industry sources,
onwards
including Monsanto
Canada.
Argentina
+3% com belt Based on only
No studies
+1%to +5%
61 Pesos all
61 Pesos all
No studies identified —
+22%
available
identified —
com belt.
years
years
based on Monsanto
marginal
analysis —
based on
+15% to
Argentina and Grupo
areas
Corn Belt =
personal
+30%
CEO (personal
70% of
communicati
marginal
communication. 2007,
plantings,
ons vfllh
areas
2008).
marginal areas
industry
30%— industry
sources in
analysis (note
2007 and
no significant
2008
plantings until
Monsanto
2006)
Argentina
ami Grupo
CEO
(persona!
communicati
on. 2007.
2008).
South Africa
0%
Not relevant
Not relevant
Not relevant
80 Rand
162 Rand all
No studies identified—
2003-2005
years
based on Monsanto
120 Rand
South Africa (personal
2006
communication, 2005,
onwards
2007, 2008).
Philippines
+15%
Based on only
+10% to
1 .232 Pesos
Not knovwi so
No studies identified—
available
+20% all
all years
conservative
based on Monsanto
analysis —
years
assumption of Philippines (personal
industry
zero used
communication, 2007,
analysis
2008).
Brookes & Barfoot — Gfobai impact of Biotech Crops: Income and Production Effects, 1996-2007
190
AgBioForum. 12(2), 2009 | 208
GMHTcahoia
+6% all years to 2004.
Based on the
Same as
Mvears: Glvohosate
Glvohosate
Sankula and
Post 2004, based on
only identified
source for cost
+3% to tolerant
teleianS
Blumenthal
Canada— see below
impact
data
+9% 1999-2001;
1999-2001:
(2003. 2006)
analysis — post
$29-50
$60,75
Johnson and
2004 based on
2002-2004; $33
2002 & 2003: $67 Strom (2007)
Canadian
2005 onwards:
2004: $69
These are the
impacts as
$12
2005; $49
only studies
same
2006 onwards:
identified that
alternative
Gliifosinate
$40
examine GM
(conventional
tolerant
Gliifosinate
HT canola in
HT) technolc^y
Al) years for to
tolerant
the US,
to Canada
2004: $17-30
All years to 2003:
available.
From 2005: $12
$44.89
2004; $44
2005; $40
2006 onwards:
$435
+10.7% all years to
Same as
+4% to
Can $44.63 all
(In Canadian $)
Based on
2004. After 2004, based
source for cost
+12% all
years to 2003
Glvohosate
Canola
on differences between
data
years
2004 onwards
tolerant
Council of
average annual variety
based on
$39 all years to
Canada
trial results for
difference seed
2003
(2001) to
Clearfields (non-GM HT
premium and
2003. (hen
varieties) and GM
ledmology fee
2004 onwards:
adjusted to
alternatives. GM
relative to
$40
reflect main
alternatives
Clearfields HT
current non
differentiated into
canola; $0 for
Glufosinate
GM (HT)
giyphosate tolerant and
GM glufosinate
tglemiH
alternative of
glufosinate tolerant.
tolerance and
Ail years to 2003;
‘Clearfields’—
This resulted in— for
Can $37 for
$39
data derived
GM giyphosate tolerant
giyphosate
from personal
varieties— no yield
tolerance
2004 onwards:
communicatio
difference for 2004 and
$10
ns with the
2005 and +4% for 2006
Canola
and 2007. For GM
Council of
glufosinate tolerant
Canada
varieties, the yield
(2008) and
differences were +12%
Gusta et al.
in 2004, +19% in 2005,
(2008).
and +10% for 2006 and
2007.
Readers should note that the assumptions are drawn
from the references cited, supplemented and updated by
industry sources {where the authors have not been able
to identity specific studies). This has been particularly
of relevance for some of the HT traits more recently
adopted in several developing countries. Accordingly,
the authors are grateful to industry sources who have
provided infonnation on impact, notably on cost of the
technology and impact on costs of crop protection.
While this information is not derived from detailed stud-
ies, the authors are confident that it is reasonably repre-
sentative of average impacts; in fact, in a number of
cases, information provided from industry sources via
personal communications has suggested levels of aver-
age impact that are lower than those identified in inde-
pendent studies. Where this has occurred, the more
conservative (industry source) data has been used.
Brookes & Barfoot — Global Impact of Biotech Crops: Income and Production Effects, 1996-2007
191
GLOBAL IMPACT OF BIOTECH CROPS
GLOBAL IMPACT OF BIOTECH CROPS: SOCIO-ECONOMIC &
ENVIRONMENTAL EFFECTS 1996-2007
Graham Brookes & Peter Barfoot, PG Economics Ltd, Dorchester, UK outline the benefits that have been found
with the growing of GM crops globally
www.pgeconomics.co.uk
Keywords: yield, cost, income, environmental impact quotient, carbon
sequestration, GM crops
Introduction
This paper summarises the findings of research into the global
socio-economic and environmental impact of biotech crops in
the twelve years since they were first commercially planted on
a significanr area in 1996. Since then the global area using this
technology has grown rapidly ro in excess of JOO million
hectares, highlighting the popularity of the technology
amongst adopting farmers. In contrast, EU farmers have had
little opportunity to adopt this technology with only one trait
(insect resistant maize} approved for piaiiring and the EU
accounting for less than ()..5% of the global biotech crop in
2007. The paper focuses on the farm level economic effects,
the production effects, the environmental impact resulting
from changes in the use of insecticides and herbicides, and the
contribution towards reducing greenhouse gas (GEIG)
emissions of biotech trait adoption. The research is based on.
and draws from, an extensive literature review of impacts
globally coupled with some collection and analysis of data,
notably relating to pe.sticide usage. More detailed infonnation
and a full list of references can be found by referring to longer
papers on. this topic by the authors in the peer reviewed
journal Agl?iofo.rum - www.agbioforum.org or directly from
the PG Exonomics vvebsile (see above).
Parm Income Impacts
GM technology has had a significant positive impact on the
income of farmers itsing the technology, derived from a
combination of enhanced productivity and efficiency gains
(Table I). .In 2007, the direct global farm income benefit
fixim biotech crops was S10.1 billion. This is equivalent to
having added 4.4% to die value of global production of the
four main crops of soybean.s, maize (com), oilseed rape
(canola) and cotton. Since 1996, farm incomes have
increased by $44.1 billion. The largest gains in farm income
have been in the soybean .sector, largely from co,st savings.
The .S3. 9 billion additional income generated by GM
herbicide tolerant (GM ITT) soybeans in 2007 ha.s been
equivalent to adding the equivalent of 6.4% to the $60
billion value of this crop in 2007.
Substantial gains have also arisen in the cotton sector
through a combination of higher yields and lower costs. In
2007, cotton farm income levels in the biotech adopting
countries increased by S3. 2 billion and from 1996 to 2007,
the sector has benefited from an addition,!! $12. 6 billion. In
2007 alone, income gain.s from GM technology added
10.2% to the $27.5 billion value of total global cotton
production, a substantial increa.se in value added terms tor
two new cotton seed technologies.
Significant increases to farm incomes have also been seen
in the maize and canola sectors. The combination of GM
insect resistant (G.M IR) and GM HT technology in maize
has boosted farm incomes by $7.2 billion since 1996. In the
North American canola sector, an additional S1.4 billion has
been generated.
Figure 1 summarises farm income impacts in key biotech
adopting countries and this highlights the important farm
income benefit arising from GM technology in South
American countries, China and India and the US. It also
illustrates the growing level of farm income benefits being
obtained in South Africa, the Philippines and Mcx'tco.
Figure I
In terms of the division of the economic benefits obtained
by farmers in less developed countries relative to farmers in
developed countries, in 2007, 5k% of the farm income
benefits have been earned by less developed country farmers,
wth the vast majority of these income gains coming from GM
IR cotton and GM HT soybeans.’ Over the twelve years.
’ The :iuihors acknowledge that the classification of different countries into less developed or dcvc.k)pcd country status affects the
distribution of benefits between the.se two categories of country. The definition used in this paper is consistent wdih the definivinn used
by James (20071
on Pest Management - December 2009
© 2009, Research Infonnation Ltd. All rights reserved
DOf; !0.!56T20d<
)6
258 Outlooks
192
GLOBAL IMPACT OF BIOTECH CROPS
Table I. Global form income benefits from^^bWing bioc«:h crops 1996-2007; million US $
Trait
Increase in farm
income 2007
increase in farm
income 1996-2007
Farm income
benefit in 2007 as
% of total value of
production of these
crops in biotech
adopting countries
Farm income
benefit in 2007 as
% of total value of
global production
of crop
GH herbicide
tolerant soybeans
3,935.5
21.814,1
7.2
,6.4 ,
GM herbicide
tolerant maize
',442.3,' ,
0.7
0.4
GM herbicide ,
tolerant cotton
, 24.5 , ,
, 848.2
O.f
• 0.1
GM herbicide
tolerant canola.
345,6
1.438.6
, • 7.65 '
1.4 '' '
GM insect resistant
maize
2,075.3
5,673;6;'.:':''
■ 3.2
1.9
GM insect resistant
toctoh'
3,204.0
12.5762
16.5.
io.2
Others
,54.4
208.8
Not applicable .
Not applicable.
TotMs .
10,081.6
44,067.1
6.9
4.4 ■
Notes: All values are nominal. Others = Virus resistant papaya and squash.Totals for the vsJue shares exclude ‘other crops’ (ie, relate tb the
4 main crops of soyb^ns, maize, canola and cotton), farm income calculations are net ferm income changes' after inclusion of trhpacts bn . ..■
yield, crop quality arid key variable costs of production (eg, payment of seed premia, impact on crop protection expenditure)
Table 1. Cost 6f accessing CM technology {million $) relative to ^e total ferrn |h(:bme.benefits 2007/
Cost of
technology:
ail farmers
Farm
income
gain: at!
farmers
Total benefit of
technology to
farmers and
seed supply
chain
Cost of
technology:
less
developed
countries
Farm income
gain: less
developed
countries
Total benefit
of technology to
farmers and seed
supply chain:
less developed
countries
GMWT
soybeans
• 930.8 ^ ,
, 3,935.5 ■
4,866.3
326
2,560.5
, ..2.886;S
GMIR
rrialze
7H:3,
: 2.075.3
2,789.6
79.1
301.9
''•'•' 38i'.
GM HT , • ; •
maize"'',' ,
• 530.8
'•'442.3 '• /
973.1
20.2
40.8
•,','' 61
GM IR
cotton
• 670.4
3.204.0
, 3.874.4
535.1
2,918.1
3.353.2
GM HT
cotton
226'.4' '
24.5
8.5
8.2
16,7
GMHT
canola
102.2
. 345.6
,-447.'8-.\-./''-."'„;
- N/a
N/a,
N/a
Total
3.174.9
10,027.2
13,202.1
968.9
5,829.5
6,798.4
N/a = not applicable. Cost of accessing technology based; bnthe s^d. phemiipaid fay formers for using GM technology relative to ids'
conventional equivalents. Total form income gain excludes. $54,4 million, associated ,widi virus resistant crops in the US
Outlooks on Pest Management -- December 2009 259
193
OTECH CROPS
\99b-lW~ rhi. cil n ! I’-uc farniincomc gain derived by less
devek-pud coiinrn fiimcis was S22.1 billion (50.1% of the
total).
Examining the cost farmers' pay for accessing GM
technology, Table 2 shows that across the four main biotech
crops, the total cost in 2007 was equal to 24% of the total
technology gains (inclusive of farm income gains plus cost of
the technology payable to the seed supply chain^). For
farmers in less developed countries the total cost was equal
to 14% of total technology gains', whilst for farmers in
developed countries the cost was 34% of the total technology
gains. These differences are accounted for by factors such as
weaker provision and enforcement of intellectual property
rights in less developed countries and the higher average level
of farm income gain on a per hectare basis derived by less
developed country farmers.
Indirect (non pecuniary) Farm Level Impacts
As well as the more tangible and quantifiable impacts on farm
profitability presented above, there are other important, more
intangible (difficult to quantify) impacts of an economic
nature that studies have identifed. The main ones are:
for herbicide tolerant crops the main benefits are:
• increased management flexibility and convenience that
comes from a combination of the ease of use associated
with broad-spcctrum, post emergent herbicides like
glyphosate and the wider window for spraying;
• reduced damage to crops by inputs. In a conventional
crop, post-emergent weed control relics on herbicide
applications before the weeds and crop are well
established to achieve maximum efficacy. As a result, the
crop may suffer ‘knock-back’ to its growth from the
effects of the herbicide. In a GM HT crop, this problem is
avoided because the crop is both tolerant to the herbicide
and spraying can occur at a later stage when the crop is
better able to withstand any possible “knock-back”
effects;
» facilitation of the adoption of conservation or no riliage
systems. This provides additional cost saving benefits
such as reduced labour and fuel costs associated with
ploughing, in addition to greater moisture rerention and
reductions in levels of soil erosion;
• improvements in levels of weed control. This has
contributed to reduced harvesting costs - cleaner crop.s
have resulted in reduced times for harvesring. It has also
improved harvest quality and led to higher levels of
quality price bonuses in some regions and years (eg, HT
soybeans and HT canola in the early years of adoption
respectively in Romania and Canada-’);
• elimination of potential damage caused by soii-
incorporated residual herbicides in follow-on crops;
• reduced need to apply herbicides in a fc>llow-t)n crop
because of the improved weed control.
For insect resistant crops the main benefits arc:
• improved production risk management - the technology
takes away much of the w'orry of significant pest damage
ocairring and is, therefore, highly valued:
• reduced management rime. .A ‘convenience’ benefit from
having to devote less time to crop walking and applying
Insecticides;
• savings in energy use - mainly associated with less use of
aerial spraying;
• savings in machinery use (for spraying and possibly
reduced harvesting times'^);
• better crop quality. There is a growing body of research
evidence^ relating to the superior quality of GM IR corn
relative to conventional and organic corn from the
perspective of having lower levels of mycotoxins;
• iniprtwcd health and safety for farmers and farm workers,
from reduced handling and use of pcsticide.s, especially in
less developed countries where many apply pesticides
with little or no use of protective clothing and equipment;
• sliortcr growing season (eg, for .some cotton growers in
India) which allows some farmers to plant a second crop
in the same season^;
• benefits to the local environment from reduced spraying.
For example. Some Indian cotton growers have reported
knock on benefits for bee keepers as fewer bees are now
lost to insecticide spraying.^
Since the early 2000s, a number of farmer-survey based
studies in the UvS have attempted to quantify these non
pecuniary benefits. These studies have usually employed
contingent valuation tcchniques.s Drawing on this analysis,
the estimated value for non pecuniary benefits derived from
biotech crops in the US (1996-2007) is $5.11 billion, equal to
26% of the total cumulative (1996-2007) direct farm
income. Similar benefits are likely likely to have accrued in
other countries, but have not yet been quantified.
Production Effects on the Technology
Based on the yield assumptions used in the direct farm
income l->cncfir calcuarions presented above and taking
account of the second soybean crop tacilimtion in South
The cost of chf (ochuology .iccrues to the seed supply chain including sellers of seed to farmers, seed multipliers, plant breeders,
distributors and the (iM technoingy providers
^ .%-e for t'x.ampic Brouke.s (2005) relating to Romania and the Canola Council (2001) rebating to Canada cited in the full Brookes &
Barfoot (2009) p.apcr
^ For example, when there is lower incidence of crops failing over slowing the speed of harvesting equipment - a notable benefit of GM
iR technology in maize - see for examj’le Brookes (2002) relating to Spain, cited in the full Brookes Barfoot (2009) paper
See Brooke.s (2008) relaiing to the adoption of Bi maiz.e in Europe, cited in the full Brookes Sc B.irfoot (2009)
Not.ibly m,ji7c in India - see tor example, Manjunath T (2008) cited in the full Brookes & Barfoot (2009) paper
^ .Vianjnnaih T (2008) ciu-sl in the full Brmtkes & Barfoot (2009) paper
^ Survey based method of obr.aining valuations of non market goods that aim to identify wiilirigne.ss to pay for specific goods (eg,
environmental goods, peace of mind, etc) or w'iliingness to pay to avoid something being lost
260 Outlooks
Pest Management - December 2009
194
GLOBAL IMPACT OF BIOTECH CROPS
America (see below), biotech crops have made important
contrihurions to global production of corn, cotton, canola
and soybeans since 1996 { Tabic 3). The biotech IR traits,
used in the corn and cotton sectors, have accounted for 99%
of the additional corn production and almost all of the
additional cotton production and since 1996 the average
yield impact across the total area planted to these traits over
the 12 year period has been +6.1% for corn traits and
+ 13.4% for cotton traits.'^
Table 3. Addiaonai crop production arising from positive
yield effects of biotech crops
1996-2007 additional
production
(million tonnes)
2007 additional
production
(million tonnes)
Soybeans
67.80
14.46
Corn
62-42
lS-08 3';:
Cotton
6.85
2.01
Canofa .
4.44
0.54
Although the primary impact of biotech HT technology
has been to provide more cost effective (less expensive) and
easier weed control versus improving yields from better weed
control (relative to weed control obtained from conventional
technology), improved weed control has, nevertheless
occurred, delivering higher yields in some countries.
.Specifically, HT soybeans in Romania improved the average
yield by over 30% and biotech HT corn in Argentina and the
Philippines delivered yield improvemenrs of +9% and +1.^%
respecrivclydo
Biotech HT soybeans have al.so facilitated the adoption of
no tillage production systems, shortening the production
cycle (eg, by nor needing to plough). This advantage enables
many farmers in South America to plant a crop of soybeans
immediately after a wheat crop in rhe same growing season.
This .second crop, additional to traditional soybean
production, has added 67. .5 million tonnes to soybean
production in Argentina and Paraguay between 1996 and
2006 (accounting for 99% of the total biorcch-relared
additional .soybean production). H
Impact on Pesticide Use and the Associated
Environmental Impact
To examine the environmental impact of pc.sricidc use with
biotech crops, studies have analysed both active ingredient
use and utilised the indicaror known as the Unvironraental
impact Quotient (EIQ1-) to assess the broader impact on the
environment (plus impact on animal and human health). The
EIQ distils the various environmental and health impacts of
individual pesticides and agrieulrurai practices in different
production .systems into a single ‘field value per hectare' by
dratving on all of the key toxicity and environmental
exposure data related to individual products. It therefore
provides a consistenr and fairly comprehensive measure to
compare the impact of crop protection practices in various
production systems (be they (tM, conventional or organic)
on the environment and human health. Table 4 summarises
the environmental impact over the last twelve years and
shows that there have been important environmental gains
associated whth adoption of biotechnology. .More specifically,
the analysis presented in the full Brookes & Barfoor (2009)
paper shows that:
• Since 1996, the quantity of herbicides and insecticides
applied to the biotech crop area was redticed by 359
million kg of active ingredient (8.8% reduction). The
overall environmental impact associated with their use on
these crops was reduced by 17.2%;
• In absolute terms, the largest environmental gain has been
asscKiatcd wdth the adoption of GM HT soybeans, which
reflects the large share of global .soybean plantings
accounted for by biotech varieties. The volume of
herbicides used in biotech .soybean crops decreased by 73
million kg {1996-2007}, a 4.6% reduction, and, the overall
environmental impact associated with herbicide u.se on
these crops decreased by 20.9% (compared to the probably
impact if this cropping area had been planted to
conventional soybeans). However, it should be noted that
in .some countries, such as in South America, the adoption
of G.M HT soybeans coincided with increases in rhe volume
of herbicides used relative to historic levels on a number of
arable crops (both GM and convenrionat). 'I'his largely
reflects the facilitating role of the GM HT technology in
accelerating and maintaining the switch away from
conventional tillage to no/iow tillage production systems
with their inherent other environmental benefits (notably
reductions in greenhouse ga.s emissions and reduced soil
erosion). Despite this net increa.se in the volume of
herbicides used in some countries, the associated EIQ
values still fell, as farmers switched to herbicides with a
more environmentally benign profile;
• Major environmental gains have al.so been derived from
the adoption of GM IR cotton. These gains were the
largest of any crop on a per hectare ha.sis. Since 1996,
farmers have used 147.6 milii<in kg less insecticide in GM.
IR cotton crops (a 23% reduction), and this has reduced
the a.ssociarcd environmental impact of insecticide use on
this crop area by 27.8%;
• Important environmental gains have also arisen in the
maize and canola sectors. In maize, herbicide and
insecticide use decreased by 92 million kg and the
associated environmental imy)act on this crop area
See the full Brookes Sc Ikiriooi (2009) paper for additional information
St'c' fhc full Brookes & Barfoov (2009) paper for additional information
" See rhe full Brookes 8c Barfcuit (2009) paper for additional information
Developed at (Sornel! University
Outlooks on Pest Management - December 2009 261
195
GLOBAL IMPACT OF BIOTECH CROPS
• Table 4. Impact of change
s biotech crops g!
obaily 1996-2007 .,
Trait
Change in
volume of active
ingredient used
(million kg)
Change in field
EIQ impact (in
terms of million
field EiQ/ha
units)
% change in ai
use on biotech
crops
.% change In
environmental
impact associated
With herbicide &
insecticide use on
biotech crops
,GM herbidded-' - ’ "
tolerant soybeans
-730:0
■- ■-62S3;-
GM herbic oo
toIeVant maize
: -^1.8
wyi- r,' -6.0.
-68
,GM herbicide
, tolerant cotton
-37-0
-ill
-i60
GM herbicide ,
tc^erant canola ,
-9.7.'
-443
•25S
■■GM'insect'/ •
resistant maize
, -10.2
. '-528-
.-S.9 • ••
.. -60
GM insect .
' -resistant cotton''
-7.133
'■ -23.0, •
Totals
-359.3
-17,069
-8.8
-17.2
decreased, due to a combination of reduced insecticide
use (5.9%) and a switch to more environmental!)' benign
herbicides (6%). !n canola, farmers reduced herbicide use
by 9.7 million kg (a 13.9% reduction) and the associated
environmental impact of lierbicide use fell by 25.8% {due
to a switch to more environmentally benign herbicides).
Fifty two per cent of the environmental benefits (1996-2007)
associated with lower insecticide and herbicide use have been
in less developed countries, the vast majority of which have
been from the use of GM IR cotton and GM HT soybeans.
Impact on Greenhouse Gas (GHG) Emissions
Biotech crops contribute to lower levels of GFIG emissions
in two principle ways>-b
• Reduced fuel use from less frequent herbicide or
insecticide applications and a reduction in the energy use
in soil cultivation. In 2007, this amounted to about 1,144
million kg of carbon dioxide savings (arising from reduced
fuel use of 416 million litres). 0%’er the period 1996 to
2007 the cumulative pennaneiu carbon dioxide reduction
is estimated at 7,090 million kg of carbon dioxide (arising
from reduced fuel use of 2,578 million litres);
• Use of ‘no-fiir and ‘reduced-tiiri^ farming systems. These
production systems have increa.sed significantly with the
adoption of GM HT crops because the technology has
improved growers ability to control competing weeds,
without the need to rely on soil cultivation and seed-bed
preparation. As a re.sult, tractor fuel use for tillage is
reduced (see above), soil quality is enhanced and levels of
soil erosion cut. In turn, more carbon remains in the soil
and this leads to lower GHG emissions. As a result of the
rapid adoption of no cill/reduced tillage farming systems
in North and South America, an extra .3,570 million kg of
soil carbon is estimated to have been sequestered in 2007
(equivalent to 13,10.3 million tonnes of carbon dioxide
that has not been released into the global atmosphere).
Cumulatively the amount of carbon sequestered may be
higher due to year-on-year benefits to soil quality.^-''
However, with <»ily an estimated 15%.-25% of the crop
area in continuous no-till systems it is currently not
possible to esrimarc confidently cumulative soil
sequestration gains.
1-^ Additional deiatis about liow these values are calculated and associated references can be found in the lull Brookes & Rarfoot (2009)
paper. Limited .-svaiiability of space for this article means full details cannot provided here atrd therefore interested readers should consult
the fv!!l report
No-ci!l farming means that the ground is not ploughed at ail, while reduced tillage means th.at the ground is disturbed less than it would
be with traditional tillage sy.stems. For example, under a no-tiiJ farming system, soybean seeds are planted through the organic matcri.ai
that is left over from a previous crop such as corn, corton or wheat
The optimum conditions for soil sequestration arc high biomass production of both surface residue and decaying roots that decompose
in moist soils where aeration is not limiting
262 Outlooks
Pest Management - December 2009
196
GLOBAL IMPACT OF BIOTECH CROPS ,1
Placing these carbon sequestration benefits within the
context ot the carbon dioxide emissions from cars. Table 5
shows that:
• fn 2007, the permanent carbon dioxide savings from
reduced fuel use were the equivalent of removing nearly
495,000 cars from the road for a year;
• The additional probable soil carbon sequestration gains
in 2007 were equivalent to removing nearly 5.823 million
cars from the roads for a year;
Table 5. Biotech crop environmenuir benefits from lovrer 'c . 7 ,
insecticide and herbicide use 1996-2007: devek^ing versus./ ;
developed countries ,
Change in field EIQ Change In field EIQ
impact (in terms impact (in terms of
of million field million field EIQ/ha
EIQ/ha units): units): less developed
developed countries countries
.GM HT soybeans
-3,559 ,
-2,724
GMIR maize
-516
■ -i2
GM HT maize
~i.910
-23 7;
GfifR cotton
, ,-1.053 ,
-6.080
GM HT cotton
-726
-22
GM HT canola
-H44
Not applicable
Total
-8,208
-8,861
• In total, the combined biotech crop-rclarcd carbon
dioxide emission savings from reduced fuel use and
additional soil carbon sequestration in 2007 were equal
to the removal from the roads for a year of nearly 6.3
million cars, equivalent to about 24% of a!! registered
cars in the UK;
• It is not possible to estimate confidently the soil carbon
sequestration gains since 1,996. If the entire biotech crop
in reduced or no tillage agricukure during the last twelve
years had remained in permanent rcduccd/no tillage then
this would have re.sulted in a carbon dioxide saving of
83.18 million kg, equivalent to taking 36.97 million cars
off the road for a year. This is, however a maximum
possibility and the actual levels of carbon dioxide
reduction are likely to be lower.
Concluding comments
Biotechnology has, to date, delivered .several specific
agronomic traits that have overcome a number of production
constraints for many farmers, decreased pesticide spraying
and signficantly boosted farm incomes, fn addition, this has
contributed to reducing the release of greenhouse gvTS
emissions from agriculture. The technology has also made
important contributions to increasing the yields of many
farmers, reducing production risk.s, improving productivity
and raising global production of key crop.s. This combination
of economic and environmental benefit delivery i.s, therefore,
already making a valuable contribution to improving the
sustainability of global agriculture, with these benefits and
improvements being greatest in less developed countries.
Table 6. Context of carbon sequestration impact 2007: car equivalent
Crop/trait/
country
Permanent
carbon dioxide
savings arising
from reduced
fuel use
(million kg of
carbon dioxide)
Average family
car equivalents
removed from
the road for a
year from the
permanent fuel
savings (’000s)
Potential
additional soil
carbon
sequestration
savings (million
kg of carbon
dioxide
Average family
car equivalents /
removed from
the road for a
year from tiie
potential
additional soil
carbon
sequestration
(’000s)
US: GM HT soybeans '
'• 247 ' '
no
3.999
' 1.777',' ......
Argentina: • ••'
609
',■271'..;,'.
6,136
2.727
GM HT soybeans. •
Other countries: •
• ,91
.40:..:--''
l,34i
' - 596 . . ..
GM HT.sbybeans
Canada;
GM HT canola-
131
58.//;%/.-":'
1,627
' 111
Global GM IR cotton
37
,0'
0 , '
Total
I,il5
495
13,103
5.823
Notes: Assumption; an average family car produces ISO gr^s crf'carbbh;dlc«i^.pf,ten. A car does an average of IS.OOOkm/year and
therefore produces 2.250kg of carbon diox'idc/year ■ • , .
Outlooks on Pest Management -• December 2009 263
197
GLOBAL IMPACT OF BIOTECH CROPS
Further Reading
Brookes Li Hiirk)or P (2009) L.M crops: global socio-economic
and environmental impacts, 1996-2007. PG Economics,
Dorchester, UK \vwvv.pgeconomics.co-uk/pdf/2009
globalitTspactsriKiy.pdf. Also version accepted for publication in
the iournal AgBioformn {furthcoming). It updates the findings
of earlier analysis presented by the authors in AgbioFomm 8
(2&3) 187-196, 9 {3) !-!3 .tnd 11 fl), 21-38.' ww'w.agbio
forum.org
Brookes G (2003) The iarm level impact of using Bt maize in Spain,
IGABR conference paper 2003, Rav'cllo, Italy. Also on
www.pgcconomics.co.uk
Brookes G (2005! 'i'hc farm level impact of U-sing Roundup Ready-
soybeans in Romania. Agbiofonun Vol 8, No 4. -www.agbio
forum, org
Brookes G (2008) The benefits of adopting GM insect resistant {Bt)
maize in the KU: first results from 1998-2006, international
journal of Biotechnology', 134, issue 3-4
Canola Council of Canada (2001) An agrtmomic & economic
assessment of tran.sgcnic canola. Canola Council, Canada.
\vww.canola-counc.ii.org
Manjunath T' (2008) Bt cotton in India: rctn.trkable adoption and
benefits, Foundation for Ritucch zXwarcncss and Education,
India, www.fbae.org
"&x^KmBroirf^.isan'a^cuhui'3l economist and consultant who nas, over the
last fcw«lve years, undertaken a number of research projects relating to tne
impact of aj^lcuhura! biotechnology and written widely on the subject. This
work induties annual updates of the , global economic and environmental
.impKt .of GM CTOps since 1996: papers on co-exiscence of GM and non GM
:cropS4ihe possdjie impact of GM crops in the a number of EU countries ^eg,
UK. l^nd,Sovakia- and Hungary), the actual impact of insect resistant maize
in- ^»in and herbicide tolerant soybeans in Romania. GM crop market
d)niamia and GM nee. crop developments to 2012. the impact of GMO
iabelbig in Europe, the economic impact of GMO zero tolerance legislation
and. the cost to the UK. economy of failure to embrace agncultura!
biotechnok^.
Peter Barfoat is a ^secialist in biotechnology, having previously worned for tne
Agncultural . Genetics Company (UK) and now runs the successful
: Bic^wtfi^io.com website. He formed PG Economics with Graham m 1999
^sedfieaHy to undertake research consultancy projects focusing on the impact
of nw Eedhnology in agrtcuiture. He has co-authored several papers on die
: impact -of fHOtachntdogy m agncuiture.(see above) with Graham Brookes.
Similar articles that appeared in Outlooks on Pest Management include - 200S 16 ( 4 ) 164;
ZOOS 16 ( 5 ) 208; 2006 17 ( 6 ) 249; 2007 18 ( 2 ) 73; 2009 20 ( 3 ) 135
Future Prospects for Chemical
Insecticides: A Symposium for
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Outlooks on Pest Management - December 2009
264
198
AgBioForum, 13(1): 25-52. ©2010 AgBioForum.
The Production and Price Impact of Biotech Corn, Canola, and
Soybean Crops
Graham Brookes
PG Economics
Tun Hsiang “Edward" Yu
University of Tennessee
Simla Tokgoz
International Food Policy Research Institute (IFPRI)
Amani Elobeid
Centre for Agricultural and Rural Development (CARD), Iowa
State University
Biotedi crops have now been growi commerciaily on a sub-
stantial global scale since 1996. This article examines the pro-
duction effects of the technology and impacts on cereal and
oilseed markets through the use of agricultural commodity mod-
els. It analyses the impacts on global production, consumption,
frade. and prices in the soybean, canola, and corn sectors. The
analysis suggests that world prices of corn, soybeans, and
canola would probably be, respectively, 5.8%, 9.6%, and 3.8%
higher, on average, than 2007 baseline levels if this technology
was no longer available to farmers. Prices of key derivatives of
soybeans (meat and oil) would also be between 5% and 9%
higher, with rapeseed meal and oil prices being about 4% higher
than baseline levels. World prices of related cereals and oil-
seeds would also be expected to be higher by 3% to 4%.
Key words: biotech crops, prices, yield, soybeans, com,
canola, partial-equilibrium model, price effects.
The effect of no longer using the current widely used
biotech traits in the com, soybean, and canola sectors
would probably impact negatively on both the global
supply and utilization of these crops, their derivatives
and related markets for grain and oilseeds. The model-
ling suggests that average global yields would fall for
com, soybeans, and canola and despite some likely
‘compensatory’ additional plantings of these three
crops, there would be a net fall in global production of
the three crops of 1 4 million tonnes. Global trade and
consumption of these crops/derivatives would also be
expected to fall. The production and consumption of
other grains such as wheat, barley, and sorghum and oil-
seeds-~notably sunflower- -would also be affected.
Overall, net production of grains and oilseeds (and
derivatives) would fall by 17.7 million tonnes, and
global consumption would fall by 15.4 million tonnes.
The cost of consumption would also increase by $20 bil-
lion (3.6%) relative to the total cost of consumption of
the (higher) biotech-inclusive level of world consump-
tion. The impacts identified in this analysis are, how-
ever, probably conservative, reflecting the limitations of
the methodology used. In particular, the limited research
conducted to date into the impact of the cost-reducing
effect of biotechnology (notably in herbicide-tolerant
[HT] soybeans) on prices suggests that the price effects
identified in this article represent only part of the total
price impact of the technology.
Introduction
Biotechnology crop traits have been growm on a wide-
spread commercial global basis since 1996, and in 2008,
the global cultivation area of biotech crops reached 125
million hectares, a 74-fold increase from the 1996 level.
The number of countries adopting biotech crop cultiva-
tion has also increased from six in 1996 to 25 in 2008,
with the United Slates leading the way in the utilization
of biotechnology in crop production. The rapid growth
of biotech crop hectares between 1996 and 2008 has
made this the most rapidly adopted crop technology in
agriculture over this period (James, 2008).
Currently, the biotech crop hectares are primarily
utilized for soybeans, com, cotton, and canola. Tlte
technolog>' used thus far has been agronomic, cost-sav-
ing technology delivering herbicide tolerance in all four
of these crops and Insect resistance in the crops of com
and cotton. This technology has provided famiers with
productivity improvements through a combination of
yield improvement and cost reductions. As such, the
technology is likely to have had an impact on the prices
of soybeans, com, cotton, and canola (and their deriva-
tives) both in the countries where fanners have used
biotech traits and in the global market.
Assessing the impact of the biotechnology applica-
tions on the prices of soybeans, com, cotton, and canola
(and their derivatives) is challenging since current and
past prices reflect a multitude of factors — of which the
introduction and adoption of new, cost-saving technolo-
gies is one. This means that disaggregating the effect of
different variables on prices is far from easy. Previous
199
studies have contributed to the iiterature by evaluating
the impacts of biotechnology application for field crops
on national/regiona! economies and farmers' welfare
(e.g., Anderson, Valenzuela, & Jackson, 2008; Martin &
Hyde, 2001; Sobolevsky, Moschini, & Lapan, 2005).
However, most of these studies primarily focused on a
single crop, such as soybeans, corn, or cotton. Thus, the
impact analysis of biotechnology adoption did not cap-
ture the responsiveness of the production of other crops.
Furthermore, since the application of biotechnology
usually occurs in various field crops, the joint impacts of
biotechnology adoption on local and global agricultural
markets need to be further explored.
Realizing the surging significance of biotechnology
application in the US and global crop markets, this arti-
cle summarizes the productivity impacts of biotech
crops' (on production) and presents the findings of anal-
ysis that has sought to quantify the impact of the use of
biotech traits on usage and the prices of com, soybeans,
and canola and their main derivatives."
Methodology
The approach used to estimate the impacts of biotech
crops on usage, trade, and prices of the three crops and
their derivatives has been to draw on part of a broad
modelling system of the world agricultural economy
comprised of US and international multi-maricet, partial-
equilibrium models of production, use, and trade In key
agricultural commodities.^ The models cover major
temperate crops, sugar, ethanol and biodiesel, dairy, and
livestock and meat products for all major producing and
consuming countries and calibrated on most recently
available data. Extensive market linkages exi.st In these
models, reflecting derived demand for feed in livestock
and dairy sectors, competition for land in production,
iind consumer substitution possibilities for dose substi-
tutes such as vegetable oils and meat types. The models
capture the biological, technical, and economic relation-
ships among key variables within a particular commod-
ity and across commodities. They are based on historical
data analysis, current academic research, and a reliance
on accepted economic, agronomic, and biological rela-
/. Drawing primarily on work by one of ihe authors. Brookes
and Barfool (200iSj. A more detailed paper is also available
on http://www.pgeconQniics.co.uk.fdf'
globalimpactstudyjiine2008pgeconomics.pdf
2. The impact of biotech traits in the cotton sector is not
included in the. analysis.
3. More details about the modelling structure are presented in
Appendix A.
AgBioForum, 13(1), 2010 | 26
tionships in agricultural production and markets. A link
is made through prices and net trade equations between
the US and international models. The models are used to
establish lO-year commodity projections for a baseline
and for policy analysis and are used extensively for the
market outlook and policy analysis.
In general, for each commodity sector, the economic
relationship that supply equals demand is maintained by
determining a market-clearing price for the commodity.
In countries where domestic prices are not solved
endogenously, these prices are modelled as a function of
the world price using a price transmission equation.
Since the models for each sector can be linked, changes
in one commodity sector will impact other sectors. For
this particular study, the US Crops, International Grains,
International Oilseed, International Sugar, and Interna-
tional Bio-fuels models were used.
In terms of the structure of the models, the following
identity is satisfied for each country/region and the
world.
Beginning Stock + Production + Imports
= Ending Stock -+• Consumption + Exports ( I )
Production is divided into yield and area equations,
while consumption is divided into feed and non-feed
demand. The models include behavioral equations for
area harvested, yield, crop production on the supply
side, and per-capita consumption and ending stocks on
the demand side. Equilibrium prices, quantities, and net
trade are determined by equating excess supply and
excess demand across countries and regions.
More specifically, in tenns of acreage, harvested
area is expressed as a function of own and competing
crop prices in real terms as well as lagged harvested area
and prices. Prices enter area functions either as part of
real gross returns per unit of land (price multiplied by
yield) or merely as prices, depending on the particular
commodity model. The US model, because of extensive
data availability, is divided into nine regions. The
planted area for each crop within each region depends
on expected net returns — which include real, variable
production expenses per unit of land- — for the crop and
competing crops.
To satisfy' the identity in Equation 1, two dilferent
methods are used. In most of the countries, domestic
price is modelled as a function of the world price with a
price transmission equation, and the identify is satisfied
with one of the variables set as the residual. In other
cases, prices are solved to satisfy the identity.
Brookes, Yu, Tokgoz, & Elobeid — The Production and Price Impact of Biotech Com, Canola, and Soybean Crops
200
Agricultural and trade policies in each country are
included in the models to the extent that they affect the
supply and demand decisions of the economic agents.
The models assume that the existing agricultural and
trade policy variables will remain unchanged in the out-
look period. Macroeconomic variables, such as GDP,
population, and exchange rates, are exogenous variables
that drive the projections of the model. All models are
calibrated on 2007/08 marketing year data for crops; 10-
year annual projections for supply and utilization of
commodities and prices for the US and the world are
generated for the period between 2008 and 2017. Elas-
ticity values for supply and demand responses are based
on econometric analysis and on consensus estimates.
Elasticity parameters estimates and policy variables are
available at Iowa State University’s Food and Agricul-
tural Policy Research Institute (FAPRI) website."^
Data for commodity supply and utilization are
obtained from the F.O. Lichts online database, the Food
and Agriculture Organization (FAO) of the United
Nations (FAOSTAT Online, 2006), the Production, Sup-
ply, and Distribution View (PS&D) of the US Depart-
ment of Agriculture (USDA), the European
Commission Directorate Genera! for Energy and Trans-
port, the ANFAVEA (2005), and tHMICA (2006). Supply
and utilization data include production, consumption,
net trade, and stocks. The macroeconomic data are gath-
ered from the International Monetary Fund and Global
Insight.
The empirical analysis relies on these agricultural
commodity models of the main regions of the world
(e.g., North and South America, the EU-27, etc.) to esti-
mate the impact on national, regional, and world mar-
kets and prices for cereals and oilseeds. These models
have been developed to allow for forward-looking pro-
jections (over a 10-year period) to be made relating to
production, use, trade, and prices of key commodities.
The models are not directly able to estimate the impact
of the technology on past prices (of com, soybeans, and
canola and their key derivatives). One advantage of
these models is that it is possible to establish a baseline
and then remove the impact of biotechnology on yields.
This allows the isolation of the impact on prices and
usage due to biotech crops and not due to other factors
such as macroeconomic and weather variables. How-
ever, the models do not allow for estimating the impact
on crop prices arising from changes to the cost base of
crop production (a major impact of HT technology).
4. http://ww\yjaprijasta}e.edu.'u^^^
AgBioForum. 13(1). 2010 \ 27
Some (limited) economic analysis has been previously
imdertaken to estimate the impact of biotechnology-
induced cost-of-production changes, notably on the
global prices of soybeans. Moschini, Lapan, and Sobo-
levsky ( 2000 ) estimated that by 2000 the influence of
biotech soybean technology on world prices of soybeans
had been between -0.5% and -1%, and that as adoption
levels increased this could be expected to increase up to
-6% (if all global production was biotech). Qaira and
Traxler (2002, 2005) estimated the impact of GM HT
soybean technology adoption on global soybean prices
to have been -1.9% by 2001. Based on this analysis,
they estimated that by 2005 it was likely that the world
price of soybeans may have been lower by between 2%
and 6% than it might otherwise have been in the absence
of biotechnology. This benefit will have been dissipated
through the post-fami gate supply chain, with some of
the gains having been passed onto consumers in the
fonn of lower real prices. We, therefore, acknowledge
the failure to include the potential impact of biotechnol-
ogy on costs of production and prices as a limitation of
the research, which potentially underestimates the
impact of the technology on prices. In addition, the anal-
ysis uses 2007 as the baseline against which the analysis
i,s run. This assumes that the level of biotech trait adop-
tion in 2007 represents the ‘counterfactual situation.’ In
doing so, it fails to take into account likely trends in bio-
tech trail adoption post 2007 and hence, this additional
weakness of the analysis probably contributes further to
understating the price effect of biotechnology. Despite
these methodological weaknesses, the approach used in
this article provides a useful tool for assessing the
impact of biotech traits on the prices of corn, canola,
soybeans, and derivatives of these crops on global mar-
kets.
Yield and production change assumptions for the
impact of biotech crops were used as bases for analysis
in the models by projecting forward a ‘what if’ scenario
in which the currently used biotech traits were no longer
available. The yield and production change assumptions
used were those identified in the published work of
Brookes and Barfoot (2008).^ For example, insect-resis-
tant (IR) com technology in the United States has deliv-
ered an average 5% improvement in corn yields. The
Brookes and Barfoot analysis is itself based on a litera-
ture review of impacts of biotechnology traits globally
5. Also available al htfp:/oviv%v.pgeconomics.co.uk. The specific
yield impacts used derive from Appeeidix 2 of the AgBioForum
article (2008).
Brookes, Yu, Tokgoz, & Elobeid — The ProducSon and Price Impact of S/ofec6 Com, Canola, and Soybean Crops
201
AgBioForum, 13(1). 2010 j 28
Table 1. Corn: Yield and production impact of IR traite, 1996-2006.
Cumulative
trait area (ha)
% of crop
to trait"
Average trait
imjxict on yield %
US corn-borer
resistant
351 .842,503
81,016.473
23%
35,078,44/
US corn-rootworm
resistant
As above
6,596,520
1.9%
+5.0%
+0.45
3.130,130
Canada com-borer
resistant
13,269,070
4,239,214
31.9%
+5.0%
+0.38
1,628,075
Canada corn-
rootworm resistant
As above
35,317
0.3%
+5.0%
+0.38
14,537
Argentina corn-
borer resistant
23,951,406
10,024.000
41 .9%
+7.6%
+0.49
4.862.787
Philippines corn-
borer resistant
10,082,808
247.698
2.5%
+24.1%
+0.52
127,920
South Africa corn-
borer resistant
21,909,720
2,392,000
10.9%
+14.5%
+0.43
1,034,735
Uruguay corn-
borer resistant
184,000
100,000
54.3%
+6.1%
+0.31
30,559
Spain corn-borer
resistant
4,013,343
303,656
7.6%
+7.6%
+0.72
218.132
Cumulative totals
425,252,850
104,954,778
24.7
+5.7%
+0.45
47,125,322
2006
41,751,216
20,640,503
49%
+6.7%
+0.47
9,734,898
® for consistency purposes, the total areas presented refer only to the years in which the IR traits ivere used by farmers—from 1 996
in the US and Canada, from 1998 in Spain and Argentina, from 2000 in South Africa, from 2003 in the Philippines, and from 2004 in
Uruguay. Com rootworm-resistant com has aiso been available to US farmers from 2003 and to Canadian farmers from 2004.
^ From year of first commercial planting to 2006.
^ Average of impact over years of use, as used by Brookes and Barfoot (2008).
since 1996, and details of the specific countr>' and trail-
specific studies used can be found in the references sec-
tion of this article. To analyze the impact of this yield
improvement, first a baseline is established (starting in
2008, and for the next 10 years covered by the model
projections) with the trend growth rate of yield. Then a
scenario is run where the yields were effectively lower
than the baseline level (starting in 2008 and ending in
2017). The baseline represents the current status quo
(technology used) and the scenario implies that the tech-
nology is no longer available. The difference between
the baseline and scenario represents the impact of the
technology (or more literally the impact of no longer
using the technology).
The models effectively assume the decreases in
average crop (e.g., corn) yield in the countries using GM
technology as a ‘shock' change to the various regional
parts of the models. This then calculates revised yield
values, changes in production and consumption,
changes in stocks, changes in imports and exports, and
changes in areas allocated to other crops. ‘Knock-on’
effects^ on the price of each crop (corn, soybeans, and
canola) plus effects on other crop (e.g., wheat, barley,
sunflower) were also derived, both at a regional and a
world level. Knock-on effects on derivatives of com,
soybeans, and canola are also derived.
Production and Yield Assumptions
The production and yield change assumptions used in
this analysis derive from the work of Brookes and Bar-
foot (2008), which itself draws on numerous crop and
country-level impact studies. The next section {Produc-
iron and Yield Impacts of Biotech Crops) provides a
summary of this data, and the assumptions used for the
analysis are presented in the following section {Conver-
sion of Production and Yield Impacts into Useable
Assumptions).
6. Indirect effects on the prices of derivatives as a result of
changes in the price of the base commodities (e.g.. a change
in the price of .soybeans affecting the price, ofsoynieal). Also,
the effect on prices arising from changes in production levels.
Brookes, Yu, Tokgoz, & Elobeid — The Production and Price Impact of Biotech Com, Canola, and Soybean Crops
202
AgBioForum, 13(1), 2010 \ 29
CancidR ^ US (1936 & 1999)
Crop: C.^nola +10% & 6% on
Vie'd, respectively. Pro
ion +3.2m tonnes
Romania (1999
Paraguay (1999)
Crop; Facilit;
crop soybeans.
+2, 2m tonnes
P
Philippines (2006)
'’3^rop; Corn +15% to yield
for early adopters
irgentina (1996)
Crop: FadlitaUon of 2nd crop soy-
beans; +50.9m tonnes
Crop: Corn- first used in 2005 +9%
to yield for early adopters
Figure 1. Hei1}icide-tofer3nt crops: Yield and production impact of biotechnology 1998-2006 by country.
Production and Yield Impacts of Biotech Traits
IR Corn Impacts. Two biotech IR traits have been com-
mercially used to target the common corn-boring
pests— -European com borer or ECB (Ostrinia nuhilalis)
and Mediterranean stem borer or MSB {Sesamia
nonagroides ) — and com rootworm pests (Diabrolica).
These are major pests of com crops in many parts of the
world and significantly reduce yield and crop quality,
unless crop-protection practices are employed.
The two biotech IR corn trails have delivered posi-
tive yield Impacts in all user countries when compared
to average yields derived from crops using conventional
technology (mostly application of insecticides and seed
treatments) for control of cora-boring and rootworm
pests.
The yield impact varies from an average of about
+5% in North America to +24% in the Philippines
(Table 1). In terms of additional production, on an area
basis, this is in a range of +0.31 tonnes/ha to +0.72
tonnes/Tia.
Average yield and production impact across the total
area planted to biotech IR com traits over the 11 -year
period has been +5.7% (+0.45 tonnes/ha). ITiis has
added 47 million tonnes to total com production in the
countries using the technology.
In 2006, the technology delivered an average of 0.47
tonnes/ha In extra production, which was equal to an
extra 9.7 million tonnes of com production (Table 1).
HT Soybeans. Weeds have traditionally been a signifi-
cant problem for soybean farmers, causing important
yield losses (from weed competition for light, nutrients,
and water). Most weeds in soybean crops have been rea-
sonably well controlled, based on application of a mix
of herbicides.
Although the primary impact of biotech HT technol-
ogy has been to provide more cost effective (less expen-
sive) and easier weed control versus improving yields
from better weed control (relative to weed control
obtained from conventional technology), improved
weed control has, nevertheless occurred, delivering
higher yields. Specifically, HT soybeans in Romania
improved the average yield by over 30% (Figure 1 ).
Biotech HT soybeans have also facilitated the adop-
tion of no-tillage production systems, thus shortening
the production cycle. This advantage enables many
farmers in South America to plant a crop of soybeans
immediately after a wheat crop in the same growing sea-
son. This second crop, additional to traditional soybean
production, has added 53.1 million tonnes to soybean
production in Argentina and Paraguay between 1996
and 2006. In 2006, the second-crop soybean production
in these countries was 1 1 .6 million tonnes (Table 2).
Brookes, Yu, Tokgoz, & Elobeid — The Production and Price Impact of Biotech Com, Canola, and Soybean Crops
203
AgBioForum, 13(1), 2010 \ 30
Table 2. Second crop soybean production facilitated by biotech HT technology in South America 1996-2006 (million tonnes).
Year first commercial use of.HT Second-crop soybean production from date of first
Country soybean technology commercial use to 2006
Argentina 1996 50.9
Paraguay 1999 2.2
Total 53.1
Table 3. Yield impact assumptions; To lower average yields for countries/crops assuming no biotech used from 2008
onwards.
Crop/country
Average yieid/production
effect on biotech area 2006
% of crop to trait (2006)
impact of technology related to
average yield on total crop if no longer used
Corn
US
+5%
49%
-2.45%
Canada
+5%
50%
-2.45%
Argentina
+7.6%
73%
- 5.55%
Philippines
+24.1%
4%
-0.97%
South Africa
+ 14.5%
35%
-5.1%
EU-27
+6-1% (Spain)
1 5% of Spain, 3.3 % of eU-27 area
-0.2% on EU-27 average yield
Soybeans
EU-27
+31% (Romania)
26% of EU-27 area
-8.1%
Paraguay
+7.5% second crop
7.5%
-7.5%
Argentina
+20% second crop
20%
-20%
Canola
US
6%
98%
-5.9%
Canada
+3.7%
84%
-3.1%
HT Canola. Weeds represent a significant problem for
canola growers because they contribute to reduced yield
and impair quality by contamination (e.g., with wild
mustard seeds). Conventional canola weed control is
based on a mix of herbicides, and it has provided rea-
sonable levels of control, although some resistant weeds
have developed (e.g., to the herbicide trifluralin).
Canola is also sensitive to herbicide carryover from
(herbicide) treatments in preceding crops, which can
affect yield.
The main impact of biotech HT canola technol-
ogy — used widely by canola farmers in Canada and the
United States — has been to provide more cost-effective
(less expensive) and easier weed control, coupled with
higher yields. The higher yields have arisen mainly from
more effective levels of weed control than were previ-
ously possible using conventional technology. Some
fanners have also obtained yield gains from biotech-
derived improvements in the yield potential of some HT
canola seed.
The average yield impacts have been about +6%
(+0.! tonnes/ha) in the United States and about +10%
(+0.15 tonnes/ha) in Canada (Figure 1). Over the 1996-
2006 period, the additional North American canola pro-
duction arising from the use of biotech HT technology
was 3.2 million tonnes.
HT Corn. Weeds have also been a significant problem
for corn farmers, causing important yield losses. Most
weeds in these crops have been reasonably controlled
based on application of a mix of herbicides.
The HT technology used in corn has mainly pro-
vided more cost-effective (less expensive) and easier
weed control rather than improving yields from better
weed control (relative to weed control levels obtained
from conventional technology).
Improved weed control from use of the HT technol-
ogy has, nevertheless, delivered higher yields in some
regions (Figure 1). For example, in Argentina, where
HT com was first used commercially in 2005, the aver-
age yield effect has been +9%, adding +0.36 tonnes/ha
to production. Similarly in the Philippines, (first used
commercially in 2006), early adopters are finding an
average of +15% to yields (+0.72 tonnes/ha).
Brookes, Yu, Tokgoz, & Elobeid — The Production and Price Impact of Biotech Com. Canola, and Soybean Crops
204
AgBioForum. 13(1), 2010 1 31
Figure 2. Increase in world commodity prices if biotech traits are no longer used.
Conversion of Production and Yield Impacts
into Usable Assumptions
To provide suitable assumptions for input into the agri-
cultural commodity models, the production and yield
impacts summarized in the above section (Production
and Yield Impacts of Biotech Trails) were converted
into national-level yield equivalents. These are pre-
sented in Table 3. These yield change assumptions were
then introduced into the models to identify impacts of
withdrawing the (bio) technology from production sys-
tems and hence indirectly identify the impact of the bio-
tech traits to date. The results are presented next.
Impact of Biotech Traits on Prices,
Production, Consumption, and Trade in the
Cereals and Oilseeds Sectors
World Level
Prices. The running of the agricultural commodity mod-
els under the ‘no biotech traits’ scenario suggests that
the impact that these productivity-enhancing biotech
traits in corn, soybeans, and canola have had on world
prices of both these crops/derivatives and other cereals
and oilseeds is significant. We consider the no-biotech
scenario as a deviation from the 2007 baseline. In the
scenario, the yield shocks are fully implemented from
2008 through 2017. We report the average of these
annua! changes for the years 2008-2010 as a summary
indicator of the short term impacts. The scenario run
shows that if these traits were no longer used in global
agriculture, the loss of the yield and production-enhanc-
ing capabilities of the technology w'ould result in world
prices of com, soybeans, and canola increasing by
-r5.8%, +9.6%, and +3.8%, respectively (Figure 2).
There would also be knock-on effects on the prices of
derivatives (e.g., a +9% increase in the world price of
soymeal and a +5% increase in the price of soy oil) and
other cereals and oilseeds (e.g., increases in prices of
+2.7% to +4.2% of wheat, barley, and sorghum). In
response to the decline in yields of com, soybean, and
canola, the production of these crops decline and their
prices increase. This leads to area reallocation away
from wheat, thus increasing its price-— though less of an
increase relative to corn, soybean, and canola prices.
Ciiven the limitations of the analysis (in not Including an
examination of the impact of the cost-reducing impact
of the technology), these estimates of the impact on crop
prices are probably understated. Additional information
is presented in Appendices B and C to help readers fol-
low how the summary values presented in this section
were derived.
In monetary ($ terms). Figure 3 shows the impacts of
these price increases relative to the average 2007/08
world price levels.^
7. The impacts presented in Appendix B show the price increases
relative to the baseline price levels (a\’erage of 2008 through
2010) and are therefore marginally different from the changes
presented in Figure 3. which relate !o actual 2007/08 average
prices. Appendix C summarizes the 2007/08 data used as the
base for this figure.
Brookes, Yu, Tokgoz, & Elobeid — The Production and Price Impact of Biotech Com, Canola, and Soybean Crops
205
AgBioForum, 13(1), 2010 j 32
Figure 3. Increase in world commodity prices if biotech traits are no longer used ($/tonne).
Table 4. Global consumption of key commodities/derivatives 2007-08 and impact of price changes.
Consumption
(million tonnes)
Cost of consumption
Additional cost of consumption If biotech
traits no longer avaitablo ($ billion*
Corn
776.80
169.3
9'.82
Wheat
618.10
194.1
5.24
Barley
136.30
33.0
1.09
Sorghum
63.28
18.9
0.79
Soymea!
157.09
49.3
4.39
Soy oil
37.40
43.1
2.24
Canola mea!
27.12
8.1
0.32
Canola oil
18,34
25-9
0.72
Sunflower meal
10.43
2.0
0.07
Sunflower oil
9.41
15,4
0.26
Total
1,8S4.00
559.1
24.94
Sources: Baseline data from USDA Market & Trade reports. Prices based on import/export levels using mainsti^am ports of trade
(USDA). These consumption figures (see Appendix C) differ marginally from the consumption values used In the model baseline
presented in Appendix 8 because they are based on more recent (updated) values to those originally input into the models.
Relating these price changes to global consumption, income gains associated with adoption of the technol-
this is equivalent to adding S25 billion (+4.5%) to the ogy for those farmers who have used biotech traits. The
total cost of consumption of these crops/derivatives in direct farm-income gain identified from adoption of bio-
2007/08 (Table 4). The sectors most affected would be tech traits over the period 1996-2006 was $33.8 billion
the com- and soybean/derivative-using sectors, although (Brookes & Barfoot, 2008); this income gain was calcu-
there would also be a significant knock-on effect in the lated net (inclusive) of the price effects identified above
wheat sector. by using current farm-level prices for each crop, coun-
In teims of income, it is important to recognize that try, and year. In contrast, those farmers who have chosen
the productivity-enhancing technology has already had to not adopt the technology or been denied access to the
an impact on producer (farmer) incomes. The downward technology (e.g., on political or regulatory grounds)
world price effects of the technology identified above have experienced the negative price effect but not
represent a loss to farmer incomes but a gain to consum- gained from the yield gains and cost savings associated
ers. The negative price effects at the producer level with using the technology,
have, though, been more than offset by the direct
Brookes. Yu, Tokgoz, & Elobeid — The Production and Price Impact of Biotech Com. Canola, and Soybean Crops
206
Table 5. Potential change to global production base if bio-
tech traits are no longer used.
j
Soybeans
+2.27 (+2.5%)
-0.11 (-4.3%)
-4.36 (-2%)
Canola
+0.11 (+0.4%) -0-01 (-0.65%)
-0.14 (-0.3%)
Soymeal
n/a
n/a
-2.69 (-1.7%)
Soy oil
n/a
n/a
-0.67 (-1.8%)
Canola/
n/a
n/a
-0.03 (-0.1%)
rape meal
Canola/
n/a
n/a
-0.04 (-0.2%)
rape oil
Notes: n/a = not applicable. Baseline for these changes are
2007/08 values. These are marginally different to the model
baseline values presented in Appendix B.
Production, Trade and Consumption Impacts. The
effect of no ionger using the current biotech traits in the
corn, soybean, and canola sectors will have an impact
on both the supply and utilization of these crops, their
derivatives, and related markets for grain and oilseeds.
By taking away the positive yield and production
impacts of the technology from the areas planted to
these traits, the negative impacts would be felt most in
the current-user (technology) countries (see Production
and Yield Assumptions section). At the global level, the
model analysis suggests that the negative impacts on the
yields of the three crops are equal to an average reduc-
tion of 1.5%, 4.3%, and 0.65%, respectively, for com,
soybeans, and canola (Table 5).
The dynamic effect on subsequent plantings and the
production base would result in a projected increase in
the total area planted to these three crops of Just under 3
million hectares, although this 'compensatory' addi-
tional planting would not offset the yield-reduction
effects of no longer using biotech traits, resulting in a
net fall in global production of the three crops of 14 mil-
lion tonnes. In respect of the key oilseed derivatives of
meal and oil, the reduction in the supply of the base seed
(soybeans and rapeseed) would result in knock-on falls
in global production of soymeal (1.7%), soy oil (1.8%),
rapenieal (0.1%), and rape oil (0.2%). The total reduc-
tion in supply of these crops and key derivatives of meal
and oil is projected to be 17.4 million tonnes.
The change in the supply availability of these three
crops and the resulting upward effect on prices is fore-
cast lo lead to falls in global trade of these crops/deriva-
tives. The modelling suggests that world trade in these
crops/derivatives would fall by about 6.6 million tonnes.
AgBioForum, 13(1), 2010 [ 33
Table 6. Potential global changes to other grains and oil-
seeds if biotech traite are no longer used.
Production
(million tonnes)
Consumption
(million tonnes)
Wheat
-0.61 (-0.1%)
0.09 (0.01%)
Barley
Nil
+0.10 (+0.07%)
Sorghum
+0.32 (+0.5%)
+0-36 (+0.57%)
Sunfto>A«r meal
Nil
+0,02 (+0-2%)
Sunflower oil
Nil
+0.02 (+0.2%)
of which the main changes would be decreased trade
volume of 3.2 million tonnes, 1.65 million tonnes, and
1.24 million tonnes for com, soymeal, and soybeans,
respectively.
ITie model also predicts annual decreases in global
consumption of these commodities and derivatives of
14.25 million tonnes. The main decreases in consump-
tion would be for com (8.07 million tonnes: a 0.98%
decrease), soymeal (2.67 million tonnes: 1.7%
decrease), and soy oil (0.64 million tonnes: a 1.7%
decrease). Change in global consumption of canola/
rapeseed derivatives would be marginal.
The analysis also identifies impacts on related grain
and oilseed sectors. In addition to the impact on prices
(see IR Corn Impacts section), the production and con-
sumption of grains such as wheat, barley, sorghum, and
oilseeds, notably sunflower, would be affected (Table
6). The global production of wheat is projected to fall by
0.1%, while the production of sorghum would increase
by 0.5%. The decline In wheat production is due to area
reallocation away from wheat towards crops such as
com, soybean, and canola, which experienced price
increases after a yield decline when biotechnology was
no longer available. This is in part due to the impact of
looking only at the yield impacts of biotech crops, but
not at the lower production cost advantages brought
about by biotech. In relation to global consumption, this
is projected to fall for wheat but increase for barley, sor-
ghum, sunflower meal, and oil.
Taking both the impacts on the three directly
affected sectors of com, soybeans, canola, and related
grains and oilseeds, the net impacts of existing biotech
traits (if no longer used in global agriculture) are an
additional 2.64 million hectares of land being brought
into grain and oilseed production. Despite this increase
in total planted area, net production of these grains and
oilseeds (excluding derivatives) w'ould fall by 14.3 mil-
lion tonnes. Inclusive of the main oilseed derivatives
(including sunflower), net production is forecast to fall
by 17,7 million tonnes. World trade in these commodi-
Brookes, Yu, Tokgoz, & Elobeid — The Produedon and Price Impact of Biotech Com, Canola, and Soybean Crops
207
AgBioForum, 13(1), 2010 ( 34
Table 7. Potential change to the US production base if biotech traits are no longer used (% change).
Area
Average- yield
Production
Net trade (net exporte)
Corn
-0.8%
- 2 . 5 %
-3%
-10%
Soybeans
+3.6%
0 %
+3.4%
+14%
Canola
+0.2%
- 5 . 9 %
-5.7%
-10%
Table 8. Potential change to the Argentine production base if biotech traits are no
longer used (% change).
Area
Averageyield
Production
Net trade (net export)
Corn
+1.6%
-4-6%
-3.1%
-3.9%
Soybeans
-18-5% (inclusive of loss of second-crcH? soy)
- 0 %
-18.8%
-81%
Soymeal
n/a
n/a
-7%
-7%
Soy oil
n/a
n/a
-7%
-8%
Note: n/a = not applicable. The model results presented in Appendix B differ from the changes presented in this table because the
model inputs the loss of second-crop soybeans as a yield deaease. The effects presented in this table therefore adjust the negative
yield effect used in the modelling to an area change which is projected to be a 1.5% increase in first-crop soybean plantings, relative
to a 20% decrease in second-crop soybeans.
ties and derivatives would also fall (by 6.6 million
tonnes) and global consumption of these grains and oil-
seed derivatives is forecast to fall by 15.4 million
tonnes. Lastly, the model estimates that the cost of
global consumption of these crops and derivatives
would increase by $20 billion (3.6%) relative to the total
cost of consumption of the (higher) biotech-inclusive
level of world consumption. In unit temis, the average
cost of consumption would increase by about 4.6% from
an average of $301 /tonne to $3 l5/lonne.
Country Level
This section discusses the impact at the global level on
specific countries and regions of the world of biotech
traits no longer being available.
US. If existing biotech traits were no longer available to
farmers globally (including US farmers), the impact in
the affected US cropping sectors would be significant
(Table 7). The model analysis points to production of
US coni and canola failing by 3% (10.8 million tonnes)
and 5.7% (50,000 tonnes), respectively, mainly due to
reduced yields (loss of yield-enhancing nature of the
biotech traits). Soybean production, however, would
potentially increase by 2.4 million tonnes due to
increased plantings of soybeans (the yield losses to com
improving the relative competitive position of soybeans
at the farm level).
Trade effects would be similar to the production
impacts, with decreases in the volumes of exported com
and canola of about 10%. Soybean exports, however,
would potentially increase significantly due to the addi-
tional production. The model also forecasts knock-on
effects in other sectors; plantings of wheat and soi^hum
would be expected to fall, resulting in decreased produc-
tion of these crops (0.6% for wheat and 0.5% for sor-
ghum). In contrast, plantings and production of barley
are expected to increase by 1.1%. Lastly, domestic US
consumption of com, soybeans, and canola is expected
to fall by 2%, 0.5%, and 2%, respectively (caused by the
higher price; see Prices section).
Arffentina. The effect of no longer using biotech traits
globally in the Argentine com and soybean sectors is
summarized in Table 8. Production of corn is forecast to
fall by 3.1% (about 0.7 million tonnes) due to reduced
yields (loss of yield-enhancing nature of the biotech
trails). Output of soybeans is predicted to fall more sig-
nificantly because of the negative effect on second-crop
soybeans, which accounted for 20%-plus of the total
Argentine soybean crop in 2006 (GM HT technology
having contributed to shortening the production cycle
for soybeans allowing many famters to plant a crop of
soybeans after wheat in the same .season). As such, no
longer having access to this technology would poten-
tially threaten plantings of second-crop soy, resulting in
a significant fall in total soybean production (equal to
almost 9 million tonnes).
The declines in production of soybeans and corn
would have an important negative impact on the wider
Argentine economy. Domestic consumption of both
corn and soybeans is forecast to fall by about 1% and
7%, respectively (due to reduced availability and higher
prices). More importantly, the reduced levels of produc-
tion would result in decreased volumes available for
export, especially in the soybean and derivative sectors.
Given that soybean exports have contributed and will
continue to contribute tax revenues to the Argentine
Brookes, Yu, Tokgoz. & Elobeid — The Productiem and Price Impact of Biotech Com, Canola, and Soybean Crops
208
Table 9. Potential change to the Canadian production ba^
if biotech traits are no longer used (% change).
Ncttrad^
Area
Average
yield
Production
(not
exports)
Soybeans
+2.2%
0%
+2.2%
+8.8%
Canola
+0.2%
-3.1%
-2.9%
-1.5%
Soymeal
n/a
n/a
-1.8%
-3.3%
Soy oil
n/a
n/a
-1.8%
-3.3%
Canola/
rape meal
n/a
n/a
-5.3%
-6.8%
Canola/
rape oil
n/a
n/a
-5.3%
-6.8%
Wheat
-0.14%
0%
-0-14%
0.13%
Note: n/a = not applicable
Exchequer, this would result in important cuts in gov-
ernment tax revenues. Lastly, the modelling results sug-
gest that production of other cereals, notably wheat and
barley, would potentially increase by over 1% due to
increased plantings of these crops.
Canada. The estimated impact of no longer making
available the existing biotech traits in the global com,
soybean, and canola markets on the relevant Canadian
cropping sectors is summarized in Table 9. Production
of com and canola is forecast to fall by more than 2%
(0.3 million tonnes for com and 0.3 million tonnes of
canola) due to reduced yields (loss of yield-enhancing
nature of the biotech traits). Soybean production, how-
ever, would likely increase (by more than 2%) because
of increased plantings (as in the United States, the yield
losses to com improving the relative competitive posi-
tion of soybeans at the farm level). The model predicts
that domestic consumption and use of all three com-
modities and derivatives would fall (by more than 4%
for both soybeans and canola and by about 1% for corn)
due to higher prices (see World Level section). Canada, a
net importer of corn, increases its net imports because of
the decline in production. Exports of soybeans, how-
ever, would potentially increase as decreased domestic
consumption results in additional volumes becoming
available for export. In contrast, exports of canola and
derivatives would be expected to fall- -exports being a
major outlet for Canadian canola relative to domestic
consumption; hence, any additional supplies available
for export from reduced domestic consumption would
be more than offset by the fall in production associated
with the withdrawal of biotech traits. The changes in
biotech crops also impact the other crop markets. With
AgBioForum, 13(1). 2010 | 35
the increase in com prices, wheat area in Canada
declines as area shifts away from wheat to com. This
increases wheat prices and thus domestic use of wheat
declines. Net exports of wheat in Canada increase since
domestic use declines more than domestic supply
because of the relatively larger decline in stocks of
wheat.
South Africa and the Philippines — Corn Sector. Both
these countries currently use biotech IR technology in
their com sectors. Consequently, if this technology was
no longer available to these and all farmers globally,
there would be important negative impacts for those
farmers who currently use the technology. At the
national level in South Africa, average corn yields
would be expected to fall by more than 5%, resulting in
a net 5.5% reduction in total corn production.^ In the
Philippines, where adoption of biotech IR corn traits is
more recent — and hence less widespread than in South
Africa (5% of total crop compared to 63% of the total
com crop in South Africa) — the national-level Impacts
are an average decrease in corn yield of 1% and produc-
tion falling by about 0.5%.^
The modelling results suggest that domestic con-
sumption of com is also expected to fall by more than
1 .5% in both countries (due to higher prices of corn). In
terms of net trade, imports in the Philippines would
increase by about 0.1 million tonnes (50%), while in
South Africa, exports (of corn) would fall by nearly
30% (about 0.45 million tonnes).
The European Union. There were two biotech traits in
use commercially in EU-27 countries of relevance dur-
ing the 1998-2006 period: IR com in several member
states and HT soybeans in Romania. The modelling
analysis identifies negative impacts of no longer using
these lechnologie.s (both in the EU and globally).'^’
Average EU-27 com yields and production would be
expected to fall marginally (by 0.2%)J® while both con-
8. Area planted is projected to fall by 0.5%.
9. .Area planted is projected to increase by 0. 7%.
10. The removal of access to this technology has. in fact, occurred
in relation to herbicide tolerant soybeans in Romania, which
joined the EU in 2007. and hence, had to adopt EU regula-
tions relating to biotechnology the planting of biotech herbi-
cide tolerant soybeans is currentiv not permitted in the EU-
27.
11. Readers should note that biotech IR corn was planted on
about 0.1 million hectares in the EU-27 in 2007. equal to
1.3% of total EU-27 corn planting.
Brookes, Yu, Tokgoz, & Elobeid — The Production and Price Impact of Biotech Com, Canola, and Soybean Crops
209
sumption and net trade (imports) of com would fall by
0.3% and 1.2%, respectively (negative effect of higher
world prices for corn). Average soybean yields across
the EU would also be expected to fall by -3.2%, and
production would be lower by - 1 .3% due to the negative
effect on yields and production of soybeans in the
important EU soybean-producing country of Romania.
This reduced supply of domestic soybeans is forecast to
result in reductions in the EU production of soyraeal and
soy oil (by 1.1%). Usage of soymeal and soy oil is also
forecast to fail by 2.6% and 1.4%, respectively (due to
higher world prices).
Conclusions
This study quantified, through the use of agricultural
commodity models, the impact of biotech traits on pro-
duction, usage, trade, and prices in the com, soybean,
and canola sectors. The previous analysis (Brookes &
Barfoot, 2008) estimated that biotech crops, through the
two main traits of insect resistance and herbicide toler-
ance have, during the 1996-2006 period, added 53.3
million tonnes and 47.1 million tonnes, respectively, to
global production of soybeans and com. Tlie technology
has also contributed an extra 3.2 million tonnes of
canola.
The estimated impact of these additional volumes of
production on markets and prices in the cereals and oil-
seeds sectors has been significant. Our modelling analy-
sis of the potential impact of no longer using these traits
in world agriculture shows that the world prices of these
commodities, their key derivatives, and related cereal
and oilseed crops would be significantly affected. World
prices of com, soybeans, and canola would probably be
respectively 5.8%, 9.6%, and 3.8% higher than the base-
line 2007 levels (when the technology was available for
the analysis purposes). Prices of key derivatives of soy-
beans (meal and oil) would also be between 5% (oil)
and 9% (meal) higher than the baseline levels, with
rapeseed meal and oil prices being about 4 % higher than
baseline levels. World prices of related cereals and oil-
seeds would also be expected to rise by 3-4%.
The effect of no longer using the current biotech
traits in the com, soybean, and canola sectors would
also impact both the supply and utilization of these
crops, their derivatives, and related markets for grain
and oilseeds. Average global yields are estimated to fall
by 1.5%, 4.3%, and 0.65% for com, soybeans, and
canola, respectively. While there is likely to be some
‘compensatory' additional plantings (of just under 3
million hectares) of these three crops, this would not
AgBioForum, 13(1), 2010 \ 36
offset the yield-reduction effects of no longer using bio-
tech traits, thus resulting in a net fall in global produc-
tion of the three crops of 14 million tonnes. The
modelling also suggests that a fall in the supply avail-
ability of these three crops and the resulting upward
effect on prices would lead to a projected decrease in
global trade of these crops/derivatives of 6.6 million
tonnes, a 1.4% decrease in corn usage and a 1.7%
decrease in usage of soymeal and soy oil (changes in
global consumption of canolaTapeseed derivatives
would be marginal).
The production and consumption of grains such as
wheat, barley, and sorghum and oilseeds, notably sun-
flower, would also be affected (e.g., the global produc-
tion and consumption of wheat would fall by 0.1% and
0.01%, respectively).
Overall, the net impacts of existing biotech traits (if
no longer used) in global agriculture are that an addi-
tional 2.64 million hectares of land would probably be
brought into grain and oilseed production. Despite this,
net production of grains and oilseeds (including deriva-
tives) would potentially fall by 17.7 million tonnes’^
and global consumption would potentially fall by 15.4
million tonnes. The cost of consumption would also
increase by S20 billion (3.6%) relative to the total cost
of consumption of the (higher) biotech-inclusive level
of world consumption. In unit temis, the net cost of con-
sumption would increase by about 4.6%.
The impacts identified in this analysis are probably
conservative, reflecting the limitations of the methodol-
ogy used to estimate the productivity-enhancing effects
of biotech traits so far used in global agriculture. In par-
ticular, the limited research conducted to date into the
impact of the cost-reducing effect of biotechnology
(notably in HT soybeans) on prices and the assumption
of using 2007 levels of biotech adoption as the ‘counter-
factual’ position suggests that the price effects identified
in this article represent only part of the total price
impact of the technology. Subsequent research might
usefully extend this analysis to incorporate consider-
ation of the cost-reducing effect of the technology (espe-
cially HT technology), a more dynamic counterfactual
position, and to examination of the cotton sector.
References
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prospective adoption of genetically modified cotton: A global
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12. Sum of Tables 5 and 6.
Brookes, Yu, Tokgoz, & Elobeid — The Producbon artd Price Impact of Biotech Com, Canola, and Soybean Crops
210
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Appendix A: Agricultural Modelling
System-Methodological Details
General Description of the Modelling System
This study uses part of a broad modelling system of
world agricultural economy comprised of US and inter-
AgBioForum, 13(1). 2010 \ 37
national multi-market, partial-equilibrium models. The
models are econometric and simulation models covering
all major temperate crops, sugar, ethanol and bio-diesel,
dairy, and livestock and meat products for all major pro-
ducing and consuming countries and calibrated on most
recently available data. A Rest-of-the- World aggregate
is included to close the models. Table Al presents a
detailed list of commodity and country coverage. E.xten-
sive market linkages exist in these models, reflecting
derived demand for feed in livestock and dairy sectors,
competition for land in production, and consumer sub-
stitution possibilities for close substitutes such as vege-
table oils and meat types.
The models capture the biological, technical, and
economic relationships among key variables within a
particular commodity and across commodities. They are
based on historical data analysis, current academic
research, and a reliance on accepted economic, agro-
nomic, and biological relationships in agricultural pro-
duction and markets. A link is made through prices and
net trade equations between the US and international
models. The models are used to establish commodity
projections for a baseline and for policy analysis, and
are used extensively for the market outlook and policy
analysis. This set of agricultural models have been used
in a number of studies including Eiobeid et al. (2007),
Fabiosa et ai. (2005, 2007), and Tokgoz et al. (2008).
In general, for each commodity sector, the economic
relationship that supply equals demand is maintained by
determining a market-clearing price for the commodity.
In countries where domestic prices are not solved
endogenously, these prices are modelled as a function of
the world price using a price transmission equation.
Since econometric models for each sector can be linked,
changes in one commodity sector will impact other sec-
tors. A detailed description of the models is available on
Iowa State University’s FAPRI website. Figure Al
provides a diagram of the overall modelling system. For
this particular study, the US Crops, International Grains,
International Oilseed, International Sugar, and Interna-
tional Bio-fuels models were used.
More specifically in terms of the structure of the
models, the following identity i.s satisfied for each coun-
try/region and the world:
Beginning Stock + Production f Imports “ End-
ing Stock + Consumption + Exports
13. http:/.HvwwfaprUastate.edu/models'
Brookes, Yu, Tokgoz. & Eiobeid — The Production and Price Impact of Biotech Com, Canola, and Soybean Crops
211
AgBloForum. 13(1), 2010 j 38
Table A1. Model inputs and output.
Commoditios
Major countrics/regions
Exogenoub inpulb
Grains
North America
Pt^ulatfon
Production
World prices
Corn
United States,
GDP
Consumption
Domestic prices
Wheat
Canada, Mexico
GDP deflator
Exports
Production
Sorghum
Exchange rate
Imports
Consumption
Barley
South America
PoptflaUon
Ending stocks
Net trade
Brazil, Argentina, Colombia.
Policy variables
Domestic prices
Stocks
Oilseeds
Soybeans
Rapeseed
Sunflower
Sugar
Biofuels
Ethanol
Biodiesel
etc-
Asia
China, Japan, India,
Indonesia. Malaysia, etc.
Africa
South Africa, Egypt, etc.
European Union
World prices
Area harvested
Yield
Oceania
Australia
Middle East
Iran, Saudi Arabia, etc.
Rest of the World
Figure A1. Model interactions: Trade, prices and physical flows.
Production is divided into yield and area equations,
while consumption is divided into feed and non-feed
demand. The models include behavioral equations for
area harvested, yield, crop production on the supply
side, and per-capita consumption and ending stocks on
the demand side. Equilibrium prices, quantities, and net
trade are determined by equating excess supply and
excess demand across countries and regions. To satisfy
the identity in Equation 1, two different methods are
used. In most of the countries, domestic price is mod-
elled as a function of the world price with a price trans-
mission equation, and the identity is satisfied with one
of the variables set as the residual. In other cases, prices
are solved to satisfy the identity.
Agricultural and trade policies in each country are
included in the models to the extent that they affect the
Brookes, Yu. Tokgoz, & Elobeid — The Production and Price Impact of Biotech Com, Canola, and Soybean Crops
212
supply and demand decisions of the economic agents.
Examples of these include taxes on exports and imports,
tariffs, tariff rate quotas, export subsidies, intervention
prices, and set-aside rates. The models assume that the
existing agricultural and trade policy variables will
remain unchanged in the outlook period. Macroeco-
nomic variables, such as GDP, population, and exchange
rates, eire exogenous variables that drive the projections
of the model. The models also include an adjustment for
marketing-year differences by including a residua! that
is equal to world exports minus world imports, which
ensures that world demand equals world supply.
.411 models are calibrated on 2007/08 marketing year
data for crops and 2007 calendar year data for livestock
and biofuels, and 10-year projections for supply and uti-
lization of commodities and prices are generated for the
period between 2008 and 2017. The models also adjust
for marketing-year differences by including a residual
that is equal to world exports minus world imports,
which ensures that world demand equals world supply.
AgBioForum, 13(1), 2010 j 39
Elasticity values for supply and demand responses are
based on econometric analysis and on consensus esti-
mates. Elasticity parameters estimates and policy vari-
ables are available in Iowa State University's FAPRFs
Elasticity Database.*'*
Data for commodity supply and utilization are
obtained from the F.O. Lichts online database, the Food
and Agriculture Organization (FAO) of the United
Nations (FAOSTAT Online, 2006), the Production, Sup-
ply and Distribution View (PS&D) of the US Depart-
ment of Agriculture (USDA), the European
Commission Directorate General for Energy and Trans-
port, the ANFAVEA (2005), and UNICA (2006). Supply
and utilization data include production, consumption,
net trade, and stocks. The macroeconomic data are gath-
ered from the International Monetary Fund and Global
Insight.
14. http:/-''M'ww.fapn.iasia!e.edii'tooIs'
Appendix B. Scenario Results
Table B1. Wheat prices.
0®09 J
1W11
12rt3 1
13/14
14/15
15/16
16/17
17/18
US FOB Gulf
(US dollars per metric ton)
Baseline
251.95
252,04
258.65
257.80
261.80
264.06
266.98
270.41
272.93
273.75
Scenario 1
255.89
260.37
267.10
264.47
268.57
271.17
273.74
276.99
279.76
280,78
% change
1.56%
3.31%
3.27%
2.58%
2.59%
2,69%
2.53%
2,43%
2,50%
2,57%
Canadian Wheat Board
Baseline
262.60
262.06
267.48
266.15
269.33
270.37
271.87
274.00
275,66
276.48
Scenario 1
265.99
269.20
274.65
271.77
275.07
276.40
277,61
279.59
281.47
282.47
% change
1,29%
2.73%
2.68%
2.11%
2.13%
2-23%
2.11%
2.04%
2,11%
2.16%
AWB limited export quote
Baseline
252,70
251,43
257.05
256-47
259.85
261.86
264.39
267.37
269.58
270,34
Scenario 1
256.04
258.60
264,41
262.32
265.75
268.04
270,28
273.11
275-53
276.45
% change
1.32%
2.85%
2.86%
2,28%
2.27%
2.36%
2.23%
2.15%
2.21%
2.26%
European Union market
Baseline
270,66
252.49
241.79
237,26
231.78
230.18
231.70
233,38
235,10
236.16
Scenario 1
274,11
255.21
244.21
239.81
234.39
232.74
234.34
236,12
237.94
239.14
% change
1 ,27%
1 ,08%
1.00%
1.08%
1-13%
1.11%
1-14%
1,17%
1-21%
1.26%
Brookes, Yu, Tokgoz, & Elobeid — The ProducVon and Price Impact of Biotech Com, Canola, and Soybean Crops
213
AgBioForum, 13(1), 2010 \ 40
Table B2. Wheat prices.
08/09
09/10
10/11
11/12
,12/13
14/15
15/16
16/17
17/18
US FOB Gulf
(US doitai^ per metric ton)
Baseline
251.95
252.04
258.65
257.80
261.80
264.06
266,98
270.41
272.93
273-75
Scenario 1
255,89
260.37
267.10
264.47
268.57
271.17
273.74
276.99
279,76
280.78
% change
1.56%
3.31%
3.27%
2.58%
2.59%
2.69%
2.53%
2-43%
2,50%
2.57%
Canadian Wheat Board
Baseline
262.60
262.06
267.48
266.15
269.33
270.37
271.87
274.00
275.66
276,48
Scenario 1
265.99
269.20
274.65
271.77
275.07
276.40
277.61
279,59
281.47
282.47
% change
1.29%
2.73%
2.68%
2.11%
2.13%
2,23%
2.11%
2.04%
2.11%
2,16%
AWB limited export quote
Baseline
252.70
251.43
257.05
256.47
259.85
261.86
264.39
267.37
269.58
270-34
Scenario 1
256.04
258.60
264.41
262,32
265.75
268.04
270.28
273.11
275.53
276,45
% change
1.32%
2.85%
2.86%
2.28%
2.27%
2.36%
2.23%
2.15%
2.21%
2.26%
European Union market
Baseline
270.66
252,49
241,79
237.26
231.78
230.18
231.70
233.38
235.10
236.16
Scenario 1
274.11
255.21
244.21
239.81
234.39
232.74
234.34
236.12
237.94
239.14
% change
1.27%
1 ,08%
1.00%
1.08%
1.13%
1.11%
1.14%
1.17%
1.21%
1.26%
Table B3. World wheat supply and utilization.
08/09
09/10
10/11
11/12
13/14
i4/is;
tSIB
16/17
17/18
Area harvested
(Thousand hectares)
Baseline
222.149
221.970
219.530
220,580
220.862
220.987
221,245
221,363
221,426
221,668
Scenario 1
222,096
221,555
219.352
220,685
220,838
220,943
221,229
221,338
221,386
221,626
% change
-0,02%
-0,19%
-0.08%
0.05%
-0.01%
-0.02%
-0,01%
-0.01%
-0.02%
-0.02%
Yield
(Metric tons per hectare)
Baseline
2.92
2.93
2,96
2.98
3.00
3.03
3.05
3,07
3.10
3.12
Scenario 1
2,92
2.93
2,96
2.98
3.00
3.03
3.05
3,07
3,10
3.12
% change
-0,02%
0.00%
0.01%
0.00%
0.00%
0,00%
0,00%
0.00%
0.00%
0,00%
Production
(Thousand metric tons)
Baseline
648,567
650.692
649,049
657.034
662.973
668,541
674,503
680,056
685,459
691,360
Scenario 1
648,294
649,468
648,582
657.345
662,873
668.398
674,438
679,951
685,304
691,199
% change
-0.04%
-0.19%
-0.07%
0.05%
-0.02%
-0.02%
-0.01%
-0,02%
-0.02%
-0.02%
Beginning stocks
Baseline
111.043
128,080
133,956
134,678
136.261
137,314
138,218
138,988
139,655
140,416
Scenario 1
111,043
127,138
131,963
132,452
134.419
135,564
136,444
137,304
138,047
138,804
% change
0.00%
-0,74%
-1.49%
-1.65%
-1.35%
-1,27%
-1,28%
-1.21%
-1,15%
-1.15%
Domestic supply
Baseline
759,610
778.772
783,005
791.712
799.235
805.854
812,720
819,044
825,114
831,777
Scenario 1
759,337
776,605
780,545
789.797
797.292
803.962
810.882
817,254
823,350
830,003
% change
-0.04%
-0.28%
-0.31%
-0.24%
-0.24%
-0.23%
-0.23%
-0.22%
-0.21%
-0-21%
Feed use
Baseline
106,204
110,104
110,389
111,272
112,283
112,932
113,533
114,211
114,658
115,137
Scenario 1
106,652
110,543
110,836
111,712
112,657
113.336
113,921
114,568
115,024
115,514
% change
0.42%
0,40%
0,41%
0.40%
0.33%
0.36%
0,34%
0,31%
0.32%
0.33%
Food and other
Baseline
525,325
534,712
537,938
544.178
549,639
554.705
560,199
565,178
570,040
575,047
Brookes. Yu, Tokgoz, & Elobeid — The ProducUon and Price Impact of Biotech Com, Canola, and Soybean Crops
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AgBioForum, 13(1), 2010 i 41
Table B3. World wheat supply and utilization.
Scenario 1
525,547
534,099
537,258
543.666
549,071
554,181
559.657
564,640
569,522
574,524
% change
0.04%
-0.11%
-0.13%
-0.09%
-0.10%
-0.09%
-0,10%
-0.10%
-0-09%
-0.09%
Ending stocks
Baseline
128,080
133,956
134,678
136,261
137.314
138,218
138,988
139,655
140.416
141593
Scenario 1
127,138
131.963
132,452
134,419
135,564
136,444
137,304
138,047
138,804
139,965
% change
-0.74%
-1.49%
-1.65%
-1.35%
-1.27%
-1.28%
-1.21%
-115%
-1.15%
-115%
Domestic use
Baseline
759.610
778,772
783,005
791,712
799,235
805,854
812.720
819,044
825,114
831777
Scenario 1
759,337
776,605
780,545
789.797
797,292
803,962
810,882
817,254
823,350
830,003
% change
-0.04%
-0.28%
-0.31%
-0.24%
-0.24%
-0.23%
-0.23%
-0.22%
-0.21%
-0.21%
Trade *
Baseline
89,343
94,120
94,202
95,988
98,715
100.937
103,167
105,148
106,888
108,747
Scenario 1
89,429
94,198
94,095
95,910
98,588
100,845
103,045
105,056
106,839
108,694
% change
0.10%
0.08%
-0.11%
-0.08%
-0.13%
-0.09%
-0,12%
-0.09%
-0.05%
-0.05%
Stocks-to-use ratio
(Percent)
Baseline
20.28
20.77
20,77
20.79
20.74
20.70
20.63
20.56
20,51
20.52
Scenario 1
20.11
20.47
20.44
20,51
20.49
20.44
20,38
20,32
20.28
20.28
% change
-0-84%
-1.46%
-1,62%
-1.34%
-1.25%
-1.27%
-1,19%
-1.13%
-1.13%
-113%
* Excludes international trade
Table B4. Coarse gram prices.
08/09
09/10
10/11
12/13
13/14
14/15
le/iT
1718
Com (FOB Gulf)
(US dollars per metric ton)
Baseline
196
216
209
209
215
215
217
221
221
220
Scenario 1
206
229
222
219
226
226
227
231
231
231
% change
4.97%
6.32%
6.08%
4,89%
4,80%
5.17%
4,73%
4,51%
4.78%
4.94%
Sorghum (FOB Gulf)
Baseline
175
191
183
184
189
188
191
194
195
195
Scenario 1
181
199
192
191
196
195
197
201
202
202
% change
3.64%
4,60%
4.49%
3.50%
3.56%
3,87%
3.47%
3.36%
3.61%
3.71%
Barley (Canada feed)
Baseline
146
153
153
154
158
161
164
169
172
175
Scenario 1
149
159
159
159
162
166
169
173
177
180
% change
2-16%
3,87%
3.89%
3.21%
2,96%
3.14%
2.95%
2,71%
2.78%
2.85%
Com (EU)
Baseline
259,24
234,42
224.72
221,50
217.38
215.39
216.36
217,33
217.60
217.06
Scenario 1
264.28
238.93
228.88
225.46
221.36
219.47
220.41
221.42
221,88
22153
% change
1.94%
1,93%
1,85%
1.79%
1.83%
1.89%
1.87%
188%
197%
2.06%
Barley (EU)
Baseline
244.80
225,86
217.26
213.89
209.27
207.91
209-25
210.64
21187
212,54
Scenario 1
247.67
228.19
219.26
216.01
211.43
210.04
211,45
212.90
214.21
215.00
% change
1.17%
1 ,03%
0,92%
0.99%
1.03%
1,03%
1.05%
1 .07%
111%
116%
Bfvokes, Yu, Tokgoz, & Elobeid — The Producti(^ and Price Impact of Biotech Com, Canola, and Soybean Crops
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AgBioForum, 13(1), 2010 1 42
Table B4. World corn supply and utilization.
08/03
09/10
10/11
11/12
12/13
13/14
14/15
15/16
16/17
17/18
Area harvested
(Thousand hectares)
Baseline
160,424
161,061
166.781
168,047
167,954
170,035
170,820
171,280
172,286
172,931
Scenario 1
160,599
161,436
167.628
169,176
168,638
170,345
171,256
171,616
172,407
173,089
% change
0,11%
0.23%
0.51%
0.67%
0.41%
0.18%
0.26%
0.20%
0.07%
0.09%
Yield
(Metric tons per hectare)
Baseline
4.96
5,03
5.14
5.25
5.31
5-39
5.47
5.53
5.60
5.67
Scenario 1
4,90
4.95
5.05
5.17
5.22
5.29
5.37
5-43
5,50
5.56
% change
-1.18%
-1.60%
-1.72%
-1.61%
-1.60%
-1.76%
-1.78%
-1.75%
-1.82%
-1.84%
Production
(Thousand metric tons)
Baseline
795.217
810,266
856.591
882,789
891 .255
915.958
934,479
947,376
964,302
980,380
Scenario 1
786,714
799.131
846,138
874.440
880,580
901,471
920.223
932,587
947,439
963,237
% change
-1.07%
-1.37%
-1.22%
-0-95%
-1.20%
-1.58%
-1.53%
-1.56%
-1.75%
-1.75%
Beginning stocks
Baseline
102.533
103.581
97,074
101,584
106,107
103.897
105,121
106,391
105,725
106,354
Scenario 1
102.533
100,234
91,708
95,717
101.391
99.763
100,321
101.790
101,531
101,839
% change
0.00%
-3.23%
-5.53%
-5.78%
-4-44%
-3.98%
-4.57%
-4.33%
-3,97%
-4.24%
Domestic supply
Baseline
897.750
913.848
953,665
984,374
997,362
1,019,854
1,039,600
1,053,768
1.070,027
1,086,734
Scenario 1
889.248
899,365
937.846
970,158
981,971
1.001.234
1,020,544
1 ,034.377
1,048.969
1,065,076
% change
-0.95%
-1,58%
-1.66%
-1.44%
-1.54%
-1.83%
-1,83%
-1.84%
-1,97%
-1.99%
Feed use
Baseline
490.514
486,098
497,113
506,626
509,382
517,178
523,330
527,204
532,514
538,892
Scenario 1
487.048
480,003
490.879
501.903
504,689
511,585
518,109
522,215
527,057
533,278
% change
-0.71%
-1.25%
-1.25%
-0.93%
-0,92%
-1.08%
-1.00%
-0.95%
-1.02%
-1.04%
Food and other
Baseline
303,655
330,676
354,968
371 ,640
384.084
397.555
409,878
420,839
431,159
439,609
Scenario 1
301.966
327.653
351,260
366,864
377,519
389,329
400,645
410,631
420,073
428,408
% change
-0.56%
-0.91%
-1,05%
-1.29%
-1.71%
-2,07%
-2,25%
-2,43%
-2.57%
-2.55%
Ending stocks
Baseline
103,581
97,074
101,584
106,107
103.897
105,121
106,391
105,725
106,354
108,233
Scenario 1
100,234
91,708
95.717
101,391
99,763
100,321
101,790
101,531
101,839
103,390
% change
-3.23%
-5.53%
-5.78%
-4,44%
-3.98%
-4,57%
-4.33%
-3,97%
-4.24%
-4.47%
Domestic use
Baseline
897,750
913.848
953,665
984,374
997,362
1,019,854
1,039,600
1.053,768
1.070,027
1,086,734
Scenario 1
889,248
899.365
937.846
970.158
981,971
1,001,234
1,020,544
1,034,377
1,048,969
1,065,076
% change
-0.95%
-1.58%
-1.66%
-1.44%
-1,54%
-1.83%
-1.83%
-1.84%
-1.97%
-1-99%
Trade *
Baseline
85,330
82,314
83,886
86,491
87,216
89,114
91,056
92,342
94,072
96,335
Scenario 1
83.408
79,105
80,681
83.874
84,859
86,613
88,685
90,151
91,852
94,045
% change
-2.25%
-3.90%
-3.82%
-3.03%
-2.70%
-2.81%
-2.60%
-2.37%
-2,36%
-2.38%
Stocks-to-use ratio
(Percent)
Baseline
13.04
11.89
11.92
12.08
11.63
11.49
11.40
11.15
11.04
11.06
Scenario 1
12.70
11.35
11.37
11.67
11-31
11-14
11.08
10.88
10.75
10.75
% change
-2.60%
-4.46%
-4.66%
-3.40%
-2.75%
-3.10%
-2-82%
-2.40%
-2.57%
-2.80%
*■ Excludes intraregional trade
Brookes, Yu. Tokgoz, & Elobeid — The Produdion and Price Impact of Biotech Com, Canola, and Soybean Crops
216
AgBioFonim, 13(1). 2010 | 43
Table B5. World barley supply and utilization.
08/09
09/10
10/11
11/12
13/14
14r1S
15/16
16/17
17/18
Area harvested
(Thousand hectares)
Baseline
56,910
56,795
57,012
57,019
57,048
57,086
57,213
57,237
57,304
57,387
Scenario 1
56,895
56,761
57,024
57.044
57,071
57,093
57.225
57,255
57,316
57,397
% change
-0.03%
-0.06%
0.02%
0.04%
0.04%
0.01%
0,02%
0,03%
0.02%
0.02%
Yield
(Metric tons per hectare)
Baseline
2.53
2,55
2.56
2.57
2.59
2.60
2,62
2.63
2.64
2.65
Scenario 1
2.53
2.55
2.56
2.57
2.59
2.60
2.62
2.63
2.64
2.65
% change
-0.03%
0.05%
0.05%
0.04%
0.02%
0.03%
0.03%
0.02%
0.02%
0.02%
Production
(Thousand metric tons)
Baseline
144,105
144,573
145.914
146,705
147.629
148,556
149,633
150,443
151,326
152,241
Scenario 1
144,027
144,556
146,021
146,822
147,725
148.619
149,706
150.527
151,393
152,306
% change
-0.05%
-0.01%
0.07%
0.08%
0.07%
0.04%
0.05%
0.06%
0.04%
0.04%
Beginning stocks
Baseline
15,413
18,066
18,557
19.015
19,259
19.355
19.455
19,562
19,605
19,710
Scenario 1
15,413
17,876
18.260
18,718
19,005
19,115
19,201
19,319
19,377
19,475
% change
0,00%
-1.05%
-1.60%
-1.56%
-1.32%
-1.24%
-1.30%
-1,24%
-1.17%
-1.19%
Domestic supply
Baseline
159,518
162.639
164,471
165,720
166,888
167.912
169,088
170.005
170,931
171,951
Scenario 1
159,440
162,432
164,281
165,540
166,730
167,733
168,907
169,847
170.769
171,781
% change
Feed use
-0.05%
-0,13%
-0.12%
-0,11%
-0.09%
-0.11%
-0,11%
-0.09%
-0.09%
-0.10%
Baseline
97,028
98,901
99,685
100,262
100,904
101,440
102,101
102,621
103,072
103,537
Scenario 1
97.166
99,042
99,843
100,390
101,033
101,564
102,213
102,738
103,191
103,655
% change
0.14%
0.14%
0.16%
0.13%
0.13%
0.12%
0.11%
0.11%
0,12%
0.11%
Food and other
Baseline
44,424
45.181
45,772
46,198
46,629
47,017
47.425
47,778
48,149
48.524
Scenario 1
44,397
45,130
45,720
46,145
46,583
46.968
47.375
47,732
48,103
48,477
% change
Ending stocks
-0.06%
-0.11%
-0.11%
-0.11%
-0.10%
-0.10%
-0.11%
-0.10%
-0.10%
-0.10%
Baseline
18,066
18,567
19,015
19,259
19,355
19,455
19,562
19,605
19,710
19,890
Scenario 1
17,876
18,260
18.718
19.005
19,115
19,201
19,319
19,377
19,475
19,650
% change
Domestic use
-1.05%
-1.60%
-1.56%
-1.32%
-1.24%
-1.30%
-1.24%
-1.17%
-1,19%
-1.21%
Baseline
159,518
162,639
164,471
165,720
166.888
167,912
169,088
170,005
170,931
171,951
Scenario 1
159,440
162,432
164,281
165,540
166,730
167,733
168,907
169.847
170,769
171,781
% change
Trade *
-0.05%
■0.13%
-0.12%
-0.11%
-0.09%
-0.11%
-0.11%
-0.09%
-0.09%
-0,10%
Baseline
15,871
16,721
17.067
17,246
17.430
17.539
17,648
17,729
17,783
17,829
Scenario 1
15,918
16,786
17.110
17,270
17,454
17.565
17,669
17,749
17,804
17,850
% change
0,30%
0.39%
0-25%
0-14%
0.14%
0.15%
0-12%
0.11%
0.12%
0.11%
Stocks-to-use ratio
(Percent)
Baseline
12.77
12.88
13.07
13.15
13.12
13.10
13.08
13,04
13.03
13.08
Scenario 1
12,63
12.67
12.86
12,97
12.95
12.93
12.92
12.88
12,87
12.92
% change
-1.13%
-1.66%
•1.63%
-1.37%
-1.30%
-1.35%
-1.28%
-1.21%
-1.24%
-1.25%
* Excludes intraregional trade
Brx}okes. Yu, Tokgoz, & Elobeid — The Production and Price Impact of Biotech Com, Canola, and Soybean Crops
217
AgBioForum. 13(1). 2010 \ 44
Table B6. World sorghum supply and utilization.
08/09
09/10
10/11
11/12
12/13
13/14
14/15
15/16
16/17
17/18
Area harvested
{Thousand hectares)
Baseline
41,252
40,889
41.670
41,378
41,134
41,487
41,507
41,724
41,976
42,008
Scenario 1
41,265
41,116
41,983
41.694
41,366
41.732
41,796
41,984
42,233
42,296
% change
0.03%
0.56%
0,75%
0.76%
0.56%
0.59%
0.70%
0.62%
0.61%
0.69%
Yield
{Metric tons per hectare)
Baseline
1.54
1.53
1.54
1.56
1.57
1.59
1.60
1.61
1,62
1-64
Scenario 1
1.54
1.53
1,54
1.56
1.57
1.59
1.60
1.61
1.63
1.64
% change
0.05%
0.03%
0,01%
0-04%
O.C»%
0.04%
0-05%
0,05%
0,04%
0,05%
Production
(Thousand metric tons)
Baseline
63,439
62,547
64,362
64,602
64,739
65,874
66,423
67,263
68.200
68,820
Scenario 1
63,494
62,915
64,850
65,122
65,143
66,286
66.917
67,718
68.648
69,325
% change
0,09%
0.59%
0.76%
0.81%
0.62%
0.63%
0.74%
0,68%
0.66%
0.73%
Beginning stocks
Baseline
3,972
4.372
4,013
4,174
4,257
4,229
4,308
4,320
4,304
4,334
Scenario 1
3,972
4,273
3,853
3,998
4,110
4.085
4,151
4,176
4,166
4,187
% change
0.00%
-2.26%
-3.99%
-4.22%
-3.46%
-3.41%
-3.64%
-3,34%
-3,21%
-3.38%
Domestic supply
Baseline
67,411
66.919
68,376
68,776
68,997
70,103
70.731
71,583
72,505
73,154
Scenario 1
67,466
67,189
68,703
69,120
69,253
70,371
71,068
71,894
72,814
73,513
% change
Feed use
0,08%
0.40%
0,48%
0.50%
0.37%
0.38%
0.48%
0.43%
0.43%
0,49%
Baseline
26,931
26,123
26,534
26.529
26,630
26,808
26,791
26,846
26,937
26,999
Scenario 1
27,069
26.288
26,686
26,691
26,759
26,933
26,929
26,966
27,049
27,117
% change
Food and other
0.51%
0.63%
0,57%
0,61%
0.48%
0,47%
0,51%
0.45%
0.42%
0,44%
Baseline
36,108
36,783
37,668
37.989
38,138
38.987
39,620
40,432
41,234
41,774
Scenario 1
36,123
37.048
38.020
38,319
38,409
39.287
39,963
40,761
41,578
42,165
% change
Ending stocks
0.04%
0.72%
0.94%
0.87%
0,71%
0,77%
0.87%
0.81%
0.83%
0,94%
Baseline
4,372
4.013
4,174
4,257
4.229
4,308
4,320
4,304
4,334
4,381
Scenario 1
4,273
3,853
3,998
4,110
4,085
4,151
4.176
4,166
4,187
4,231
% change
-2.26%
-3.99%
-4,22%
-3.46%
-3.41%
-3.64%
-3.34%
-3.21%
-3.38%
-3.43%
Domestic use
Baseline
67.411
66,919
68,376
68,776
68,997
70,103
70,731
71,583
72,505
73,154
Scenario 1
67,466
67.189
68.703
69,120
69,253
70,371
71,068
71,894
72,814
73,513
% change
0.08%
0.40%
0.48%
0.50%
0.37%
0-38%
0,48%
0-43%
0.43%
0,49%
Trade *
Baseline
6,109
5,621
5.557
5.761
5,823
5,935
6,100
6,192
6,277
6,409
Scenario 1
6,094
5.600
5,441
5,721
5,817
5,918
6,075
6,178
6,255
6,371
% change
-0.24%
-0.38%
-2.10%
-0.70%
-0.10%
-0-29%
-0.40%
-0,23%
-0.35%
-0.59%
Stocks-to-use ratio {Percent)
Baseline
6,94
6.38
6,50
6,60
6.53
6.55
6,50
6,40
6.36
6.37
Scenario 1
6.76
6.08
6.18
6.32
6.27
6-27
6.24
6-15
6.10
6.11
% change
-2.50%
-4.64%
-4.96%
-4.19%
-4.00%
-4.26%
-4.03%
-3.85%
-4.03%
-4,14%
* Excludes intraregional tmde
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Table B7. Soybean and product prices.
88/09
09/10
10/11
11/12
12/13
13/14
14/15
15/16
16/17
17/18
Illinois processor
Baseline 398
378
386
(US dollars per metric ton)
Soybean prices
399 388 395
405
406
409
412
Scenario 1
442
419
415
432
422
426
437
439
441
445
% change
11.18%
10.81%
7.37%
8.21%
8.81%
7.85%
7.83%
8.15%
7.94%
8.03%
GIF Rotterdam
Baseline
511
486
496
511
497
505
517
518
521
523
Scenario 1
567
537
531
552
540
544
557
559
561
565
% change
10.94%
10.58%
7.22%
8.04%
8.63%
7.69%
7.67%
7.98%
7.78%
7,86%
FOB Decatur 48%
Baseline 306.76
289.97
281.68
Soymeal prices
283.93 283-49
285.21
289.20
287.94
285,00
281.04
Scenario 1
336.88
317,19
303.02
307.20
308.00
309.09
313.86
313.51
310,80
307.64
% change
9,82%
9.39%
7.57%
8.20%
8.65%
8.37%
8.52%
8.88%
9.05%
9,47%
GIF Rotterdam
Baseline
402.14
380.55
369.90
372.79
372.22
374.43
379,57
377.95
374.16
369.07
Scenario 1
440.80
415.53
397.33
402.71
403.73
405.13
411.26
410.81
407.33
403.27
% change
9,61%
9,19%
7.42%
8.03%
8.47%
8.20%
8.35%
8.69%
8,86%
9.27%
FOB Decatur
Baseline
1,034
1,029
1,075
Soy oil prices
1,102 1.055
1,070
1,094
1,111
1,140
1,171
Scenario 1
1.084
1,092
1,125
1.164
1.125
1,139
1,168
1,190
1,221
1,264
% change
4,83%
6.13%
4,62%
5.60%
6.61%
6.45%
6.78%
7.16%
7,11%
7.11%
FOB Rotterdam
Baseline 1,255
1,249
1.304
1,336
1,280
1.298
1,326
1,346
1,381
1,418
Scenario 1
1,314
1,324
1,363
1.409
1,363
1.380
1,414
1,441
1,477
1,516
% change
4.73%
6.01%
4.53%
5.49%
6,47%
6.31%
6.64%
7,01%
6.96%
6.97%
Table B8. Rapeseed and product prices.
08/09
09/10
10/11
11/12
12/13^
13/14
14/15
1SI16
16/17
}
(US dollars per metric ton)
Rapeseed prices
Cash Vancouver
Baseline
Scenario 1
411.34
426.09
411.19
427.14
413.68
428.47
396.40
412.66
392.59
409.56
395.74
412.84
396,93
415.11
398.25
417,33
402,49
422.15
405.44
425.98
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Table B8. Rapeseed and product prices.
% change
3-58%
3,88%
3.58%
4.10%o
4.32%
4.32%
4.58%
4.79%
4.89%>
5.06%
GIF Hamburg
Baseline
529.20
529.00
532.27
509.59
504.60
508.73
510.28
512,01
517.58
521.45
Scenario 1
548.56
549.94
551.70
530.93
526.85
531.16
534.14
537.06
543.39
548.41
% change
3.66%
3.96%
3.65%
4.19%
4.41%
4.41%
4.68%
4.89%
4.99%
5.17%
Rapeseed meal price
FOB Hamburg
Baseline
303
301
295
294
301
305
308
309
308
304
Scenario 1
316
314
305
304
311
315
318
319
318
315
% change
4,32%
4.10%
3.57%
3.49%
3.34%
3.29%
3.28%
3.28%,
3.37%
3.56%
Rapeseed oil price
FOB Hamburg
Baseline
1,310
1.344
1.385
1,347
1,338
1,362
1,385
1,413
1,456
1,502
Scenario 1
1,345
1,384
1.423
1,391
1,385
1.409
1.436
1,467
1,512
1,560
% change
2.65%
2.98%
2.78%
3.22%
3.50%
3.48%
3.65%
3,81%
3.81%,
3.83%,
Table B9. Sunflower seed and product prices.
08/03
09/10
10/11
12/13
13/14
14/15
, 15/16 :
16/17
17/18
GIF Lower Rhine
{US dollars per metric ton)
Baseline
601
588
596
587
577
578
580
579
579
578
Scenario 1
617
610
614
606
596
596
599
598
598
598
% change
2.59%
3,73%
3.05%
3.13%
3.30%
3-16%.
3.24%
3,32%
3.31%
3.40%
GIF Rotterdam
Baseline
276
270
265
264
268
272
275
274
271
266
Scenario 1
285
280
274
272
276
280
282
282
279
275
% change
3.49%
3,76%
3.20%
3.04%
3.00%
2.93%
2.88%
2.89%
2,97%
3,13%
FOB NW Europe
Baseline
1,432
1,424
1,463
1,471
1,467
1,490
1,517
1,545
1,577
1,609
Scenario 1
1,451
1,453
1,487
1,497
1,495
1.517
1,546
1,575
1,607
1,639
% change
1.35%
2,00%
1.63%>
1.78%
1,92%
1.83%
1 ,88%.
1.93%
1.90%
1.89%
Table B10. World soybean sector supply and utilization.
08/03
03/10
10/11
. 11/12
14/15
15/16
16'17
17/18
Soybeans
Area harvested
{Thousand hectares)
Baseline
96,946
99,931
100,256
100,770
102.729
103.231
103,792
105,049
105,939
106,803
Scenario 1
97,822
102,806
103,924
103,881
105,798
106.571
107,050
108,264
109,268
110,143
% change
0.90%
2.88%
3.66%.
3.09%
2.99%
3.24%
3.14%
3,06%
3.14%,
3.13%
Production
(Thousand metric tons)
Baseline
242,217
252,279
255.277
258.491
266,315
270.217
274,164
280,326
285,531
290,682
Scenario 1
233,417
248,311
253,470
255,008
262,557
267,188
270,815
276,729
282,179
287,262
% change
-3.63%
-1.57%
-0.71%.
-1.35%
-1 ,41%
-1.12%
-1.22%
-1.28%
-1.17%,
-1.18%,
Beginning stocks
Baseline
47.227
48,060
49,742
50,129
49,637
50,547
50,748
50,506
50,755
50,910
Scenario 1
47,227
45,053
46,583
47,617
46,967
47,645
47,971
47,716
47,850
48,013
% change
0.00%
-6.26%
-6.35%
-5.01%
-5.38%
-5.74%
-5.47%,
-5.52%
-5.72%,
-5.69%
Domestic supply
Brookes. Yu. Tokaoz. & Blobeid — The Pmducbon and Price Impact of Biotech Com, Canola, and Soybean Crops
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AgBioForum, 13(1). 2010 1 47
Table B10. World soybean sector supply and utilization.
Baseline
289,444
300,339
305,019
308,621
315.952
320.764
324,913
330,832
336,286
341,591
Scenario 1
280,643
293,364
300,052
302,625
309,524
314,833
318,785
324,445
330,029
335,275
% change
^3.04%
-2.32%
-1-63%
-1.94%
-2.03%
-1.85%
-1.89%
-1.93%
-1.86%
-1.85%
Crush
Baseline
209,533
218,369
222,558
226,309
232,128
236,595
240,822
246,127
251,150
256,042
Scenario 1
204,327
214,881
220,184
223,155
228,795
233.559
237.612
242,789
247,905
252,748
% change
-2.48%
-1.60%
-1.07%
-1.39%
-1.44%
-1.28%
-1.33%
-1.36%
-1 .29%
-1.29%
Food use
Baseline
14,504
14,829
14,949
15,131
15,384
15,462
15,497
15,624
15,715
15,887
Scenario 1
14,182
14,484
14,723
14,900
15,112
15.218
15,257
15,366
15,468
15,637
% change
-2.22%
-2.33%
-1.51%
-1.53%
-1.77%
-1,58%
-1,55%
-1 .65%
-1.58%
-1.57%
Other use
Baseline
16,473
16,963
16,948
17,107
17,457
17,524
17,653
17,891
18,075
18,283
Scenario 1
16,224
16,981
17,093
17,167
17,537
17,651
17,765
18,004
18,208
18,409
% change
-1.51%
0.10%
0-85%
0.35%
0.45%
0.73%
0,64%
0.63%
0.74%
0.69%
Residual
Baseline
436
436
436
436
436
436
436
436
436
436
Scenario 1
436
436
436
436
436
436
436
436
436
436
% change
0.00%
0,00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
Ending stocks
Baseline
48,060
49,742
50,129
49.637
50,547
50,748
50,506
50.755
50,910
50,943
Scenario 1
45,053
46,583
47,617
46,967
47.645
47,971
47,716
47,850
48,013
48,045
% change
-6.26%
-6.35%
-5.01%
-5.38%
-5,74%
-5.47%
-5.52%
-5.72%
-5.69%
-5,69%
Domestic use
Baseline
289,006
300,339
305,020
308,621
315,952
320,765
324,913
330.832
336,286
341,592
Scenario 1
280,222
293,364
300,053
302,625
309.525
314,834
318,786
324.446
330,030
335,276
% change
-3.04%
-2.32%
-1.63%
-1.94%
-2.03%
-1.85%
-1.89%
■1.93%
-1.86%
-1.85%
Trade*
Baseline
70,094
72,279
73,476
75,117
77,980
79,962
81,824
84,209
86,428
88,696
Scenario 1
68,359
71 ,000
73,071
74,718
77,695
80,052
82,051
84,462
86., 814
89,144
% change
-2.48%
-1.77%
-0,55%
-0.53%
-0-36%
0.11%
0.28%
0,30%
0.45%
0.51%
Production
Baseline
165,122
172,092
175,401
Soybean meal
178,363 182,958
186,486
189,825
194.015
197.983
201,848
Scenario 1
161,027
169,352
173,543
175,893
180,349
184,113
187,316
191,406
195,448
199,275
% change
-2.48%
-1.59%
-1,06%
-1.38%
-1.43%
-1.27%
-1.32%
-1.34%
-1.28%
-1.27%
Consumption
Baseline
162,560
169,579
173.013
176,107
180.656
184,203
187,570
191.700
195,656
199,516
Scenario 1
158,877
166,793
171,072
173,657
178,056
181,814
185,063
189.095
193,116
196,945
% change
-2.27%
-1.64%
-1.12%
-1.39%
-1,44%
-1.30%
-1.34%
-1.36%
-1.30%
-1,29%
Ending stocks
Baseline
5,768
6,069
6.243
6,286
6,374
6,445
6,487
6,588
6,702
6,822
Scenario 1
5,356
5,703
5,961
5.984
6.064
6,150
6,190
6,288
6,406
6,524
% change
-7,14%
-6.03%
-4.52%
-4.80%
-4.87%
-4.58%
-4.58%
-4.56%
-4.42%
-4.37%
Trade *
Baseline
56,655
60,137
61,994
62,804
64.161
65,415
66,896
68,602
70,286
71,907
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Table B1 0. World soybean sector supply and utilization.
Scenario 1
54,520
58,498
60,491
60,863
62,049
63,673
65.023
66,656
68,326
69,918
% change
-3.77%
-2.73%
-2.42%
-3.09%
-3.29%
-2.66%
-2.80%
-2.84%
-2.79%
-2.77%
Soybean oil
Production
Baseline
39,020
40,765
41,647
42,446
43.638
44,587
45,498
46,618
47,694
48,753
Scenario 1
38,034
40,098
41,182
41.827
42,979
43,977
44.848
45,940
47.027
48,071
% change
-2,53%
-1.64%
-1.12%
-1.46%
-1.51%
-1.37%
-1,43%
-1-46%
-1.40%
-1.40%
Consumption
Baseline
39,063
40,488
41,453
42,156
43,383
44,331
45,289
46,427
47,488
48,554
Scenario 1
38,171
39,841
40,965
41.562
42,735
43,719
44.649
45,754
46,821
47,875
% change
-2,28%
-1.60%
-1.18%
-1,41%
-1.49%
-1.38%
-1.41%
-1-45%
-1.40%
-1.40%
Ending stocks
Baseline
2,361
2,422
2,400
2,473
2,512
2,552
2.545
2,521
2,511
2,494
Scenario 1
2,267
2.307
2.308
2,358
2,386
2.428
2,412
2,381
2.372
2,352
% change
^.00%
-4.76%
-3.81%
-4.67%
-5.02%
-4.86%
-5.23%
-5.53%
-5,55%
-5.70%
Trade *
Baseline
9,651
10,042
10,268
10.443
11,019
11,350
11,733
12,191
12.638
13,091
Scenario 1
9,458
9,708
9,938
10.027
10,525
10,814
11,153
11,581
12,011
12,456
% change
-2.00%
-3,33%
-3.21%
-3.99%
-4.48%
-4.72%
-4.95%
-5,00%
-4.96%
-4.85%
Per-capita consumption
(Kilograms)
Baseline
5.78
5.92
6.00
6,03
6,14
6.20
6,27
6,36
6.44
6.51
Scenario 1
5.65
5.83
5.93
5.94
6.04
6.12
6.1S
6.27
6.35
6.42
% change
-2,28%
-1,60%
-1.18%
-1.41%
-1 .49%
-1.38%
-1.41%
-1.45%
-1.40%
-1.40%
* Excludes intraregional trade
Table B11. Worid rapeseed sectorsupply and utilization.
08/09
09/10
11/12
15/16
16/17
17/18
Rapeseed
Area harvested
(Thousand hectares)
Baseline
28,729
29,388
29,904
30,355
30,612
30,935
31,345
31,743
32,145
32,587
Scenario 1
28,785
29,532
30.060
30.516
30.806
31.147
31.565
31,979
32,395
32,842
% change
0.19%
0.49%
0.52%
0.53%
0,63%
0,69%
0.70%
0.75%
0.78%
0.78%
Production
(Thousand metric tons)
Baseline
50,085
51,784
53,205
54,597
55.648
56.797
58,087
59,356
60,642
62.001
Scenario 1
49.836
51.703
53.148
54,542
55,643
56.819
58,115
59,405
60,708
62,072
% change
-0.50%
-0.16%
-0,11%
-0.10%
-0.01%
0,04%
0.05%
0,08%
0.11%
0.11%
Beginning stocks
Baseline
2,860
3,034
3,050
3,061
3,146
3,183
3,199
3,224
3,254
3,279
Scenario 1
2,860
2,975
2,987
3.005
3,084
3,120
3,136
3,159
3,187
3,212
% change
0.00%
-1,94%
-2.04%
-1.85%
-1.96%
-2.01%
-1.97%
-2.04%
-2-07%
-2.06%
Domestic supply
Baseline
52,945
54,818
56,254
57,658
58,794
59.981
61,285
62,580
63,896
65,281
Scenario 1
52,696
54.678
56,135
57.546
58.727
59.938
61,251
62,564
63,895
65,284
% change
-0.47%
-0.25%
-0.21%
-0.19%
-0.11%
-0.07%
-0.06%
-0.03%
0.00%
0.00%
Crush
Baseline
46,056
47,742
49,123
50,373
51,428
52,616
53,943
55,300
56,690
58,164
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Table B11. World rapeseed sector supply and utilization.
Scenario 1
45.918
47,706
49,091
50,338
51,430
52,631
53,956
55,323
56,718
58,188
% change
-0.30%
-0,08%
-0.07%
-0.07%
0.00%
0.03%
0.02%
0.04%
0,05%
0-04%
Other use
Baseline
3,584
3,755
3,799
3,868
3,912
3,895
3,846
3.755
3,656
3,537
Scenario 1
3,532
3.714
3,768
3,853
3,906
3,901
3,864
3,783
3,694
3,585
% change
-1.46%
-1,08%
-0,80%
-0.40%
-0.15%
0.14%
0.46%
0.76%
1 .04%
1 .35%
Residual
Baseline
271
271
271
271
271
271
271
271
271
271
Scenario 1
271
271
271
271
271
271
271
271
271
271
% change
0.00%
0,00%
0.00%
0.00%
0.00%
0.00%
0,00%
0.00%
0.00%
0-00%
Ending stocks
Baseline
3,034
3,050
3,061
3.146
3,183
3.199
3,224
3,254
3,279
3,308
Scenario 1
2,975
2.987
3,005
3,084
3,120
3.136
3,159
3,187
3,212
3,239
% change
-1.94%
-2,04%
-1.85%
-1.96%
-2.01%
-1.97%
-2.04%
-2.07%
-2.06%
-2.07%
Domestic use
Baseline
52,945
54,818
56,254
57,658
58,794
59.981
61,285
62,580
63,896
65,281
Scenario 1
52,696
54,678
56,135
57.546
58,727
59,938
61.251
62,564
63,895
65.284
% change
-0.47%
-0.25%
-0.21%
-0.19%
-0.11%
-0.07%
-0.06%
-0,03%
0,00%
0.00%
Trade *
Baseline
7,472
8.088
8,304
8,493
8,675
8.868
9,086
9.330
9,591
9,866
Scenario 1
7,476
7,976
8,160
8,327
8.496
8,674
8,877
9,108
9,357
9,619
% change
0.05%
-1.39%
-1.74%
-1.96%
-2.06%
-2.18%
-2,30%
-2.38%
-2.44%
-2.50%
Production
Baseline
27,251
28,226
29,031
Rapeseed meat
29,768 30,384
31,080
31.862
32,662
33,481
34,352
Scenario 1
27,170
28,203
29,011
29,745
30,383
31.087
31,866
32,672
33,494
34,362
% change
-0.30%
-0,08%
-0,07%
-0.08%
0.00%
0.02%
0.01%
0.03%
0.04%
0.03%
Consumption
Baseline
27,559
28,537
29,340
30,081
30,703
31,397
32,177
32,976
33,793
34,662
Scenario 1
27,489
28,513
29,317
30,058
30,702
31,402
32,182
32,985
33,806
34,672
% change
-0,25%
-0.08%
-0.08%
-0,08%
0,00%
0.02%
0.01%
0.03%
0.04%
0.03%
Ending stocks
Baseline
314
322
333
339
339
342
345
351
357
366
Scenario 1
303
312
324
330
331
334
338
343
350
358
% change
-3.72%
-3,34%
-2.70%
-2,54%
-2.43%
-2.34%
-2,28%
-2.19%
-2.14%
-2.13%
Trade *
Baseline
2.404
2,738
2.946
3,008
3,121
3,214
3,291
3,369
3,446
3,626
Scenario 1
2,389
2,792
2,992
3,062
3,180
3,274
3,356
3,437
3,517
3,589
% change
-0.62%
1.95%
1.58%
1.82%
1.89%
1,88%
1.97%
2.02%
2.04%
-1.03%
Production
Baseline
18,068
18,760
19,321
Rapeseed oil
19,821 20,250
20,731
21,265
21,809
22,367
22,957
Scenario 1
18,009
18,744
19,307
19.808
20,252
20,738
21,272
21,821
22,381
22,970
% change
-0,33%
-0.08%
-0.07%
-0.07%
0.01%
0.03%
0,03%
0,05%
0-06%
0.06%
Consumption
Baseline
18,287
19,016
19,580
20,067
20,498
20,987
21,s522
22,068
22,629
23,220
Brookes, Yu, Tokgoz. 5 Elobeid — The Production and Price Impact of Biotech Corn, Canola, and Soybean Crops
223
AgBioForum. 13(1). 2010 \ 50
Table B11. World rapeseed sector supply and utilization.
Scenario 1
18,237
19,005
19,567
20,056
20,501
20.994
21,530
22.081
22,644
23,233
% change
-0.27%
-0,06%
-0.07%
-0.06%
0.02%
0.04%
0,04%
0,06%
0,06%
0.06%
Ending stocks
Baseline
427
429
428
440
451
453
453
452
448
443
Scenario 1
418
416
414
424
433
435
434
433
428
422
% change
-2,18%
-3,13%
-3.24%
-3.58%
-3.86%
-3.95%
-4.14%
-4.35%
-4.49%
-4.63%
Trade *
Baseline
1,591
1,631
1,708
1,759
1,830
1,909
1,981
2,045
2,101
2,158
Scenario 1
1,481
1,563
1,648
1.707
1,785
1,870
1,949
2,018
2,078
2,140
% change
-6,91%
-4.15%
-3.53%
-2.99%
-2.45%
-2.02%
-1.64%
-1.32%
-1 .07%
-0.85%
Per-capita consumption
(Kilograms)
Baseline
2,71
2.78
2.83
2.87
2.90
2.94
2.98
3.02
3.07
3.11
Scenario 1
2,70
2,78
2.83
2.87
2.90
2.94
2.98
3.02
3.07
3.12
% change
-0,27%
-0.06%
-0.07%
-0.06%
0.02%
0.04%
0.04%
0.06%
0.06%
0.06%
* Excludes intraregional trade
Table B1 2. World sunflower sector supply and utilization.
09/10 V
10/11
11/12
12/13
13/14
1F/1G
16/17
17/18
Sunflower seed
Area harvested
(Thousand hectares)
Baseline
24.273
24,401
24,392
24.474
24,513
24,538
24,600
24.680
24.759
24,850
Scenario 1
24,261
24,392
24,404
24,490
24,537
24,571
24,633
24,717
24,800
24,891
% diange
-0.05%
-0.04%
0,05%
0.07%
0.10%
0.13%
0.13%
0,15%
0.17%
0,16%
Production
(Thousand metric tons)
Baseline
29,838
30,284
30.612
31,042
31,425
31,784
32,182
32,610
33,037
33,480
Scenario 1
29,828
30,287
30,642
31,074
31,469
31,841
32.241
32,675
33,108
33,552
% change
-0,04%
0.01%
0,10%
0.10%
0,14%
0.18%
0,18%
0,20%
0.22%
0,21%
Beginning stocks
Baseline
1.884
2,032
2,089
2.105
2.136
2,179
2,198
2,215
2,238
2,258
Scenario 1
1,884
2,002
2,051
2,076
2.105
2,147
2,169
2,186
2,209
2,230
% change
0.00%
-1.50%
-1.81%
-1.38%
-1.43%
-1.44%
-1,29%
-1.29%
-1.28%
-1.22%
Domestic supply
Baseline
31,722
32,316
32,701
33,147
33,561
33.962
34,380
34,825
35,275
35,737
Scenario i
31,712
32,289
32,693
33.150
33,575
33,988
34,410
34,861
35,317
35.782
% change
Crush
-0.03%
-0.09%
-0,02%
0,01%
0,04%
0.08%
0,09%
0.10%
0.12%
0.12%
Baseline
26,228
26,695
27,040
27,421
27.746
28,106
28,487
28,880
29,292
29,706
Scenario 1
26,276
26,738
27,084
27.480
27,817
28.181
28,567
28,967
29,381
29,797
% change
Other use
0.18%
0.16%
0.16%
0.21%
0.25%
0.27%
0,28%
0.30%
0.31%
0.31%
Baseline
3,387
3,458
3,481
3,615
3,561
3.583
3,602
3,631
3.650
3,680
Scenario 1
3,359
3,425
3,458
3,490
3,536
3,562
3,581
3,610
3,631
3,661
% change
Residual
-0.84%
-0,96%
-0.66%
-0.72%
-0.72%
-0.59%
-0,59%
-0.58%
-0.53%
-0.52%
Baseline
75
75
75
75
75
75
75
75
75
75
Scenario 1
75
75
75
75
75
75
75
75
75
75
Brookes, Yu, Tokgoz, & Elobeid — The Production and Price Impact of Biotech Com. Canola, and Soybean Crops
224
AgBioForum, 13(1). 2010 \ 51
Table B12. World sunflower sector supply and utilization.
% change
Ending stocks
0,00%
0.00%
0,00%
0.00%
0.00%
0.00%
0.00%
0-00%
0-00%
0.00%
Baseline
2,032
2,089
2.105
2.136
2,179
2,198
2,215
2,238
2,258
2,276
Scenario 1
2,002
2,051
2,076
2.105
2,147
2.169
2,186
2,209
2,230
2,249
% change
Domestic use
-1,50%
-1.81%
-1,38%
-1.43%
-1.44%
-1.29%
-1.29%
-1.28%
-1.22%
-1.21%
Baseline
31,722
32,316
32,701
33,147
33.561
33,962
34.380
34,825
35,275
35,737
Scenario 1
31,712
32,289
32,693
33,150
33,575
33.988
34,410
34,861
35,317
35,782
% change
Trade *
-0,03%
-0.09%
-0.02%
0.01%
0.04%
0.08%
0,09%
0.10%
0.12%
0.12%
Baseline
513
615
757
856
947
1.012
1,083
1,163
1,238
1,318
Scenario 1
511
577
708
811
905
972
1,043
1,125
1,200
1,280
% change
-0,33%
-6.18%
-6,50%
-5.30%
-4.47%
-3.98%
-3,71%
-3.33%
-3.09%
-2,94%
Baseline
11,614
11,806
11,958
12,129
12,268
12.419
12,579
12.745
12,918
13,092
Scenario 1
11,636
11,824
11,978
12,155
12,300
12,454
12,616
12,785
12,959
13,134
% change
0.18%
0,16%
0.16%
0.22%
0.26%
0.28%
0.29%
0.31%
0,32%
0,32%
Consumption
Baseline
11,276
11,483
11,636
11,808
11,949
12,099
12,259
12,424
12.596
12,770
Scenario 1
11,301
11,502
11,655
11,834
11,981
12,134
12,296
12,464
12,638
12,813
% change
0,22%
0.16%
0.16%
0.22%
0.27%
0.28%
0,30%
0.32%
0,33%
0,33%
Ending stocks
Baseline
257
262
266
268
270
272
274
277
280
284
Scenario 1
253
258
263
266
267
269
271
274
278
281
% change
-1,41%
-1 .42%
-1,14%
-1.05%
-1.01%
-0,97%
-0.92%
-0.88%
-0,86%
-0.85%
Trade *
Baseline
2,652
2,696
2,683
2.675
2,677
2,688
2,695
2,702
2,713
2,728
Scenario 1
2,655
2,699
2,685
2,677
2,680
2,691
2,696
2,705
2,716
2,731
% change
0.13%
0.09%
0,08%
0.11%
0.12%
0.11%
0.12%
0.12%
0,12%
0,12%
Production
Baseline
10,680
10,875
11,016
Sunflower Oil
11,171 11,304
11,452
11,609
11,771
11,940
12,111
Scenario 1
10.700
10,893
11,034
11,195
11.333
11,483
11,642
11,807
11,977
12,149
% change
0,18%
0,16%
0.17%
0.22%
0.26%
0,27%
0.29%
0.30%
0.31%
0.31%
Consumption
Baseline
10,294
10,518
10,673
10.823
10,950
11,105
11,262
11,424
11,594
11,766
Brookes. Yu. Tokgoz, & Elobeid The Produdion and Price Impact of Biotech Com. Canola, and Soybean Crops
225
AgBioForum, 13(1), 2010 ! 52
Table B12. World sunflower sector supply and utinzatSon.
Scenario 1
10,320
10,538
10,690
10,848
10.979
11,135
11,296
11,460
11,631 11,803
% change
Ending stocks
0-25%
0.19%
0.15%
0.23%
0-27%
0.28%
0.30%
0.31%
0.32% 0.32%
Baseline
427
443
443
449
462
467
472
477
481 484
Scenario 1
421
434
436
441
453
459
464
469
473 476
% change
Trade *
-1.57%
-2.03%
-1,59%
-1.75%
-1.82%
-1.68%
-1.70%
-1.72%
-1.66% -1.63%
Baseline
3,236
3,349
3,396
3.446
3,516
3,600
3,685
3,774
3,869 3.972
Scenario 1
3,240
3,354
3,401
3,454
3.525
3,610
3,697
3,787
3,883 3,986
% change
0.13%
0,15%
0.17%
0.24%
0.26%
0.28%
0.31%
0.33%
0.34% 0.35%
Per-capita consumption
(Kilograms)
Baseline
1.52
1,54
1.54
1.55
1.55
1,55
1.56
1.56
1.57 1.58
Scenario 1
1.53
1,54
1.55
1.55
1.55
1.56
1.56
1.57
1.58 1.58
% change
0.25%
0-19%
0.15%
0.23%
0.27%
0.28%
0.30%
0.31%
0.32% 0.32%
* Excludes intraregional trade
Appendix C
Table C1. Baseline 2007-08 world production, consumption, and price data.
Area
Production
Consumption
Pnce
(million hectares) (million tonnes] (million loniies)
(million tonnosi
($/tonne)
Corn
159
790
97
777
216
Soybeans
91
218
78
n/a
469
Canola
28
48
4
n/a
644
Wheat
217
611
115
618
314
Barie
57
133
18
176
242
Sunflower
22
27
1
n/a
745
Sorghum
41
63
9
63
299
Soymeal
n/a
158
55
157
314
Soy oil
n/a
37
10
37
1,151
Rapemeal
n/a
27
4
27
298
Rape oil
n/a
18
2
18
1.410
Sun meal
n/a
11
3
10
191
Sun oil
n/a
10
3
9
1,639
Note: All values rounded to nearest million; n/a = not applicable
Brookes, Yu, Tokgoz, & Elobeid — The Production and Price Impact of Biotech Com, Canola, and Soybean Crops
Pspufation fhillmns}
226
Consiiniaiiun lechr ’h'lv I
nii-.'lJ-.ijLi]
l^n tltelran^tGfS didlR thepast 1S,GOO
years - anti do it in an environmentally
snstalnabie manner.
Biotechnology-derived crops and the
sustainable farming systems they iactil-
tate are key tools in the race to grow more
.Idddv teed.ilber and fuel while protecting
the environment.
Warld Population: 195D-2050
Year
Race Againat Time
To meet the projected soybean demand of 2030, growers would have to add
168 million acres of soybeans to existing production if global yields remained
the same as today, or double those yields to 59.5 !:>usitels per acre to harvest
enough soybeans cm todays acreage,
Biotoch crops show promise to double or triple the current rale of yield
increase in co.rn, and match or exceed the average O.S-bushel-per-acre
annual Increase in soybean y:sids.
Not surprisingly, millions of farrners have adooled biotech crops readily.
In the U.S.. 91.5 percent of the soybeans, 85 percent of the corn and 88
percent of the cotton in the 2009 crop was otanted to btctech varieties.
For a copy of the full report, visit
stainabii
! Dinfecrinoiogy-detived crops focused primarily on input traits,
^roaiic'inn slticrencies- in fact, ine worlcTAids economic benefit of
t -'■K' y non 1^36 ana 2007 was caiculaled at $44 -billion,
raiion cf oiGtecn croos will feature additional input traifs such as
■' s rt'sects as well as more efficient use of water and
iC'-- •.ph ar;t=^ ‘'•ans including:
Protectuu] the Bju’inmment
Environmental bei'icflis frorr? biolsch inj
jt traits add up _ . . tj,
qiiici':iy in pounds of herbicides and insecticides eliminated g ’
from the production system. For example; S
• Herbicide-ioierani soybeans and cotton reduced U.S. s f i
herbicide usage in 2007 by 47.4 million pounds of active g
♦ insect-resistant colton and corn varieties decreased S '
insecticide applications that year by 8.67 million pounds ^ I * I
of active ingredient, • *
There are significant long-term benefils. too. The adop- vSW ^ ■
tion of biotech crops - especially soybeatis - closely tracks ‘ ji.V
the expansion of conservation tillage and no-tiif producto.
Between the introduclion of Roundup Read/^ soybeans in '"1 ’ ■**’
1996 and the 2008 cropping season, the U.S, acreage
no-titled fuil-season soybeans grew by nearly 70 percent.
Conservation tillage and no^til! improve soil qualify, conserve water and provide wildlife
haijitat. They also significanity reduce soil erosiori, nutrient enrichment of streams and herbi-
cide runoff, in fact, a number of studies show reductions in soli loss of more than 90 percent
and reduced movement of tola! phosphorus by more than 70 percCTt on no-tili fields.
High-residue farming practices also build up soil organic matter by capturing and storing
atmospheric carbon. In fact, reducing tillage can quadruple carbon sequestration in crop-
land soils, and no-tii! can increase annual carbon storage five-fold. Reducing or eliminating
tillage also lowers fuel consumption, cutting greenhouse gas emissions further. In all, con-
servation fittage and no-tiil can significantly improve the cartson footprint of farm operations.
Markets for water quality and carbon credits are emerging that could make environmental
services sucti as combating water pollution artd sequestering carbon - which ccstservation
farming practices can often accomplish more cost-effectively than many alfernatives - into
income opportunities for farmers.
Beet Option
No Ollier optioris have been identified with the potential to improve yields and safeguard the
environment as well as biotecti crops farmed with sustainable p.-'acticss.
Every ton cf soil saved on the field, every pound of pesticide that doesn’t have to be
applied, every dollar that helps a farmer stay economically viable and every bushel cf yield
orcrduced is a milestone in the effort fo provide frx a steadihy increasing global population.
228
J Reduces labor, saves time
As little as one trip tor planting compared to two
or more tillage operations means fewer hours or^
a tractor and fewer labor hours to pay ... or more
acres to farm. For instance, on 500 acres the
time savings can be as much as 225 hours per
year. That’s almost four 60-hour weeks.
2 Saves fuel
Save an average 3.5 gallons an acre or 1 ,750
gallons on a 500-acre farm.
2 Reduces machinery wear
Fewer trips save an estimated S5 per acre on
machinery wear and maintenance costs— a
$2,500 savings on a 500-acre farm.
^ Improves soil tilth
A continuous no-till system increases soil par-
ticle aggregation (small soil clumps) making it
easier for plants to establish roots. Improved soil
tilth also can minimize compaction. Of course,
compaction is also reduced by reducing trips
across the field.
2 Increases organic matter
The latest research shows the more soil is tilled,
the more carbon is released to the air and the
less carbon is available to build organic mat-
ter for future crops, in fact, carbon accounts for
about half of organic matter.
^ Traps soil moisture to improve water avaliability
Keeping crop residue on the surface traps water in
the soil by providing shade. The shade reduces wa-
ter evaporation. In addition, residue acts as tiny dams
slowing runoff and increasing the opportunity for water
to soak into the soil. Another way infiltration increases
is by the channels (macropores) created by earthworms
and old plant roots. In fact, continuous no-till can result
in as much as two additional inches of water available to
plants in late summer.
7 Reduces soil erosion
Crop residues on the soil surface reduce erosion by
water and wind. Depending on the amount of residues
present, soil erosion can be reduced by up to 90%
compared to an unprotected, intensively tilled field.
Q Improves water quality
Crop residue helps hold soil along with associated
nutrients (particularly phosphorous) and pesticides
on the field to reduce runoff into surface water. In fact,
residue can cut herbicide runoff rates in half. Addition-
ally. microbes that live in carbon-rich soils quickly
degrade pesticides and utilize nutrients to protect
groundwater quality.
Q Increases wildlife
Crop residues provide shelter and food for wildlife, such
as game birds and small animals.
10
Improves air quality
Crop residue left on the surface improves air quality
because it: Reduces wind erosion, thus it reduces the
amount of dust in the air; Reduces fossil fuel emissions
from tractors by making fewer trips across the field; and
Reduces the release of carbon dioxide into the atmo-
sphere by tying up more carbon in organic matter.
Source: Purdue University/Conservation Technology Information Center
Farm&FoodFACTS '09
37
229
Update on Increasing Crop Productivity
Increasing Crop Prodnctivity to Meet Global Needs for
Feed, Food, and Fuel
Michael D. Edgerton”^
Monsanto Company, St. Louis, Missouri 63167
Global demand and consumption of agricultural
crops for food, feed, and fuel is increasing at a rapid
pace. This demand for plant materials has been
expanding for many years. However, recent increase
in meat consumption in emerging economies together
with accelerating use of grain for biofuel production in
developed countries have placed new pressures on
global grain supplies. To satisfy the growing, world-
wide demand for grain, two broad options are avail-
able: (1) The area under production can be increased or
(2) productivity can be improved on existing farm-
land. These two options are not mutually exclusive
and both will be employed to produce the additional
200 million tonnes/year of corn (Ze« mai/s) and wheat
{Triticum aesHvum) estimated to be needed by 2017.
Both options will alter the environmental footprint of
farming. Of the two options, increasing productivity
on existing agricultural land is preferable as it avoids
greenhouse gas emissions and the large-scale disrup-
tion of existing ecosystems associated with bringing
new land into production. In the United States,
breeders, agronomists, and farmers have a documented
history of increasing yield. U.S. average com yields
have increased from approximately 1.6 tonnes/ha in
the first third of the 20th century to today's approxi-
mately 9.5 tonnes/ha. This dramatic yield improve-
ment is due to the development and widespread use of
new farming technologies such as hybrid com, syn-
thetic fertilizers, and farm machinery. The introduc-
tion of biotechnology traits and development of new
breeding methodology using DNA-based markers are
further improving yields. Outside the United States,
similar farming practices have been adopted in
some agricultural nations, but in many major grain-
producing countries, yields still lag well behind world
averages. By continuing to develop new farming tech-
nologies and deploying of them on a global basis,
demand for feed, fuel, and food can be met without the
commitment of large land areas to new production.
Global demand for corn and wheat is growing at a
rapid pace. As disposable incomes have risen in de-
veloping countries, meat consumption has increased.
Among urban Chinese, meat consiimption rose from
’* B~ma0 miko.edgerton@rnonsantO-Com.
The author responsible for di.s{ribuiion of tnaterials integral to the
findiiAgs presented in this article in accordance wifli 8>e policy
described in the instructioas for Authors (vvww.pJantphysiol.org) is:
Michael D. Edgerton {mike.edgt’rton@monsantoxom}.
\vww.plantphy5iol.org/cgi/doi/Tl).n04/pp.l08.j:W195
25 kg person"’ year '^ to 32 kg person"^ year"’ be-
tween 1996 and 2006 (von Braun, 2007). It is antici-
pated that meat consumption will continue to grow in
developing countries because global consumption
levels remain far below the approximately 100 kg
pei^n"’ year"’ meat consumption rate of the United
States and many western European countries. Glob-
ally, meat consumption is expected io grow by 55
million tonnes to Mo million tonnes/year over the
next decade (OECD-FAO, 2008). I>UTing this same
period, biofuel production from corn and, to a lesser
extent, wheat is expected to grow by 28 billion liters to
67 billion liters/year (Fig. 1). Meeting the expected
demand for meat will require feed grain usage to
increase by about 50 million tonne.s to about 640
million tonnes/year. Concomitantly, grain consump-
tion for biofuel production is likely to increase by
about 60 million tonnes to about 145 million tonnes/
year. When food use for corn and wheat is added to the
calculation, total demand for com and wheat over the
next decade is expected to increase by about 15% or
about 200 million tonnes/year to a total of approxi-
mately 1.5 billion tonnes/year (Table I; FAPRI, 2008).
The Food and Policy Research Institute (FAPRI)
estimates that an additional 6 million ha of corn and
4 million ha of wheat plus a roughly 12% increase in
global corn and wheat yields will be used to produce
this additional 2(K) million tonnes of grain. Both in-
creases in planted area and increases in yield are likely
to be needed to meet global demand for grain. How-
ever, improving yield on existing agricultural land will
have a lower environmental impact than bringing new
land into production. Cultivation of new acreage re-
quires land clearing and subsequent tillage that results
in significant greenhouse gas emissions (Fargione
et al., 2008) also has negative impacts upon biodiver-
sity and water quality (Foley et al, 2005).
Increasing the productivity of existing agricultural
land will also have environmental consequences (Tilman
et al, 2002), but the negative consequences are gener-
ally less onerous and in some cases can be positive,
depending upon how the land was previously used.
Increased use of nitrogen fertilizers, a concern with
both methods of increasing production, can increase
nitrous oxide emis.sions, reduce water quality, and
increase the size of hypoxic zones (Donner and
Kucharik, 2008). However, incremental yield increases
can be achieved on existing agricultural land through
conserv^ation tillage or transgenic insect control. Con-
servation tillage can decrease erosion, conserve soil
7
Plant Physiology, janiiary 2009, Voi. 149. pp. 7-13, www.plantphy'siol.org © 2(XB .American Society of Plant Biologists
230
Edgerton
2007 2017 2007 2017
Figure 1. Estimates of globai meat consumption and grain-based
biofiiei production. A, Ciobal meat consumption estimates from
OECD-FAO (2008). Meat consumption outside of the OECf) is ex-
pected to increase by 48 million tonnes/year in the next decade. B,
Global grain-based biofuel production estimates from FAPRl (2(X)8,'.
Crain-based biofuel production is expected to increase by 28 billion
liters/year in the next decade.
moisture, and increase soil organic matter (Lai, 2004),
and transgenic insect control can reduce broad spec-
trum insecticide use (Qaim and Zilberman, 2(X)3;
Cattaneo et al., 2006).
Global corn yields average 4.9 tonnes/ha and have
been increasing steadily for many years (Fig. 2). This is
encouraging, but yields in major grain-producing
countri^ are nearly double the globai average, sug-
gesting tliat there is room for significant improve-
ments in global yields. Average corn yield in the
United States is 9.4 tonnes/ha and Canadian farmers
attain average yields of 8.2 tonnes/ha with this crop of
tropica! origin. In contrast, corn yields in the 10 largest
Iow'er-)neIding corn-producing countries are just 2.8
tonnes/ha (Table II; FAO, 2008), well below the global
average. Much of the disparity in yields can be as-
cribed to agronomic practices, such as the use of open-
pollinated corn varieties instead of hybrids, low input
rates, or poor soil management. Brazil (29%), India
(56%), and Romania (57%) all plant significant
amounts of open-pollinated varieties. Weather is also
a significant factor in some countries, but the use of
less robust production systems can magnify the effects
of unfav'^orable weather in countries such as South
Africa and Romania, increasing the use of modern
farming practices in these countries, together with the
infrastructure, marketing, and risk management tools
needed to support them, could lead to significant
increases in crop production that limit the need to
bring incremental land into production.
Higher crop prices, prompted in part by rising
demand, have increased costs for urban consumers,
especially those in poorer countries. Fiowever, higher
crop prices will also provide farmers with the eco-
nomic incentive to invest in farming methods and
technologies that improve crop yields (von Braun,
2007; Gallagher, 2008). Raising corn yields in the 10
largest, below average, corn-producing countries to
just the world average will result in the production of
an additional 100 million tonnes of corn or about 80%
of the projected growth in demand by 2017. Implicit in
this scenario is the idea that rising yields will mark-
edly diminish the global need for new crop acreage.
Rates of gain for yield have changed as new agri-
cultural technologies have been developed and adopted
(Griiiches, 1960; Troyer, 2006). Average annual com
grain yields in the United States were relatively steady
at approximately 1.5 tonnes/ha prior to the 1930s.
Yields began to increase when hybrid corn was first
introduced and the rate of gain accelerated further
in the 1950s as single cross hybrids were introduced
2007
□ China
eEU
OUS
Table 1. Glolynl corn snd wheat production arni cotisumptkm cstinnUes from FAPRI's 2008 U.S. and
World Afiricultural Outlook
All values arc in million tonnes/year.
Crop
Crop Year
Production
Feed
Fuel
Foori/Other
Corn
07/08
767
492
84
191
17/18
896
528
143
225
Increase
129
36
58
35
Wheat
07/08
603
98
1
303
17/18
688
113
3
.572
Increase
85
14
2
68
Combined
07/08
1,370
590
85
694
17/18
1,584
641
146
797
Increase
214
50
60
103
8
Plant Physiol- Vol. 149, 2009
231
Increasing Crop Productivity
Figure 2. Annual corn yield averages and area planted in the United
States and the world. Yield rate of gain in the United Slates from 1 961 to
2007 was 0,1 1 tonnes ha '* year ' ^ Global yield rate of gain was about
half of this at 0.06 tonnes ha" ' year Globa! corn area harvested has
been increasing at the rate of 0.9,1 million ha,'^'ear, in the United States,
corn area harvested increased by approximately 5 million ha in 2007
and 2008, although the long-term trend is much lower at 0.15 million
ha/year fFAO, 2008), Lines indicate yieid trend Itr«;.
(Troyer, 2006; Fig. 3A), Similarly, U.S. sorghum {Sor-
ghum bicolor) yields increa.sed sharply in the 1950s as
hybrid sorghums were adopted (Miller and Kebede,
1984). Since that time, yield has improved steadily
because of fertilizer management, the development of
more efficient farm machinery, and the breeding of
hybrids with improved stress tolerance that in turn
enabled higher plant populations (Tollenaar and Lee,
2002) and earlier planting dates (Kucharik, 2008).
Genetic gain experiments, in which hybrids that
were widely grown at different points in time, often
referred to as era hybrids, are compareci side by side in
the same trials, have been employed to estimate that
about K)% of the yield gained between the introduc-
tion of hybrid corn, and today is derived from breed-
ing and the remainder from improved agronomic
practices (Duvtck, 2005). Similar results have been
reported from studies in France, Canada, and Brazil
(Ru^ell, 1991; Duvick, 2005). As new farming tech-
nologies are adopted by fanners, the gap betu^een test
plot results, such as those reported by Duvick, and on-
farm yieid averages decreases. Between 1935 and 1990
this gap shrank from about 3.0 tonnes/ha to about 1 .8
tonnes/ha. However, as rates of gain derived from
breeding have increased in recent years (Fig. 3B), this
gap appears to have widened again. This observation
supports the hypothesis that the immediate future will
witness a shift in average rates of gain as newer
hybrids are adopted more widely in the United States
and elsewhere.
Marker-assisted breeding and biotechnology traits
are relatively new technologies for the improvement of
productivity. Incorporation of these technologies into
crop improvement programs is likely to increase rates
of gain beyond those seen in the last few decades.
Results from a Monsanto Company study of a large
number of commercial com and soybean {Glycine max)
populations indicated that use of markers can improve
the rate of gain for yield and associated traits such as
grain moisture and stalk lodging (Fig. 4; Eathington
et ai., 2007). Likewise, the suite of biotechnology traits
currently used in commercial production in the United
States increases average yields by protecting corn from
the stress of competing pests and weeds (Fig. 5). Data
Table !l. Average corn yields from high- and low-yielding countries
Values are ,5-year averages from 2003 lo 2007 (FAG, 2008). Yield, harvested area,
averaged independently and do not nrx;essari!y sum across this table.
and production wrtre
C<Hm!ry
Area
Yield
Pfodudion
million ha
tonnes/ha
million tonnes
High-yielding countries
64.4
7.5
482
United States
30.5
9.4
287
China
26.2
5.2
1 36
Argentina
2.5
6.8
17
Franco
1.6
8.4
14
Hungary
1.2
6.4
8
Canada
1.2
8.2
9
Italy
1.1
8.8
10
low-yielding countries
48.0
2.8
1.32
Brazil
12.7
3.4
44
India
7.6
2,0
15
,Mexico
7.4
2.9
21
Nigeria
3.8
1.6
6
Indonesia
3.4
3.4
12
Tanzania
2.9
1.1
3
South Africa
2.9
.3.1
9
Romania
2.7
3.4
9
Philippines
2.5
2.2
6
Ukraine
1-9
.3.7
7
Plant Physiol Vol 149, 2009
232
Edgerton
B 15.0
•5s
E 5,0
3
1
A A
A ®
4
I
A
i
&
A
A
d
#
#
•
•
• US National average
£i Iowa state average
aDEKALB RMIIO
0.0 'I 1 >
2000 2001 2002 2003 2004 2005 2006 2007
Figure 3. U.S. c(3rn yield averages compared lo yields obtained with
widely used hybrids in test plots. A, National and Iowa corn yield
averages (USDA ERS, 2008); Duvick’s era hybrid average yields are
from Dijvick (1 997). Iowa state averages are inclufJed as the era hv'brki
experiments were conducted in Iowa. The yield differeirtial tretwec'ii
lest plots grown in Iowa and tlie Iowa stale averages can be senm to
decrease over time from approximately 3 tonnes/ha in 1936 to 1942 to
approximately 1.8 tonnesAia in 1988 to 1991. B, Genetic gain study of
DEKALB commercial hybrids released from 2001 through 2006 in the
1 IQ-day relative maturity group (RMIIO), a region of the corn hell
stretching across central Iowa, New KM1 10 commercial hybrids intro-
duced from 2001 ihrough 2006 were tested at 20 locations/year from
2005 through 2007 to produce ihc reported yield averages. Ail seed
was from the same nursery and none of the hybrids contained biotech-
nology traits (Trevor Hohls, personal communication). Annual yield
improvement was estimated at 0.24 tonnes ha' ’ year ' ’ for this group of
hybrids and average yields were .3 tonnes/ha greater than iiwa and 4.2
tonnes/ha greater than the U.S. national average for this set of hybrids,
documenting the resulting reduction in risk to growers
has been rigorously reviewed and acknowledged via
the Federal Crop Insurance Corporation's Biotech
Yield Endorsement, a risk management instrument
that offers an insurance premium rate reduction for
farmers using a suite of biotechnology traits {USDA
FCIC, 2008). In 2008, farmers in the United States have
planted 11 million ha of triple-stacked corn containing
biotechnology traits that provide resistance to com
borers, com rootw'orm, and the herbicide glyphos-
phate (Monsanto, 2008). While the yield benefits of
these biotechnology traits vary from year to year, this
level of planting will increase corn supply in the
United States by approximately 5% if yield results
seen in 2005 to 2007 are manifested in the 2008 grow-
ing season. The contribution of biotechnology traits to
world com supply will increase as they are used more
widely.
The next generation of commercialized, biotechnol-
og)' traits is likely to have a larger impact on crop
yields. Improved drought tolerance will be one of the
next major, transgenic technologies brought to the
marketplace (Fig. 6; Nelson et at, 2007; Castiglioni
et a!., 2008). Drought tolerance has the potential to (1)
inercase yields in drier areas, (2) increase average
yields in rain-fed systems by reducing the effects of
sporadic drought, and (3) decrease water require-
ments in irrigated systems. Similarly, biotechnology
traits that improve yield (Lundry et a!., 2008) or oil
concentration in soybean (Lardizabal et al., 2008)
should improve global supplies of vegetable oil and
protein meal. The first of these biotechnology traits, a
higher-yielding, glyphosphate-tolerant soybean will
be offered commercially in 2009 and commercializa-
tion of improved drought tolerance traits is expected
around 2012. The transgenes described above are at
relatively advanced stages of commercial develop-
ment. A larger collection of transgenes derived from
large-scale screening programs such as those de-
scribed by Riechmann et al. (2000), Van Camp (2005),
and Creelman et al. (2008) are at earlier stages of
development. Biotechnology traits that improve grain
yield and nitrogen use efficiency in replicated multi-
year field trials are expected to reach farmers' fields in
the second half of the next decade (Padgette, 2008).
Figure 4. Breeding rates of gain for a multitrait index for 248 corn
pt^ulalions initiated across 3 years. The rnultitrait index is weighted
toward yield, but also incorporates other agronomic traits such as grain
moisture and stalk strength {Eafhington et al., 2007).
10
Plant Physiol. Vo). 149, 2009
233
Increasing Crop Productivity
® Tripie Stack S Non-transgenic
Figure 5. Yield advanfage of tripie-jtack Cf>rn. Corn hybrids expressing
either three biotechnology traits {YicIdGard Pius with Roundup Ready
Corn2 or YieidGard VT Triple) or without any biottxhnology traits were
tested in yield trials at the indicated numb<;r of locations across the
United Slates in 200S, 200b, and 2007. Average yield values are shown
in the bars and the yield difference between triple-slack and non-
transgenic corn is indicatc*d in the text above the bars. These are
average values from yield trials run across corn-growing regions in the
United States. Values can be significantly higher in regions with more
insect pressure. Nontransgenic corn was treatc'ri with insecticide to
control corn rootworm.
soybean, new varieties adapted to loca! conditions will
be produced as a part of the ongoing breeding pro-
gram. Unfortunately, this is not the case for crops such
as wheat and rice {Oryza sativa) that lack the support of
large, private breeding programs. Accordingly, in-
creased public support for crop improvement efforts
are sorely needed if new wheat and rice varieties are to
be adapted to changing local climatic conditions. This
is particularly true for regions of the world predicted
to undergo more dramatic near term changes in cli-
mate than the central United States.
Nitrogen is another factor that may limit crop )deids.
Nitrogen may become less available as the cost of
fertilizer rises and the continued growth of eutrophic
dead zones and nitrous oxide emissions leads to
changes in the way fertilizer is used (Dormer and
Kucharik, 2008). Nitrogen use efficiency, defined as the
amount of crop produced per unit of input, has
steadily improved in the United States since the
1980s (Frink et al., 1999). More precise nitrogen appli-
cations and genetic improvements in crops are likely
to sustain improvements in nitrogen use efficiency
although there is a limit to how far nitrogen applica-
tion can be reduced. A 10 tonnes/ha corn crop con-
tains around 100 kg nitrogen/ha as protein and at least
this amount of nitrogen must be added back to the
field to maintain fertility. Lastly, a sharp downturn in
the global economy could restrict demand for both
meat and fuel in ways that reduce the economic
incentive to increase crop yields (IMF, 2008).
The combination of marker-assisted breeding, bio-
technology traits, and continued advances in agro-
This group of genetically identified biotechnology
traits are referred to as yield-enhancing traits, but the
increase in yield may be due to an increase in yield
potential and/or an improvement in tolerance to one
or more stresses. Collectively, the next generation of
biotechnology traits should contribute significantly to
productivity on existing cropland, thereby increasing
grain supplies and reduce the need to bring new land
into production.
While breeders, agronomists, and farmers are work-
ing to increase yields, a number of factors that may
reduce yields must be considered. Over the next two
decades, climate change effects in the central United
States are predicted to increase night air temperatures,
the number and severity of adverse weather events,
and increase the incidence of insect pests and disease.
The result could be a drag on crop yields (Hatfield
et al., 2008). Rapid adaptation of crops to changing
climatic conditions may help mitigate these effects.
Such rapid adaptation may occur for crops supported
by strong breeding programs that continuously de-
velop and introduce superior, locally adapted hybrids
and varieties. New, higher-yielding hybrids produced
from Monsanto's North American com breeding pro-
gram currently have a product half-life of approxi-
mately 4 years and are completely turned over about
every 7 years, raising hopes that, for corn and possibly
20.0 -T-
Figure 6. Yield increase in corn plants expressing espB, a cold shock
protein from Bacillus subtilis. Hybrids from a single triAnsgenic event
were tested in yield trials over i years at managed stress locations. Yield
of the transgenic hybrid fgteen circles) and nontransgenic isogenic
hy4)rids (white circles) at individual locations arc plotted against the
yield of all entries tested at that location (Castiglioni ct al., 2008).
Plant Physiol. Vo!. 149, 2009
U
234
25.0
: OBiotechnoiogy traits
Figure 7. Anticipated impact of improvorntmts in agronomics, breed-
ing, and biotechnology on average com yields in the United States.
Rate of yi(?Id improvement due to breeding is extmpoiated from
observations such as those shown in figure 3B, using data extending
across maturity groups from Monsanto's North American cwn breeding
program. Agronomic {planting density, fertilizer use efficiency, im-
provements in soil management) contributions to the rate of yield
improvement are considered to proceed at current historical rates
based on estintates in f!)uvick (2005). Rate of yield improvetnent for
biotechnology traits is a combination of the effects of current yield-
protecting biotechnokjgy traits, the introduction of biotechnology traits
for drought tolerance, and additional yield-enhancing biotwhnolc^
traits. Biotechnology contributions to yield from herbicide tolerance,
corn borer, and corn rootworm profet:tion are estimated from the data
presented in figure 5. Biott'chnoiogy contributions to yield from
drought tolerance are estimated from data presented in Figure 6 and
an assumption that drought conditions strong enough to reduce yield
wii! be seen on approximately 1 0% of the planted acrt?s. Biotechnology'
contributions from yield-enhancing transgenes assume the intrcKluction
of three new biotechnology traits with effects similar to those described
by Padgette (2008) ov<^r the course of the next d«:arlt?. In ctach case
bioteclinology trait adoption curves such as those observed for current
commercially available biotechnology trails are assumc*d (Monsanto,
2008).
nomic practices has the potential to double com yields
in the United States over the next two decades (Fig. 7).
Doubling U.S. average yields would raise average
yields to approximately 20 tonnes/ha, values now
seen rarely in nonirrigated corn. The theoretical light-
limited maximum for corn yields in the United States
has been estimated at approximately 25 tonnes/ha
(Specht et al., 1999; Tolienaar and Lee, 2002), close to
the 24.2 tonnes/ha recorded on a 2-ha plot by David
Hula of Charles City, Virginia in the 2007 National
Corn Growers Association Corn Yield Contest. This
fact suggests that corn yields can be doubled without
large increases in yield potential, although significant
improvements in broad stress tolerance, water use
efficiency, and broad dissemination of excellent agro-
nomic practices will be required to approach the Hula
yield on broad acreage. Improving yields in com and
other crops on a global basis will allow farmers to meet
12
global demand for feed, fuel, and food white mini-
mizing the need to bring large amounts of new land
into crop production. Even if crop producers supported
by the agricultural sector fall short of doubling
yields, continued public and private investment in
agricultural technology will lead to significant in-
creases in productivity that will help supply the
world's needs for food, meat, and energy in a sustain-
able fashion.
ACKNOWI.EDGMENTS
Many arfleagues at Mons^uito have contributed to thii^ review. John
Ande/son, Martha Stanton, Beth CaiabotSa, Dusty Tost, Trevor Mohls, and
Paolo Castigiicad ha\’e all provided data, helpful sxiggestion.s on content, or
editing. In addition, a much larger group of people have contributed to the
research and development that has made die inventions described in this
review possible.
Received September 22, 2fX)8; accepted CX'tober 28, 20()v8; published Jainuir\' 7,
20C».
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13
236
Faw<«tt, R., Towery, D. 2002. Conservation Tillage and Plant Biotechnology -
How New Technologies can Improve the Environment By Reducing the Need to
Plow. C<Miservati(Mi Technology Infonnation Center. 1-24.
Q.
CT 3
*< 03
o S
o 13
Conservation Tillage and Plant Biote|:hnology;
How New Technologies Can Improve the Environment Reducing the Need to Ph-
237
Conservation Tillage and Plant Biotechnology:
How New Technologies Can Improve the Environment
By Reducing the Need to Plow
By Richard Fawcett and Dan Towery
Reviewers;
Dave Schertz, U.S. Department of Agriculture, Natural Resources Conservation Service, Washington, DC
Wayne Reeves, U.S. Department of Agriculture, Agricultural Research Service, Soil Dynamics lab, Auburn, Al
Carem Sandretto, U.S. Department of Agriculture, Economic Research Service, Washington, DC
Jerry Hatfield, U.S. Department of Agriculture, Agricultural Research Service, National Soil Tilth Lab, Ames, iA
Terry Riley, Wildlife Management Institute. Washirtgton, DC
American Soybean Association
The Conservation Technology Information Center (CTIC) is a rwi-prcrfit organization dedicated to environmentally responsible and economically
viable agricultural decision-making, CTIC is supported by a partner^ip of indivkJuats. corporations, governmental agencies, associations,
foundations, universities and media.
Mention of product name or company does not constiti^e an endcxsement by CTIC.
Roundup Ready is a regiaered trademark of Monsanto Technology IIC.
Support for the study provided by the Council fcx Biotechnology frifcHtnation.
Conservation Technology Information Center
1220 Potter Drive, Suite 1 70, West Lafavehe. IN 47906 E-MAii: CTiC®CTic,PU.RDUE,EDU
VW' W. CTIC .PURDUE . EDU
238
Table of Contents
iNTRODUCTION : 1
Recreating the prairie soii cycle 1
Conservation tillage benefits the environment 1
Biotechnology and the growth of no-tilt 1
What is conservation tillage? 2
Tillage was once necessary to control weeds, prepare soil 3
Environmental benefits of conservation tiuage 4
Erosion is reduced by nearly 1 billion tons per year 4
$3,5 billion in sedimentation costs saved in 2002 4
Insects, earthworms and microbes thrive 6
Habitat for birds and mammals improves 6
Preventing sedimertt and nutrient loss improves aquatic habitat 7
Runoff into streams is reduced 7
Decreased flooding, increased soil moisture 9
Reducing "greenhouse gases" while enriching the soil 9
improved air quality 1 1
No-tiii saves 3.9 gallons of fuel per acre 11
Trends link biotech, conservation tillage 12
Improvements in weed control 1 2
No-till has grown steadily since 1 994 1 4
Clear association between sustainable tillage and biotech 1 5
Farmers not using h-t seeds not likely to practice conservation tillage 1 6
Summary statement 17
1 7
References Cited
239
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i
RF.CREATING THE PRAIRIE SOIL CYCLE
Two liundred years ago. most of the lands that today-
make up Americas row-crop larms were vast expanses
of grasslands or forests. These areas supported an
ecological cycle that changed radically after settlers
first put plows to the soil.
in the prairies, the annual cycle of gra.sses created
a deep layer of litter, which protected tlje soil from
wind and water ero.sion and temperature extremes.
Soil organisms and insects thrived in the layers of
dead grasses that built up each .season. A.s prairie plants
decayed, carbon and other nutrients returned to the .soil.
Water, instead of mnning olT fields, seeped back into
the soil, replenishing groundwater and nearby .streams.
Nearly two centuries of intensive tillage later, that
cycle has been radicttily allerod. Organic matter ha.s
been lost, and erosion has taken topsoil. Within the
past decade, however, many fanners have begun to
recreate the cycle tltat once characterized the prairie
soils and forests before they were cleared for fanning.
Corn, cotton, soybeans, wheat and other crops have
replaced the tall grasses of the 1 8th century, which
exist only in small pockets today. Neverthelcs.s, the life
cycle of the native soils is slowly returning as farmers
convert their land to soil-saving conservation tillage
while continuing to produce abundant crops.
Instead of plowing and disking their fields before
planting, many farmers are leaving the residue of
the previous crop on the soil surface. 'Ibis layer of
decaying plant material provides protective litter and
bcgiits to create condition.s that existed before people
first began to till the soil.
Conservation tillage benefits
THE ENVIRONMENT
Conservation tillage. a.s defined by the Conseiwation
Technology Information Center, (www.ctic.purdue.edu)
jneans any minimal tillage system that leaves the soil
surface at least 30 percent covered by crop residue.
Fanners employ various conscr\'ation tillage systems,
which leave various amounts of residue. No-till, in
which the soil is left undistuibed by tillage and the
residue is left on the soil surface, is the most effwtive
soil-coii-seiwing system. Re.search shows diat land left
in continuous no-till can eventually create a soil, water
and biokigical sy.stem (hat more closely resembles
characteristics of native soils before the advent of
agriculture. No-lill .systems also can provide cover
for wildlife if the stubble from the previous crop is left
standing. Other studies .show that reducing tillage can
produce many other environttiental benefits, such as:
• Reduced soil erosion.
• Improved moisture content in soil.
• Healthier, more nutrient-enriched soil.
• More earthworms and beneficial soil microbes.
• Reduced consumption of fuel to operate equipment.
• The return of beneficial insects, birds and other
wildlife in and around fields.
• Les.s sediment and chemical runoif entering streams.
• Reduced potential for flooding.
• Le-ss dust and smoke to pollute the air.
• Less carbon dioxide released into the atmosphere.
Biotechnology and the growth
OF NO-TILL
Tlie movement toward leaving more crop residue on
farm ficid.s expanded rapidly in the early 1990s. The
federal government largely drove this by requiring soil
conservation efforts on highly erodibie acres in order
to participate in farm programs. The introduction
of improved high-residue seeding equipment and
improved weed control technology also aided adoption.
The conversion of acreage to conservation tillage
began to level off somewhat by the mid-1990s,
Ilow-es-er, since the niid-1990s, farmers liave been
increasing the amount of residue left on the soil
surface. While reduced tillage practices such a.s
mulch-till and ridge-till have been fairlj' static,
fanners have been moving toward no-ti!i farming.
This agricultural practice, which has the potential
to most closely approximate the tiative soil cycle,
has expanded steadily during the time period when
hejbicide-tolerant crops, dex^eloped through
biotechnology, have been adopted by U.S. and
Canadian farmers.
There is a strong association between tlte u.se
of herbicide-tolerant biotech crops and recent
improvements in tillage reduction. Four trends
sup[X)rt this conclusion;
• Weed control is a major consideration wlien farmers
are weighing whether to implement conservation
tillage, and several surveys indicate that farmers
have more confidence in weed control since the
introduction of herbicide-tolerant biotech crops. In
some surveys, iarmci-s say herbicide-tolerant crops
enabled them to increase the amount of residue they
leave on their fields.
240
• No-tiil, the tillage system that most relies on good
herbicide performance, has grown more Sian other
reduced tillage systems since 1996, and nearly all
the growth has occurred in crops where herbicide-
tolerance technology is available - soybeans, cotteHi
and canola. (Herbicide-tolerant corn has not Iwen
widely adopted due to pending regulatory approval
in Europe, nor has no-till com expanded as rapidly
as other crops.)
■ Fanners who purchase herbicide-tolerant seeds
use them disproportionately on their conserv'ation
tillage acres.
• Farmers who do not purchase herbicide-tolerant seeds
are not as likely to participate in conservation tillage.
llie main reason farmers till their soil is to control
w’eeds. which compete with their crops for space,
nuhients and water and can interfere with harvesting
equipment. Historically, farmers have plowed
under emerged weeds before planting mid tilled
the soil in preparation for herbicides that prevent
additional weeds from emerging. If herbicides
failed due to weather conditions, farmers could
use additional tillage as a rescue.
With herbicide-tolerant crops, farmers allow weeds
to emeige with dwir crops. Then they apply herbicide
over the of their crq), removing the weeds
without harming the crop, which has been modified
through biotechnology to withstand the herbicide.
This improvement in vv^ed control gives increased
confidence that weeds can be controlled economically
without relying on tillage. It partially explains why
no-till farrait^ has been increasing significantly in
crops where the technology is available.
Many analyses have shown that conservation
tillage provides economic benefits by saving
time and reducing fiiel and equipment costs.
Despite these benefits, many farmers were reluctant
to commit to a new system in which they saw
potential risk of yield reduction due to competition
from weeds. The trends since 1996, when herbicide-
tolerant crops were first introduced, provide a strong
indication that improved weed control made possible
with the new biotech crops has given growers the
confidence to increase tlieir u-se of conservation
tillage, especially no-tili.
WHAT IS CONSERVATION TILLAGE?
Crop msldij&s left qiyilifi.soil Hjrfacii prdt^
enerqy of wind and raiixiops. Research: ^lows ihai: reduaions--:^
; hie.Cdntiervaticpif.fe (dticj has:-''"''
ckiOriafvsiidufiiiibqbiSyskiflls'accOTiiiicj'W/tkiWt^
residirti is kifi:®! tfHs.soll surface a'W types csJ iWoqe lools
Conservation tillage - Any Ullbge arid. p^^
lhai covers . rnao . than 30 per(»m of the soil suitK® with oop
(.rasidvibV' bfi'br;' plaitihgijb'''t^(jCe:'spii..»b!«ob!b^
, 'sc'iiii eiPsibh'' t)y''Wirid;.'is ihb.';i»frhafy .epneferh^^bhy'S;^^
nialritaiiifai lea« 1 ,G00 pcHJrxls per. acre ^
residue equivaiefH CXI ilTe.tkirfi^ ttirbiighas.ihbaiiicolwxid: '
erosioiipCTicdivNqtiii;',rfd0fltiti,;brklmjlc^ ;
conservation
Wo-tiir-:T|ie. sqif:
except for piabfingiahcl nijf Sew inj«.iiori i Raniing'-bf'afiHi^^
accompIishCH'i in S (if
rdw.cleahers; disk operwrs; fo-row chisels cx raaiy'ili,t^:''V)^d,'
conlfol .is abcbTiplIslTecl fximarily 'by tiert^.|des., CiAlvafksi'iTiay:
L'e'i.'ised fpr emergency w?ed conwot ' y/ v .Tobd./;:::':.:/:;.'::.'':'':
Ridge-till - i.' -01 is left.i.cidraiirtxk), from harvea k> pSaiXH^^:,
except, k-v ni^rierx irijeciidn. Piarsir^ }scc^pleied'iR'a.'sesdb^.}:-
prepared on ridges with swesxis. disk bj:jeffefs:'GbtiSefS, a'now^^
t;ieanef5. Residue is iefton the swface between
Weed coniroi is accomplisheci with herbicides'dtid/cx,; '■
mechanical cukivaiion. Ridg^ ore reixuR ckrirg
IVhilch-till - ThS'SoilIrs diaurPed prior.tp ■pisfflihg. TlllagQ.icktl'i
ajcrt'as ctHsels. field .cufuvators. flisks.:swe^.' and blades are
; u^,;'..yyeed:COfWd it/acTOmoiisNxJ'wfth %bicidss and/qf: . :
■'m^t^i^&'cuWyaSoRi'T ■"■■'.■■.V'.'. ''
Conventional-tillage loaves iG?5s.'than:i S'.i^n-.ijni fesidtie':. ■
'■■.cOvw''^f' plSr8ir^y''Of less tfian 500 pdi^^ per acre of.smbtl
readue equ'ryatett thfowjhoot the cfticai. wiixl erosion
■i^ipd, 'll -^icBRy' involves .plowing .or intfrayP :iiiiragei . Tilfagp.
,'I^^ti^ie^«'',T5.fd'50 percent .fQsidiie cover after ptaniing .
'of.SDb tb'TiOdO.pPurids'pef acre of small grain residue., ■
'SometBhes are' r^^red-.to.'as reduced tillage, bu rhey' ■
do Rcn qud% as conservation tillage.
2
INTRODUCTiON
NOIl:
241
As a significant percentage of agriculture is left
untilled, more like the original prairies, the water and
soil cycles also will begin to return to a more natural
state. Continued adoption of no-till practices will
bring additional environmental benefits, w’hich include
increasing the amount of topsoil that is saved each
year, reducing runoff into streams and further cutting
back on ftiel use and emissions.
}mpro^'ed weed control available through heihicide-
tolerant crops will be an important factor in continued
adoption of no-till.
Tillage was once necessary
Repeated tillage to prepare crop seedbeds and control
w'eeds was an indispensable component of agricitlture
tmtil the last half of the 20th century. However,
excessive tillage causes soil erosion, thus reducing
the sustainability of agriculture. For example, 100
years after Iowa w'as settled, nearly half the original
topsoil had eroded.' Repeated tillage also can reduce
soil quality and productivity by destroying soil
structure, reducing organic matter content and harming
beneficial invertebrates such as earthworms. Sediment
eroded from intensively tilled fields fouls aquatic
systems, and runoff of water contributes to flooding.
Tillage destroys wildlife food sources and reduces
surface crop residues that serv-e as wildlife cover.
Edward Faulkner was one of the earliest proponents
of eliminating the use of the moldboard plow, the most
widely used primary tillage tool until the late 20th
century. In his 1943 book, “Plowman’s Folly,”- he
called the plow “the villain in the world’s agricultural
drama.” He concluded that plowing crop residues deep
into tlie soil, leaving the soil’s surface bare, reduced
the long-term productivity of the soil. Faulkner wrote:
“Had we not originally gone contrary to the laws
of nature by plowing the land, we would have avoided
tlie problems ... the erosion, the sour soils, the
mounting floodvS, the lowering water table, the
vanishing wildlife, the compact and impervious
soil surfaces.”
Although many of Faulkners predictions of benefits
from w'hat was later to be called “conservation tillage”
turned out to be true, poor weed control, experienced
when tillage was reduced, prevented most farmers
from adopting the systems until the introduction
of herbicides. Development of effective herbicides in
the 1960s allowed farmers to reduce their dependence
on repeated tillage to control weeds. Some eliminated
tillage altogether.
However, weed control challenges and uncertainties
remain. Some problem weeds, such as perennials,
remain difficult to control. A few weeds have
developed resistance to some popular herbicides.
Because most herbicides do not control all weed
species present in fields, farmers often apply two,
three or more herbicides in combination. Effective
weed control with herbicides requires careful
identification of w'eed species and precise application
timing. Crop injury may occur if adverse weather
conditions reduce crop tolerance, or herbicide
residues in the soil injure rotational crops.
Soil-applied herbicides may fail if sufficient
rainfall does not occur to activate the chemical.
Biotechnology has given farmers additional weed
control options by facilitating the development
of crop v'arieties tolerant to herbicides, such as
glyphosate and glufoslnate. These herbicides,
rather than preventing weed growth in the soil, are
applied to emerged weeds and are effective against a
broad spectrum of annual and perennial weeds. They
are well-suited to con.servation tillage systems because
they do not require incoq^oration with tillage tools.
In addition, they are applied at low rates, have low
toxicity to animals and degrade rapidly. They cannot,
however, be used with crops that have not been made
tolerant through biotechnology, because they would
have the same detrimental effect on the crop as they
have on weeds.
As will be discussed later, farmers are using herbicide-
tolerant crops disproportionately in reduced tillage
systems, especially no-ti!l. The majority of such
crops are glyphosate-tolerant; therefore, subsequent
discussion of herbicide-tolerant crops in this report
w'ill focus on glyphosate-tolerant varieties developed
through biotechnology.
3
242
Environmental benefits of
CONSERVATION TILLAGE
As no-ti!l acreage expands, fanners are able to
recreate soil and watei' cycles more closely resembling
characteristics of prairies and woodlands before settles
first put plows to the soil. The residue from the
harvested crop is left on the soil surface. This layer
of leaves and stems mimics the layer of litter that
once covered native soils, protecting the soil from
heat, preserving soil moisture and preventing erosion.
Decaying root channels and burrows from earthworms
serve as macropores, which aerate the soil and improve
water infiltration. Other attendant benefits, including
a return of soil organisms, birds and mantmals, also
are being realized.
Erosion is reduced by nearly 1 billion tons
per year
Conservation tillage is one of the most practical and
economical ways to reduce soil erosion. Reducing or
elijninating tillage operations leaves more crop residue
on the soil surface, protecting the soil from the erosive
impacts of wind and rain. Reductions in erosion are
proportional to the amount of soil covered by crop
residue (Figure 1 ).'
No-til! systems, which leave nearly all plant surface
residue in place, can reduce erosion by 90 percent or
more. The 1997 National Resources Inventory^
showed that dramatic decreases in erosion have
taken place in the United States since 1982. .Much
of this reduction can be credited to the adoption of
conservation tillage by U.S. farmers. Sheet and rill
(water) erosion on cultivated cropland fell from an
average 4.4 tons per acre per year (9,856 kgha/year)
in 1982to3.i ton&’acre/year (6,944 kglia/year) in
1997, a 30 percent decrease (Figure 2). The average
wind erosion rate dropped 3 1 percent. Almost ! billion
tons per year of soil savings have occurred due to these
changes in management- However, erosion is still
occurring at a rate of 1 .9 billion tons per year, and
108 million acres (29 percent of cropland) is still
eroding at exces.sive rates.'
$3.5 billion in sedimentation costs
saved in 2002
The 1998 National Water Quality Inventory reports
that sedimentation is the most prevalent pollutant in
streams that have been identified as environmentally
impaired.* Unacceptable le\'els of sediment occur in
40 percent of impaired stream miles. Bacteria uwe the
second most prevalent pollutant, present in 38 percent
of impaired tniles, follow'ed by nutrients, occurring in
30 percent of impaired miles. Conservation tillage
reduces the nmoff of all these pollutants to svirface
water systems.
Figure 1 . Effect of Residue Cover on Soil Erosion
Residue cover Scxircc lancn e; ai 1 9B5
ENVIRONMENTAL BENEFITS
ENVIRONMENTAL BENEFITS
243
Sediment decreases the storage capacity of reservoirs
and interferes with the navigational and recreational
uses of water. According to a U.S. Department of
Agriculture study, the annual cost of damage to water
quality from sediment originating on farmere’ fields
was S4 billion to S5 billion in the mid-1980s.''
Table 1 shows USDA estimates of the annual offeite
damage from water and wind erosion. ITtese damage
values were calculated considering the cost of
maintenance due to erosion, such as dredging rivers,
cleaning road ditches and treating drinking water,
as well as economic losses. Soil erosion rates fell
30 percent between 1982 and 1997, largely due to the
adoption of conservation tillage by U.S. farmers and
land enrolled in the Conservation Reser\'e Program
(CRP)." The ofi'site erosion damages (S8.78 biUion)
shown in Table 1 were calculated in the 1980s. If
offsite damages are proportional to erosion rates, an
estimated S2,6 billioji annual savings has resulted due
Figure 2. Soil Erosion from Cropland*
Table 1: Annual Offsite Damage from Soil
I Erosion in the United States
Damage Category
Annual Offsite
Damage
(Millions of $)
Water recreation
2,679
Water borage
1 .090
Navigation
749
Flooding
978
Ditches
978
Commercial tlshirig
450
Municipal wafer reatment
964
Municipal and industrial use
1,1 96
Steam power cooling .
24
TOTAL- ■
$8,783
244
to the erosion reduction achieved by farmers
largely through conservation tillage. If adjusted
for inflation this would represent a S3. 5 billion
annual savings in 2002.
Sediment in water also has human health
implications. Sediment and organic carbon
carried on sediment cause problems for water
utilities that use surface water as a drinking U'ater
source. Chlorine used to disinfect water reacts with
organic carbon to produce trihalomethanes such as
chloroform. Due to carcinogenicity, trihalomethanes
are regulated under the Safe Drinking Water Act.
Additional filtering is required to reduce sediment and
organic carbon to prevent Irihalomelhane formation.
Allowed levels of iTihalomethanes are scheduled to
decrease in the future, which will increase costs to
water utilities.
Insects, earthworms and microbes thrive
Stinner tind House'" have reviewed studies of
arthropods and invertebrates in no-till and other
conservation tillage systems. They found that no-til!
crop fields generally have increased divereity of
surface microarthropods. Many beneficial predatory
arthropods, including ground beetles and spideir, are
increased by no-till. For example. House and Pamialee"
found 1 7.6 carabid beetles per square meter in no-till
soybeans compared with 0.38 per square meter in
plowed treatments, Carabid beetles are important
predators of pests in many crops. Mites, which are
important predators of other arthropods and nematodes,
are increased in no-till.'^ Increased diversity of
arthropods with no-til! ha.s been attributed to the
increased structural diversity of litter.
Earthworm populations have consistently increased
as tillage is reduced. House and Parmalee" compared
a field with 17 years of no-lill cropping with a
conventionally tilled field and found from 3.5 to
6.3 times more earthworms in the no-till field.
Earth-worms help incorporate organic residues into
the soil, aerate the soil and improve water infiltration.
Night crawlers (Lumbricus wrestris L.) are large,
surface-feeding earthworms, which live in permanent,
vertical burrow's. Tillage harms earthworms by burying
food sources and destroying burrows. As many as
81,000 burrows per acre (200,000/ha) have been
reported in no-lill fields.'-' Improvements in water
infiltration, which often accompany conversion
to no-till, have been at least partly attributed to
these burrow.s."'
Tillage, which incorporates organic debris into the
soil, is more suitable for microorganisms with higher
himover rates, such as bacteria and baclivorous fauna,
including pit^zoa and nematodes.’’-''' Decomposition
processes in no-tiliage systems are controlled primarily
by fungi, with fungivorous microarthropods, nematodes
and earthworms dominant itt subsequent steps in the
food web.” Fungal dominated microbial communities
of no-till systems store more organic material for longer
periods, resulting in higher steady-state lev'els of
organic matter. Fungal hyphae aid in the formation of
soil a^iegat^ or tiny soil particles bound into larger
units. These aggr^ates aid in improviiig soil structure
and increasing retention of soil carbon. Extracellular
polysaccharides of fungi also are important in the
formation of soil aggregates. Soil aggregates allow
for the most desirable mix of air and water for good
plant growth.
Total microbial populations are often higher in no-till
soils than in tilled soils. Doran'* found that counts of
aerobic microorganisms, facultative anaerobes and
denitrifiers in the surface of no-till soils were higher
than in the surface of plowed soil. Phosphatase and
dehydrogenase enzyme activities and contents of water
and organic carbon and nitrogen in the surface of
no-till soil also were significantly higher than those
for conventional tillage. Such increases in microbial
activity have been associated with increased rates of
herbicide and insecticide degradation with no-till.’*-”
Rapid degradation of pesticides is one of the factors
that reduce their potential to enter surface or ground-
water supplie.s.
Habitat for birds and mammals improves
Research shows that no-till fields provide food and
habitat for birds and mammaLs. Insects and other
arthropods, which thrive in the protective residue in
no-till fields, arc important food sources for many
birds. Palmer" studied bobwhite quail {Colimix
virginianus) behavior in no-fill arid conventional fields
in North Carolina. The research showed that quail
chicks needed 22 hours to obtain their minimum daily
requirement of insects in conventional soybean fields.
In no-till scybean fields, only 4.2 hours were required
to obtain the minimum daily requirement, about the
same as the 4.3 hours required in natural fallow areas
believed to be ideal quail habitat (Figure 3).
Cov^r provided by crop residue, plus waste grain and
'freed food sources left on the soil surface, along
with less disturbance from field operations, are all
beneficial to wildlife. Many studies have shoum that
no-till row crop fields have higher densities of birds
and neste mid are used by a greater variety of bird
species during die breeding season than tilled fields,-' --
Bird nesting success in conventionally tilled row-crop
6
ENVIRONMENTAL BENEFITS
245
CO
tz
UJ
m
7
Figure 3. Time Needed for Bobwhite Quail Chicks to Satisfy Daily insect Requirements*
25 ^
0 No-till Field Edge Conventional Tillage
Scxjrc'c: Pairntx 1995 Soybean field '''tO lo Kldayoia chicks.
fields is usually below levels needed to sustain
populations, often because field operations disrupt
nests,-’ As fewer trips over the field with equipment
are made with conservation tillage, nesting is favored,
particularly for species titat normally raise only one
brood per year, such as the ringneck pheasant. Grassy
nesting cover adjacent to no-till fields provides even
more favorable habitat.
Small mammals also favor conservation tillage.
In Illinois, no-till cornfields had more abundant and
more diverse invertebrates, birds and small mammals
than conventionally tilled com.- Small-mammal
populations, particularly deer mice, were more stable
in no-tiil. Management changes can fiirther improve
wildlife habitat provided by no-till fields. Leaving
stubble 1 0 to 14 inches tall when har\'estjng small
grains provides impro%'ed habitat compared wifli
shorter stubble heights. Additional re.search is needed
to determine how to maximize the wildlife benefite
of conservation tillage.
Preventing sediment and nutrient loss
improves aquatic habitat
Sediment in rivers, streams and lakes covers grawl
beds needed for habitat by fish and crustaceans.
Sediment also clouds water, reducing sunlight
penetration and reducing photosynthesis of
submerged plants and algae, causing a cascading
effect through food chains, Conservation tillage’s
ability to dramatically reduce erosion reduces
delivery of sediment to aquatic systems, improving
aquatic habitats.
Excessive loads of the nutrients phosphorus and
nitrogen from agricultural land and other sources can
lead to excessive growth of aquatic plants. When these
plants decompose, oxygen concentrations in water
can drop to levels too low to support some aquatic
organism-s, a condition called hypoxia. Hy^toxia can
occur in fresh water bodies or marine environments
such as the Gulf of Mexico.’* Because conservation
tillage reduces nutrient losses, it is an important tool
in reducing agriculture’s impact on hypoxia.
Runoff into streams is reduced
As portions of agriculture are returned to an unfilled
state more like the original prairies and forests, the
w'ater cycle also will return to a more natural state.”
With less water runoff and more inliltration, streams
are fed more by subsurface flow than surface runoff.
This allows better use of water and nutrients by crops
and allows soil clay, organic matter and biological activ-
ity to filter the water before it becomes surface water.
246
Decreased runoff means that fewer pollutants enter
streams. Several paired watershed studies showed
that no-till I’ields produced no seasonal runoff' while
conventional tillage watersheds had significant wafer
runoff, soil erosion and pesticide An Ohio
study compared total w'ater runoff' from a !. 2-acre
(0.5 ha) watershed with 9 percent slope that had been
farmed for 20 years in continuous no-lill com to a
similar conventionally tilled watershed. Over four
years, runoff was 99 percent less under the long-temi
no-till. I'his decrease in runoff was attributed to
increases in infiltration due to development of soil
macropores in the absence of tillage,"' Cracks, root
channels and earthwomr holes allow water to bypass
upper soil layers when rainfall exceeds the capacity
of soil to absorb water through capillary flow, the
movement through tiny spaces between soil particles.”
show reduction in phosphorus fertilizer runoff if the
fertilizers are suteurface band-applied instead of
surface-af^lied. Andraski ei a!/' compared runoff'
losses of phosphate from four tillage systems when
fertilizCT was subsurface banded in all systems. Three
reduced till^e ^tems — no-till, muich-tiil and
strip-till — reduced total phosphate losses by 8 i ,
70 and 59 percent respectively, compared with the
moldboard plow. Soluble phosphorus losses also
were reduced 1^' no-till and mulch-tiil, which employs
a chisel plow. When total phosplionis tosses were
compared in no-tiil and conventional tillage, a 97
percent reduction in soil erosion with no-till resulted
in an 80 to 91 percent reduction in pitosphoms loss’”
for st^beans following com. For com following
soybeans, an 86 percent reduction in soil loss led
to a 66 to 77 percent reduction in phosphorus lost.”'’
When runoff is reduced, the flow of polhitants such
as sediment, feniiizera and pesticides also is reduced.
Pesticides and fertilizers enter surface waters in liquid
solution or attached to sediment that washes off farm
fields. Studies have demonstrated how no-till reduces
chemical runoff. Baker and Laflen’“ found that a 97
percent reduction in sediment loss for no-till (relative
to the moldboard plow) resulted in a 75 to 90 percent
reduction in total nitrogen loss for soybeans planted
following corn and 50 to 73 percent reduction in
nitrogen loss for com following soybeans. Studies
Runoff of pesticides, both soil-attached and
dissolved, usually is reduced in conservation tillage.
No-tii! sometimes has resulted in complete elimination
of pesticide mnoff.^ ” A summary of published
nanirai rainfall studies comparing no-till with
moldboard plowing show'cd that, on the average
(over 32 treaonenf-site-years of data), no-iill resulted
in 70 percent less herbicide runoff, 93 percent less
erosion and 69 percent less water runoff than
moldboard plowing (Figure 4).’-
Fii^re 4. Runoff and Erosion in No-tilt Watersheds Compared to Conventional Tillage Watersheds
100
247
Other conservation tillage systems also have reduced
tierbicicie riinofi' In a Kentucky natural rainfall study,
botii no-tiil and chisel plowing (mulch-tillage) reduced
runoff of atrazine, simazine and cyanazine by more
than 90 percent, compared with nwldboard plowing.”
Ridge-till has reduced herbicide runofFby an
average 42 percent in natural rainfall studies.”
Because no-till often increases water infiltration,
some feared that this tillage system might also
increase leaching of chemicals through the soil profile
to groundwater. Several studies have shown, however,
that no-till either had little impact on nitrate leaching
or decreased leaching slightly.’*- A few studies have
shown increased leaching of certain pesticides to
sliallow depths in no-till compared wdlh tilled .soil,”-’*
while others have documented less leaching of
pesticides with no-til!.”-*'"-*’-*’-" As crops genetically
modified to tolerate liie herbicide glyphosate are
increasifigly planted in no-till systems, leaching
potential sliould be lessened, because this compound
binds tightly to the soil and is highly unlikely to
move to groundwater. Reductions in leaching of
other herbicides used in no-till may be due to greater
microbial activity degrading the pesticide, greater
oiganic matter adsorbing the pesticide or to water
bypassing upper layers of soil containing the pesticide,
due to flow down macropores. The mucous lining
of earthworm burrows has also been shown to adsorb
pesticides.*-' When the herbicide atrazine was poured
down night crawler burrows, concentrations exiting
at the bottom were reduced tenfold. Although
conservation tillage has not always reduced pesticide
leaching, because of favorable results in many studies,
no-till is recommended as a practice to reduce
pesticide leaching by some water quality specialists.*’**
Decreased flooding, increased soil moisture
Reduced runoff due to conservation tillage also is
associated with decreased flooding. Such a decrease
was docuniented on the Pecatonica River in Wisconsin.
A decrease in flood peaks and wimer/spring flood
volumes accomp^ied by an increase in base flow (due
to infiltration) was documented. The changes were not
correlated to climatic variations, reservoir construction
or major land use changes but appeared “to have
resulted Irom the adoption of various soil conservation
practices, particularly those involving the treatment
of gullies and the adoption of coiKervation tillage.”**
Conservation tillage not only reduces water loss
through runoff’ it also reduces evaporation losses
so that more .soil moisture is preserved for crop
production. In one study, cumulative water losses
for the first five hours after tillage w'ere 0.1 13 in.
(0.29 cm) with conventional tillage vs. 0.052 in. (0.13
cm) for no-till.*' In Kentucky, annua! evaporation was
reduced by 5.9 inches (15.0 cm) with no-till.** In areas
where rainfall is limited, such as the Great Plains of the
United States, grain production is made possible by
fallowing land. No crop is planted for a year or part
of a year so that soil moisture can be stored for use by
tlie next planted crop. Weeds must be controlled during
the fallow period to prevent them from drawing
moisture out of the soil. Traditionally, weeds in fallow
land were coittrolled by repeated tillage operations.
However, tillage increases evaporation losses, causes
wind and water erosion and disturbs wildlife habitat.
Chemical fallow or ecofaliow systems, which use
herbicides to control weeds, have been developed for
crops planted no-till following the fallow period.”-'"
In Kansas, Norwood” found that water use efficiency
was increased by 28 percent in no-till com grown in a
wheat-corn-fallow rotation, compared with conventiottal
tillage. Corn yields were 3 1 percent higher with no-fill.
Widespread adoption of these conservation systems
across the Great Plains has improved the economic
welfare of farmers, as well as reduced erosion and
improved wildlife habitat.
Irrigation efficiency also is improved by conservation
tillage. More moisture from rainfall is .stored, and more
of applied irrigation water infiltrates to be used by
crops. The residue on the soil surface also redtjces
crop evapotranspiration. Improved irrigation efficiency
benefits farmers by increasing yields and decreasing
pumping and irrigation water costs while protecting
aquifers from depletion.
Reducing "greenhouse gases"
while enriching the soil
Soil organic matter is considered to be the largest
terrestrial carbon poof’ and influences the atmospheric
content of CO:, CH* atid other greenhouse gases. ”
Soil oiganic matter can serve as a source or a sink
for atmospheric carbon.** Conservation tillage,
especially no-ti!i, increases the ability of soil to
store or sequester carbon, simultaneously enriching
the soil and protecting the atmo.sphere.
Tillage increases the availability of oxygen, thus
speeding the microbial decomposition of soil organic
matter. Decomposition releases large quantities of CO:,
a ‘'greenhouse” gas linked to global climate change.
A lO-year analysis of common cropping systems in the
United States showed that no-till farming had far !e.ss
global warming potential than conventional tillage or
organic systems,” The researchers calculated the types
and amounts of greenhouse gases that w-ere emitted or
stored by each cropping activity and calculated a
9
248
numerical value called the gross warming potent!^
(GWP) for each. Conventionally plowed fields had die
highest net GWP (114), compared with 41 foroiganic
farming and 14 for no-till (Figure 5).
By converting land to no-tiii production, rather than
depleting soil organic matter, organic matter can be
increased, sequestering COj from the atmosphere.
Soil organic matter content has increased by 1,000
Ib/acre/year (1 120 kg/Fia/year) in some no-till studies.^^
That is equivalent to 590 Ib/acre (66? kg/ha) carbon
stored per year, compared with tiie 1 5-20 Ib/'acre
( 1 7-22 kg/ha) carbon tiiat was burned as fuel to
produce the crop.
Kern and Johnson’’ projected changes in atmospheric
carbon due to several scenarios involving adoption of
conservation tillage in the United Stales until the year
2020. Converting from conventional tillage to no-till
on 57 percent of crop acres would result in a gain in
soil otganic matter of 80 trillion to 129 trillion grams
(Tg) (Tg = !012g “ 1 million metric tons - 1.102
million tons) and would remove a like amount
of carbon from the atmosphere.
Lai et al.^ have reviewed the impoiiance of cropland as
a source and sink fw atmospheric carbon. The estimated
55,000 million medic tons (MMT) of historic soil-C
less from cultivat«i soils worldwide accounts for about
7 percent of the current atmospheric inventory. They
conclude that cropland soils potentially can sequester
a considerable part of this lost carbon with adoption of
practices such as conservation tillage. Considering US.
cropland, about 5,(MX) MMT of soil organic carbon has
been lost from its pre-agricultuiai levels. The aiitiiors
conclude: ‘X)ne reasonably can assume that cropland
potentially can sequester 4,0(X) to 6,000 MMT, with an
average of 5,000 MMT in cropland soils - potentially
more, wddi new technologies and proper management."
Reicoslgr ef al.^ measured CO: released from soil
after tilling w’heat stubble with various implements in
the fall. Over a 19-day period, one pass of a moldboard
plow caused five times as much CO: to be lost from
ilte soil, compared with untilled plots. More organic
matter was oxidized in 19 days than was produced all
year in wfreat straw and roots, helping explain why
organic matter content has steadily declined in tilled
Figure 5. Gross Warming Potential (GWP) of Various Tillage Systems
Source. Korx.'rv,on. Paju ,?ricJ H^rvvc.-ort Tillage system
10
ENVIRONMENTAL BENEFITS
249
soils until equilibrium is reached. Organic matter
contents of agricultmal soils in the United States
have declined by as much as 50 percent or more due
to this phenomenon. In effect, organic matter has been
“mined" by agriculture. For example, the Morrow
Plots at the University of Illinois were first established
in 1876 and have been maintained in constant
cropping systems to date.’’ Soil organic matter was
first measured in 1903, when levels were about 40 tons
per acre (44,800 kg/ha). By 1973, under continuous
corn production, organic matter content had dropped
to about 20 tons per acre (22,400 kg/ha). Consen-ation
tillage .systems, especially no-till systems, do not
simply stop organic matter loss; they can cause soil
organic matter content to increase. Reicosky et al.
and Reeves found that organic matter has increased by
as much as 1 ,800 pounds/acre/year (2000 kg/ha/j'ear)
in long-term no-till studies.’''"’
Imprt>ved air quality
Conservation tillage, by reducing wind erosion,
also reduces the amount of dust that can enter the
atmosphere, fn some regions, dust from agricultural
fields is a major air quality concern. Wind-eroded dust
also carries other contaminants such as pesticides
and nutrients into the atmosphere where they are
later deposited by rainfall into aquatic systems.'’'
Conservation tillage is also an alternative to the
practice of burning residue left on fields. In some
regions of the United States, crop residue is burned to
facilitate planting of rotational crops. This practice not
only causes air pollution with smoke but also releases
CO’ into the atmosphere and reduces soil quality by
destroying organic matter. Adoption of conserv-ation
tillage systems has significantly reduced the practice
of burning crop residues.
No-tiii saves 3.9 gallons of fuel per acre
As tillage operations in crop fields are reduced or
eliminated w'ith the adoption of conservation tillage,
fuel consumption declines. Fuel usage for no-tili
may decrease from 3.5 gal/acrc (32.7 L per ha) to
5.7 gal/acre (53.3 L per ha) depending on the nmnber
of tillage trips reduced, clay and moisture content
of the soil, and type of tillage operations eliminated.’’
Moldboard plowing typically uses 5.3 gal/acre, chisel
Figure 6. Tillage System vs. Fuel Consumption per Acre
Source )a50, o! Nebraska 1991 Type Of tillage USed
11
250
plowing 3.3 gal/acre, and no-tiil 1.4 gal'acre.^-’ For
every gallon of diesel fliel saved, 3.72 lbs of CO’ are
not released.
In 2002, 1 5 million acres (6. 1 million hectares)
of corn and 26 million acres {10.5 million hectares)
of soybeans were grown in no-till .systems in the United
States, amounting to 41 million no-tiil acres (16.6
million hectares). Using the 3.9 gallons per acre
estimated savings from no-till,'^ a net savings of 160
million gallons (605 million liters) of fiiel per year is
being realized in the no-till production of just these
two crops. The 55.3 million no-tiil acres (22.4 million
hectares) planted from ail crops in the US. in 2002
would account for a savings of 216 million gallons
(817 liters) of fuel that year. Mulch-tillage saves two
gallons per acre of fiiej compared witli conventional
tillage, accounting for a fuel savings of 90 raitiion
gallons on the 45 million acres (18.2 million hectares)
of rnuich-till systems. The combined fuel reduction
from no-till and mulch-till systems therefore accounted
for a savings of 306 million gallons of fuel.
Significant reductions in tillage liave occurred as
herbicide-tolerant crop varieties have facilitated
conversions to conservation tillage. A 2001 American
Soybean As.sociatio!i survey^ asked soybean growers
if and how much tillage had been reduced between
1996 and 2001 (the period of time glyphosate-tolerani
soybeans had been available), Soybean growers
responded that they had reduced tillage by an average
1 ,8 passes per growing season. One tillage pass
consumes about 0.7 gallons of diesel fuel per acre.^
Thus, soybean growers have reduced fuel consumption
by 1 .26 gallons per acre since the introduction
of glypliosate-tolerant soybeans. With more than
56 million acres of biotech soybeans planted in 2001,
a savings of 70 million gallons of fuel occurred just
from this crop. In 2002, 75 percent of all scybeans
planted were biotech soybeans. (USDA/NASS)
Trends link biotech,
CONSERVATION TILLAGE
Many factors determine whether a farmer will practice
conservation tillage. Cultural factors, climate, soil type,
equipment availability, moi,sture content, tradition and
other considerations all can be at play in making tillage
decisions. Weed control is among the most important
factors, at least in commonly grown row crops. The
development of herbicide-tolerant crops has given
farmers a new, versatile technology for controlling
weeds. It has removed much of the uncertainty in weed
control that prevented farmers from abandoning tillage.
Since the development of herbicide-tolerant soybeans
juid cotton, there have bewi marked increases in
conversion to no-till, the system most dependent on
herbicide performance, hi other crops, where the
herbicide-tolerant technology is not available, there
have not been large increases in conservation tillage.
FaimMS who use herbicide-tolerant seeds are more
likely to engage in ranservation tillage practices than
in conventional tillage practices. Furthermore, farmers
who use herbicide-tolerant seeds practice conservation
tillage to a greater degree than farmers w-ho do not use
the new technology.
These facts and trends indicate that the advent
of herbicide-tolerant crops, developed through
biotechnology, has solidified the acreage converted
to conservation tillage during the early 1990s and
has contribirted to the steady growth of no-till
acreage since 1996, when the crops were introduced.
Biotechnology may w'ell have the potential to facilitate
even more no-till.
An analysis of go\'emmcntaI, independent and
industry data, as well as grower surve>^, shows a
strong association between herbicide-tolerant crops
and grmvers' decisions to increase their level of crop
residue. The following four findings emerge:
I. Improvements in weed control, Including the
adoption of biotech herbicide-tolerant crops,
arc important reasons for initial adoption and
continuance of no-tiil.
Because the primary reason for tillage is weed
control, many farmers, assured of weed control
w'ithout disturbing the seedbed, will chwse to reduce
tillage. Herbicide-tolerant crops provide farmers with
an important advancement in weed control capability,
Past sur\’eys of farmers, assessing reasons for not
adopting conservation tillage, consistently found that
weed control was one of the greatest deterrents.^’' In
1991, low'a farmers were surveyed on their attitudes
about tillage. Weed control was most important to
farmers considtmng tillage changes. Fanners who
had tried no-till were asked to identify advantages
or disadvantages to the system. Sixty-eight percent
responded that w«ed control w-as a disadvantage. Only
chemical costs {70 percent responding) ranked higher
as a disadv'antage.*'’
12
251
If fanners had greater confidence in no-till weed
control systems, more farmers could be expected
to convert to no-till. Conclusions from tiiese surveys
indicate that improvements in w'eed control, including
the adoption of biotech herbicide-tolerant crops, are
important reasons for initial adoption and continuance
in no-till systems.
In 1 999, corn and soybean producers in Iowa were
surveyed to determine their tillage practices, yields
and attitudes about tillage.** Among no-till farmers,
68 percent felt that herbicide elfectiveness had
increased in tire last five years; 56 percent of farmers
who had tried but quit no-tiil felt effeclivenejs had
increased; and 34 percent of farmers who had never
tried no-till felt herbicides were more effective.
Thus, it is apparent that no-till adopters have more
confidence in their weed control systems. Consistent
weed control offered by herbicide-tolerant crop
systems could increase the confidence of all farmers,
resulting in tite increased adoption of no-till by
farmers who have never tried it and reducing the
number of first time no-tillers who revert back to
conventional tillage.
An American Soybean Association random survey
of soybean growers planting 200 acres or more in
the 19 major soybean-producing states documents
the importance of glyphosale-tolerant soybeans in
facilitating conversion from conventional tillage to
no-till and reduced tillage. Soybean growers reported
having reduced tillage by an average 1.8 passes
from 1 996 to 200 1 . during the period of time that
glyphosate-tolerani soybeans were available. Average
crop residue cover increased from 28 percent to 49
percent. During the same period, no-till soybean acres
in the American Soybean Association surv’ey more
than doubled to 49 percent, and reduced tillage acres
increased by more than one-fourth, to account for 83
percent of soybean acres. During this time, 53 percent
of growers reponed making fewer tillage passes, 73
percent left more crop residue on the soil surface,
and 48 percent had increased their no-till acres.**
To what can these increases be attributed? Sixty-three
percent of soybean growers who increased their crop
residue between 1996 and 2001 cited glyphosate-
tolerant teclinology as the key factor that made it
possible for them to reduce tillage or increase residue.**
That was an unaided response to the question: “In the
past five years, what changes in lechnolc^ such as
equipment, chemicals or seed have made it possible
for you to reduce tillage or increase crop residue
in soybeans?"
When asked which of .six factors had the greatest
impact toward the adoption of reduced tillage or
no-till during the past five years, growers indicated:
• The introduction of glyphosate-toierant soybean.s
54 percent.
• Availability of over-lhe-top or in-crop herbicides
12 percent.
• The cost of burndow'n herbicides 6 percent.
• The availability of bumdown herbicides 3 percent.
A total of 75 percent of surveyed farmers felt some
aspect of weed control was the greatest factor in
adopting reduced tillage or no-till. Availability of and
improvements in no-till drills garnered responses of
9 and 15 percent respectively.**
In a Canadian survey. 26 percent of canola growei-s
said they had increased their conservation tillage
practices because of Iterbicide-toleranl technology.
Their average increase was 69 percent, which translates
into 2.6 million acres or 1.05 million hectares in
western Canada having been positively impacted
by increased conservation tillage practices since the
introduction of the technology.
Weed control is similarly important to cotton producers.
A USDA survey showed that 76.3 percent of herbicide-
tolerant cotton growers said they planted herbicide-
tolerant varieties because of increased yields through
better weed control, and 1 8.9 percent cited decreased
herbicide input costs,™
Competition brought on by herbicide-tolerant technology
has resulted in an overall lowering of weed control costs,
drus addressing another concern about moving to no-till.
Gianessi and Carpenter calculated that US. soybean
grow'ens spent S220 million less on weed control in 1998
compared witlt 1995, after the added costs of glNT^hosate-
tolerant seed were factored in.’' These benefits are
supported by the rapid adoption of the technology since
its introduction in 1996. Glyphosate-toierant soybeans
were planted on 75 percent of soybean acres in 2002,
and glyphosate-toierant cotton was planted on 58 percent
of cotton acres.’- In Canada, herbicide -tolerajit varieties
were planted on an estimated 55 percent of the
12 million acres (4.9 million hectares) of canola
produced in 2000.**
Biotech crops have given farmers a new weed manage-
ment tool, allowing the post-emergence use of highly
effective broad-spectrum herbicides. Perennial weeds
are often prevalent in conservation tillage, especially in
no-till systems. Many perennials have been noted to
13
Millions of acres
252
increase with conser\’ation tillage.’’ The ability to remained fairly constant - about 36 percent of all
apply glyphosate over tolerant crops, made possible annually planted crc^iandor between 103 million
by biotechnology, now allows control of tough and 109 million acres. Thus, total conservation tillage
perennials that escape most other herbicides. Tbe acnss appear to have temporarily reached a plateau.
ri.sk of suffering poor weed control has been reduced However, adoption of no-ti!l. the most soil-conserving
significantly. Biotech crops are not required for the fomi of conservation tillage, continues to increase,
practice of conservation tillage or iio-tili, but the rising from 40.9 million acres (14.7 perceiit of ail
herbicide-tolerant crops developed through cropland) in 1 995 to 55.3 million acres ( 1 9.6 percent
biotechnology have provided farmers with an of all cioplmid) in 2002. This represents a growth
additional weed management tool, solving some vwed of 35 percent in no-till since biotech crops were
control problems faced by conservation tillage farmers, introduced in 1996, according to CTiC’s National
Crop R^idue Management Survey.
2. No-tiil, the system that most depends on herbicide
performance, has grown steadily since 1994. Hie feet that no-till acreage increased while overall
Nearly ail of this growth occurred in crops conserv'ation tillage has remained steady indicates
where herbicide-tolerant technology is available. that growere who earlier made a commitment to some
form of reduced tillage decided to leave even more
CTIC tillage surveys are based on criteria it developed residue on their fields. Tbe 2001 American So>tiean
to define conserv'ation tillage (at least 30 percent Association surv-ey found that 73 percent of soybean
residue cover after planting). Mulch-till, ridge-till growers were leaving more crop residue than five
and no-till are the various forms of conservation j'eais eariier, and 48 percent of them had increased
tillage. Figure 7 shows national adoption trends for their no-till acreage from 1996 levels. As stated
these systems from 1 990 through 2002. Since 1996, earlier, 75 percent of soybeans planted in 2002
conservation tillage adoption in the United States has w'erc glyphosate-tolCTant varieties.
Figure 7. Conservation Tillage Adoption in the U.S. (1990-2002)
0 1990 1992 1994 1996 1998 2000 2002
IS Ridge-till ^ No-till ^ Mulch-till
TRENDS IN CONSERVATION TILLAGE
253
Soybeans and cotton have the highest percentage of 3- There is a clear association between sustainable
biotech crops and account for half of the total no-tiil tillage practices and biotech crops,
acres planted in (he U.S. in 2002, according to CTIC
figures. It is also significant that the two crops for Table 2 shows national percentages of tillage categories
which glyphosate-tolerant (Roundup Ready*) varieties planted to glyphosate-tolerant soybeans, cotton and
have been rapidly adopted continue to show increases com for 1998-2000. While famiere using all tillage
in adoption of no-till. No-lill soybean acres increased systems have adopted the glyphosate-tolerant crops,
from 19.3 million acres (7.8 million hectares) in 1995 conservation tillage farmers are much more likely to
(before glyphosate-tolerant crops) to 26 million acres use the biotechnology crops. For example, in 1 998,
(10.5 million hectares) in 2002. No-till cotton acres no-til! soybeans were nearly twice as likely to be
increased from 0.5 million (0.2 million haiares) in planted to glyphosate-tolerant varieties compared with
1 996 (before glyphosate-tolerant crops) to 2 million conventional varieties, while no-tili cotton was more
acres (0.82 million hectares) in 2002. Glyphosate-toler- than twice as likely to be planted to glyphosate-tolerant
ant soybean varieties have been available since 1996, varieties. Adoption of glyphosate-tolerant crops by
and cotton varieties since 1997. Glyphosate-tolerant conservation tillage fanners continues to grow. In 2000,
com was first marketed in 1 998. Herbicide-tolerant 52.9 percent of conventional tillage, 63.9 percent of
canola became available in Canada in 1996 and the reduced tillage, and 74,5 percent of no-till soybean
United States in 1999. Only about 1.5 million acres acres were planted to glyphosate-tolerant varieties,
of canola were planted in the United Slates in 2000. Cotton acres planted to glyphosate-tolerant varieties for
Figure 8. Comparison of Soybeans vs. Roundup Ready Soybeans (Planted 1998-2000)
Year Source of % Roundup Ready Soybearss: Monsanto
Conventional tillage lilli Roundup Ready Soybeans
Reduced tillage
Mulch Ull * Reduced till
254
2000 were 46.8 percent of conventional tillage, 63.2
percent of reduced tillage and 86,2 percent of no-tilL
In 2000, 4.3 percent of conventional tillage, 4 percent
of reduced tillage and 7 percent of no-till com
planted to glyphosate-tolerant varieties.
No-till cotton is constrained by tlie predontinance of
furrow irrigation and boll-weevil eradication programs
in some regions, such as California and Arizona, which
restricts conversion to no-till. In other cotton-growing
regions, producers who tried the relatively new no-till
system for cotton used herbicide-tolerant varieties to
facilitate the change. In Arkansas in 1 998, only 6.7
percent of conventionally tilled cotton was planted to
glyphosate-tolerant varieties, while 97.8 percent of no-
till cotton acres were planted to the biotech varieties.
In 2000, glj^hosate-tolerant cotton was planted on
97, 96, 95 and 94 percent of no-til! cotton in Georgia,
Tennessee, Alabama and North Carolina, respectively.”
The high adoption rate of glyphosate-tolerant cotton by
no-till producers illustrates tiie utility of this technology
in conservation tillage. In 2000, glyphosate-tolerant
com was planted on only 5 percent of com acres in
the United States, due in large part to a concern about
export restrictions. About 7 percent of all no-till com
acres planted in 2000 were glyphosate-tolerant.
The American Soybean Association survey of grower
practices confimts the greater usage of glyphosatc-
toleratU soybeans in no-till and reduced tillage systems.
In the 1 9-state area represented by the survey,
glyphosate-tolerant sewbeans were planted on 36.8
million cemservation tillage acres and only on 5.3
million conventionally tilled acres." Clearly, with the
glyphosate-tolerant seeds going disproportionately
to the soybean acres in conservation tillage, farmers
understand the value of the technology to reduced
tillage systems.
4. Farmers who don't use herbicide-tolerant seeds
arc not as likely to engage in conservation tillage.
While it is clear that many farmers who use traditional
w'eed control ^tems also participate in conservation
tillage, there is significantly greater participation
among those soybean and cotton farmers who use
herbicide-tolerant varieties developed throiigh
biotechnology. Table 3 shows results of the American
Soybean Association survey*" comparing practices of
glyphosate-tolerant soybean adopters to non-adopters.
GI>'phosate-toleranl soybean growers planted more
no-tiil and reduced till acres than non-adopters. For the
period 1996 to 2001, 52 percent of glyphosate-tolerant
soybean adopters had increased no-till acres, compared
with 2 1 percent of non-adopters. Fifty-eight percent
of adopters reported reducing tillage passes, with
20 percent of non-adopters reducing tillage passes.
l-ikewise. in Canada, 50 percent of canola growers
who used herbicide-tolerant N'arieties participated in
conservation tillage practices, while only 35 percent
of non-adopters practiced conservation tillage."
Percent of Acres Planted to Giyphosate-Tolerant Crop
1 Year
Conventional Tillage
Reduced Tillage
No-till
1998
28,5
34.7
51,2
1999
47 0
55.9
70,7
2000.
52.9
63.9
74,5
1998
21.3
37.7
57,2
1999
35.0
51.4
65.8
2000
46.8
63.2
CD
CO
1998
1.2
1.1
1.8
1999
3.2
2.9
4.4
2000
4 3
4.0
7,0
Souicc Company
16
TRENDS IN CONSERVATION TILLAGE
255
Table 3: American Soybean Association 2001 survey of U.S. soybean grower practices
of giyphosate-toterant soybean adopters and non-adopters, 1996 to 2001
Characteriaics - - : . j
Gl^nahosale-tolerani
so^}ean growers
Non-glyphosate-tolerant
soybean growers
Percent of 2001 soybean acres in
no'iiit or reduced till
34
72
Percent of growers having more rK>tili
soybeans vs. five years ago
52
21
Peicent of growers making fewer
tillage passes vs. five years ago
58
20
Percent of growers leaving more crop i
residue vs. five years ago
76
57
Sample size-unweighted base
393
59
SoiKC-c: Arrcrican Soybean Association 2001
Summary statement
Herbicide-tolerant crops developed through biotech-
nology have provided farmers with an additional weed
management tool. They have solved some weed control
problems faced by conservation tillage farmers and
vSimplified weed control. An analysis of surveys
conducted since the introduction of herbicide-tolerant
crops strongly supports the conclusion that these crops
developed through plant biotechnology are facilitating
the continued expansion of conservation tillage,
especially no-till. As more acres are converted to
conservation tillage, and especially no-till, significant
environmental benefits will be derived.
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REFERENCES
260
United States
Department
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USDA
• e «
Economic
Research
Service
Economic
Research
Report
Number 36
Off-Farm Income,
Technology Adoption, and
Farm Economic Performance
Jorge Fernandez-Cornejo, with contributions from Ashok Mishra,
Richard Nehring, Chad Hendricks, Malaya Southern
and Alexandra Gregory
261
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Off-farm income, farm economic performance, and technology adoption.
(Economic research report (United States. Dept, of Agriculture.
Economic Research Service) ; no. 36)
1 . Farm income — United States.
2. Farmers— Time management— United States.
3. Part-time farming — Economic aspects — United States.
4. Agricultural innovations — Economic aspects — United States.
5. Farms, Size of— Economic aspects— United States.
I. Fernandez-Cornejo, Jorge.
II. United States. Dept, of Agriculture. Economic Research Service, III. Title.
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USDA
United States
Department
of Agriculture
Economic
Research
Report
Number 36
January 2007
• •
• • •
• • • A Report from the Economic Research Service
www.ers.usda.gov
Off-Farm Income,
Technology Adoption, and
Farm Economic Performance
Jorge Fernandez-Cornejo, with contributions from
Ashok Mishra, Richard Nehring, Chad Hendricks,
Malaya Southern, and Alexandra Gregory
Abstract
The economic well-being of most U.S. farm households depends on income from both
onfarm and off-farm activities. Consequently, for many farm households, economic
decisions (including technology adoption and other production decisions) are likely to
be shaped by the allocation of managerial time among such activities. While time allo-
cation decisions are usually not measured directly, we observe the outcomes of such
decisions, such as onfarm and off-farm Income. This report finds that a farm operator’s
off-farm employment and off-fann income vary inversely with the size of the farm.
Operators of smaller farm operations improve their economic performance by compen-
sating for the scale disadvantages of their farm business with more off-farm involve-
ment. Off-farm work reduces farm-level technical efficiency, but increases
household-level technical efficiency. And adoption of agricultural innovations that save
managerial time is associated with higher off-farm income.
Keywords: Off-farm income, farm households, economic performance, managerial time,
scale economies, scope economies, technical efficiency, technology adoption, farm size.
Acknowledgments
The authors thank James MacDonald, Keith Wiebe, Dayton Lambert, Carol Jones, and
Utpal Vasavada, ERS, for the helpful comments provided on earlier drafts of the report.
We also thank James Hruboveak from the Office of the Chief Economist, Jane
Schuchardl from the Cooperative Slate Research, Education and Extension Service,
Bruce Gardner from the University of Maryland, and an anonymous reviewer. Finally,
we are very grateful to Dale Simms for his valuable and prompt editorial assistance and
Anne Pearl for cover design and document layout.
263
Contents
Summary iii
Introduction and Overview 1
An integrated Approach 2
Approaches to Integrate Olf-Farm Work and Farm Production 3
Off-Farm Work and Income in U.S. Farm Households 5
Farmers’ Motivations To Work Off Farm 5
Opportunity Cost of Labor for Farm Operators 6
Off-Farm Income and Farm/Household Characteristics 8
Off-Farm Income and F'ami Size 8
Off-Farm Income and Farm Location 10
Off-Farm Income, Type of Enterprise, and Human Capital 11
Off-Farm Work, Scale and Scope Economies, and Efficiency 12
Off-Farm Work and Scale Economies 12
Off-Farm Work and Economies of Scope 13
Off-Farm Work and Efficiency 15
Efficiency of the Farm Business 15
Household-Level Efficiency 15
Off-Farm Work and the Adoption of Agricultural Innovations 17
Off-Fann Work as a Factor in Early Studies of
Technology Adoption 17
Weaknesses of Early Studies 19
Modeling the Interaction Between Off-Farm Work
and Adoption Decisions 19
Technology Adoption and Off-Faim Income 20
Conclusions 23
References 25
Appendix 1 - Economies of Scale and Scope and
Technical Efficiency 36
Appendix 2 • Incorporating Technology Adoption in the
Farm Household Model 40
ii
Off-Farm Income, Technology Adoption, and Farm Economic Performartce/ERR-36
Economic Research Service/USDA
264
Summary
U.S. farmers must make a host of decisions relating to their farms’ opera-
tion, including what to grow, when to grow it, in what quantities, and by
what methods. Often overlooked in this calculation, but factoring heavily in
the diversity of U.S. farms and farm households, is the fact that most opera-
tor split their time between farm and nonfarm activities. Large farms are
typically able to economize on inputs and better coordinate stages of
production. Smaller farms, though often unprofitable fi'om a farm business
perspective, have endured by being part of household enterprises that
combine farm and off-farm activities. Their operators’ onfarm decisions,
from choice of technology to choice of specialty, are often influenced by
off-farm commitments and income.
What Is the Issue?
Onfarm and off-farm activities compete for limited managerial time (mainly
of the operator and spouse). How farm operator households allocate their
time largely affects production decisions (such as technology adoption),
economic performance, and the household’s economic well-being.
The extent of off-farm work and its relationship with farm economic
performance may have important policy implications. For example, govern-
ment policies for agriculture (via conservation, research and development,
extension, and commodity programs) may affect farm households differ-
ently, depending on the relative importance of onfarm versus off-farm
income. And the effectiveness of policies promoting adoption of farm tech-
nologies might be improved by taking into account the different demands on
managerial time and the relative ability of the farm household to accommo-
date those demands.
What Did the Study Find?
Operators of smaller farms typically participate more in off-farm
employment, work more hours off the farm, and have higher off-farm
income than operators of larger farms. In 2004, farm households with
farm sales less than $10,000 had average off-farm earned income of
$54,600, while households with farm sales of $500,000 - $1 million aver-
aged only $.^0,100. More than 58 percent of operators with farm sales less
than $10,000 reported off-farm hours worked in 2004, versus less than 20
percent for operators of farms with sales of $500,000-$ 1 million.
As previous studies have shown, off-farm work is less likely on farms
with labor-intensive enterprises such as dairy. Moreover, dairy farmers
who do work off the farm tend to require higher compensation to do so than
farmers producing other commodities. Off-farm work has also been shown
to be positively related to urban proximity and to the education and experi-
ence of the operator and spouse.
Including off-farm income-generating activities improves the overall
economic performance of the farm household. Off-farm income clearly
adds to total household income, but it can also improve efficiency and other
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measures of performance of the farm household. Our estimates for com and
soybean farms show that households engaged in off-farm income-generating
activities together with the production of traditional farm outputs have cost
savings of 24 percent relative to carrying out those activities separately. The
savings likely arise from the sharing of managerial expertise (and its many
components, such as accounting and information processing skills, sales
expertise, administrative and technical know-how, etc.) between onfarm and
off'fami activities. For example, management skills acquired in farming
might be applicable to (and shared with) a nonfarm business, and vice-versa.
From a farm business perspective, operators of smaller farms have a greater
incentive to expand. However, from a household perspective (including off-
farm income-generating activities), operators of small farms have a reduced
tendency to increase their farm size.
Large farms are generally more efficient than smaller farms in trans-
forming farm inputs into outputs, given the technology at their disposal.
But focusing on farm inputs and outputs alone is misleading because off-
farm income-generating activities are increasingly important in determining
economic performance of the farm household.
When off-farm activities are included, farm household-level efficiencies are
higher than farm-level efficiencies across all farm sizes, and efficiency gains
from integrating off-fann work into the output portfolio are relatively
greatest for smaller farms. As a result, household-level efficiencies of
smaller farms are comparable to farm-level efficiencies of larger farms.
This suggests that households operating small farms have partially adapted
to shortfalls in farm-level performance by increasing their off-farm income.
In addition to Its links with the farm business, as traditionally exam-
ined, farmers’ technology choices are closely related to off-farm income.
Higher off-farm income is significantly related to the adoption of technolo-
gies that economize on management time (management saving such as
herbicide-tolerant crops, conservation tillage). For example, a 16-percent
increase in off-farm household income is associated with a lO-percent
increase in the probability of adopting herbicide-tolerant (HT) soybeans.
Household income from onfarm sources is not significantly associated with
adoption of these technologies, but total household income (including
income from off-farm sources) is. On the other hand, lower off-fann
income is significantly related to adoption of managerially intensive tech-
nologies (such as precision farming). For example, an 8-percent decrease in
off-farm income is associated with a 10-percenl increase in the probability
of adopting yield monitors, a key component of precision agriculture.
These findings corroborate a tradeoff between household/operaior time
spent in onfarm and off-farm activities. Households operating small farms
devote more time to off-farm opportunities and are more likely to adopt
management-saving technologies.
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How Was the Study Conducted?
To examine the relationships between off-farm income, farm and household
characteristics, and economic performance of U.S. farm households, we
developed econometric models and estimated them using USDA’s Agricul-
tural Resource Management Survey (ARMS) data for several years (1996-
2001). To examine the relationship between off-farm work and economic
performance of farm households (including economies of scale and scope,
and economic efficiency), we compared estim^es obtained using traditional
farm-level models to estimates obtained using household-level models
(including off-farm income-generating activities along with traditional farm
outputs such as crops and livestock). To examine the relationship between
off-fann income and technology adoption, we developed a model that incor-
porates the adoption decision into the agricultural household framework. We
examined the interaction of off-farm work and adoption of agricultural tech-
nologies of varying managerial intensity, including herbicide-tolerant crops,
precision agriculture, conservation tillage, and Bt (Bacillus thuringiensis)
com, after controlling for other factors.
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Introduction and Overview
Decisionmakers (mainly farm operators and their spouses) are a major
determinant of farms’ economic performance. The effort and ability to
manage land, water, machinery, and other inputs — as well as adoption of
technologies and production practices — can help secure farm business
success and the economic well-being of a farm household. However, many
farm operators (and other household members) use a large share of their
time in off-farm income-generating activities. Consequently, for many farm
households, economic decisions (including technology adoption and other
production decisions) are likely to shape and be shaped by the allocation of
managerial time to such activities. While time allocation decisions nre
usually not measured directly, we observe the outcomes of such decisions,
such as onfarm and off-farm income.
Off-farm income (largely earned income from employment and off-farm
business income) received by U.S. farm operators and their spouses has
risen steadily over recent decades and now constitutes the largest component
of farm household income (fig. la, b). The impact of off-farm income is felt
particularly by households operating small farms, allowing many of them to
survive and even flourish to an extent not thought possible 20 or 30 years
ago (Gardner, 2005). In addition, the growth in off-farm income over the
last 40 years reduced income inequality among farm households and helped
U.S. farmers’ average incomes overtake those of the nonfarm population
(Gardner, 2002).
This report examines the empirical relationships between off-farm income,
farm household characteristics, production decisions (particularly tech-
nology adoption), and various measures of economic performance for U.S.
farm households. This research provides insights into farmers’ choices in
the context of farm/liousehold integration and helps improve our undcr-
Figurela
Farm household income, U.S. average 1960-2004
1 960 65 70 75 80 85 90 95 2000 05
Sources: USDA, ERS, Deflator used to calculate real income is the consumer price
index (CPI-U) from the Bureau of Labor Statistics.
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Figure 1b
Off-farm Income share of total farm household income,
U.S. average, 1960-2004
Percent
Sources: 1 960-2003: USDA farm household income estimates over time, ERS farm structure
briefing room, htfp://www.ers.usda.gov/Briefing/FarmStructure/Datafliistoriahhn; 2004;
Covey et ai., 2005.
Standing of the pace of technological innovation and its relation to the struc-
ture of agriculture.
The report also suggests the need to analyze the economics of the farm busi-
ness and farm household in an integrated framework and describes two
approaches for doing so. We summarize statistics of off-farm work and
income in U.S. farm households and examine the relationship between off-
farm income and farm size, location, and household characteristics.
Our main research focus is to examine how off-farm work influences the
economic performance of the integrated farm business and household. To
do this, we expand traditional concepts of economic performance, such as
economies of scale and efficiency, to incorporate onfarm and off-faim
income-generating activities of household members. In addition, we
examine the relationship between off-farm income and the adoption of agri-
cultural technologies of varying managerial intensity, namely herbicide-
tolerant crops, precision agriculture, coaservation tillage, and Bt {Bacillus
thuringiensis) corn.
An Integrated Approach
While increasing household income, off-farm activities also compete for
managerial time (mainly of farm operators and their spouses), which may
affect the economic perfonnance of the farm business. Consequently,
economic decisions (including technology adoption and other production
decisions) are likely to shape and be shaped by the underlying allocation of
time within the farm operator household. So, rather than examining the
farm business or farm household in isolation, an integrated approach
captures the interplay of farm and nonfarm considerations and contributions.
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Despite its importance, the role of off-farm income has been largely
neglected in empirical analyses of farm economic performance and tech-
nology adoption.* Some exceptions include Gardner (2001), Boisvert
(2002), Goodwin and Mishra (2004), Femandez-Comejo et a1. (2005),
Nehring et al. (2005), Paul and Nehring (2005), and Chavas et al. (2005).-
One reason for this lack of studies may be the modeling and data challenges
in moving from the traditional unit of analysis (the farm business) to the
farm household.
While agricultural economists have made major contributions in under-
standing farm production functions, they may not have exploited as fully the
concept of the household production function (Offutt, 2002). In this context,
the allocation of lime (and money) of household members to production,
consumption, and other activities is particularly important. An integrated
firm-household perspective was suggested back in 1952 by E.O. Heady,
who observed that “the fiiin-household complex is important not only to
defining the organization of resources and family activities which will maxi-
mize utility at a given point in lime but also in helping to explain uncer-
tainty precautions, capital accumulation, soil conservation, and other
production-consumption decisions, which relate to time.”^
Approaches To Integrate Off-Farm Work
and Farm Production
Two approaches are used in this report to model the interaction of off-farm
income-generating activities with traditional farm production activities. The
unifying notion underlying the two approaches is that managerial time is a
key resource in both onfarm and off-farm activities.
In one approach, we expand the agricultural household model to include the
technology adoption decision together with the olf-farm work decisions by the
operator and spouse. The agricultural household model describes how a farm
household allocates its time (and other resources) among producing commodi-
ties, earning off-fann income, leisure, and home production.** The model
assumes that the farm household maximizes its utility subject to constraints on
its time (including work and leisure), income, and production technology
(production function). Household members derive utility from goods
purchased for consumption, leisure, and factors exogenous to current house-
hold decisions, such as human capital, household characteristics, and weather.
Using this model, we examine the interaction of off-farm work and the adop-
tion of agricultural innovations (both management saving like herbicide-
tolerant crops, and management u.sing like precision agriculture or integrated
pest management— IPM), then obtain empirical estimates of the relationship
between adoption of these technologies and farm household income.
Though the agricultural household model has intuitive appeal in modeling
fatrn household behavior, it requires much in the way of assumptions and
data (Offutt, 2002). Parameter estimation for the models spawned by the
household production function often requires hard-to-get data, including
consumption expenditures, farm and off-farm labor supply, farm and
nonfarin outputs and inputs, assets, and prices for all gocxls, inputs, and
labor. Also needed is information on technologies and participation in
'Economic researchers have been
examining farm economic performance
fcx;using on the farm business for sev-
eral decades (Heady; Griiiches;
Dawson and Hubbard; Hallam).
Anolher line of research has focused
on the farm household and the labor
allocation decisions by the operator
and their spouses (Huffman, 1980,
1991; Lass, Findeis, and Hallberg,
1989: Lass and Gempesaw. 1992;
Kimhi, 1994,2004),
-Boisvert (2002) stressed not only
the growing links between farming
activities and off-farm labor markets
but also the links between farm house-
hold activities, conservation payments,
and agricultural pollution.
•^Loosely, utility is a measure of sat-
isfaction. Economists assume that peo-
ple act if doing so gives them ulilify.
*The household model initially
received a great deal of attention in
studies of developing countries’ agri-
culture because of the relative impor-
tance of consumption activities in such
households. Agricultural economists
have also applied those models in
developed countries to examine how
household members make decisions
about the allocation of labor both on
and off the farm (Huffman, .1980,
1991; Sumner, 1982; Lopez. 1985:
Singh et al,. 1986; Lass et al., 1989;
Lass and Gempesaw, 1992; Kimhi,
1994, 2004; Mishra and Goodwin.
1997; Goodwin and Holt, 2002). Other
analysts have examined income and
wealth distributions and links between
income instability and
consumption/investment (E!-Osta and
Morehait: Mishra and Moreharl).
Lopez is one of the few to have consid-
ered labor supply and farm production
decisions simultaneously. In a very
recent application, Chavas et al. used a
farm household model to investigate
the economic efficiency of farm house-
holds in Gambia (Chavas et al, 2005).
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government programs, as well as demographic data. For these reasons, it is
sometimes necessary to use alternative methods. In this approach, we
expand the concept of scope economies to include as output all income-
generating activities, on or off the farm, in addition to the traditional farm
outputs such as com, soybeans, and livestock (Nehring et al., 2(X)5). In addi-
tion, we estimate scale economies and technical efficiency, and compare
results at the farm and household levels.
Scale and Efficiency
Scale Economies
A farm is said to have economies of scale {or
increasing returns to scale) if the average cost decline
as output (scale of production) increases. If a farm is
subject to economies of scale, it is cost effective for
that ftum to increase all outputs simultaneously while
holding the mix of outputs constant (costs would rise : :
less than proportionally). I’hus. the existence of scale
economies suggests that farms can achieve lower
average costs by becoming larger. Economists have
established (under reasonable conditions) the equiva-
lence between the information provided by the costs
and the production technology (Carlton and Perloff,
2(X)0). Based on the production technology, economies
of scale may be viewed from an output or input
perspective.
From an output perspective, the tenn elasticity of scale
is used to measure the percent increase in output gener-
ated by a I 'percent increase In all inputs (Varian,
1992). There are increasing returns to scale if the elas-
ticity is greater than 1 ; that is, an increase in overall
inputs generates a rriore than proportionate increase in
output. For example, a scale elasticity of 1.15 means
that a l-percem increase in inputs leads toa i. 15-
percent increase in output. Conversely, if the elasticity
is lower than one there are decreasing returns to scale;
that is, an increase in overall inputs generates a less
than proportionate increase in output. For example, a
scale elasticity of 0.8 means that a i -percent increase in
inputs leads to a 0.8-perceni increa.se in output.
Constant returns to scale means that a 1 -percent
increase in overall inputs generates a I -percent increase
in output; in this case the elasticity of scale is equal to
1 .
From an input perspective, a simil^ly defined scale
elasticity measures the percent increase in inputs
required to support a l-percent increase in all outputs,
lii this case, returns to scale are increasing when the
input-oriented scale elasticity is less than one. For
example, if the scale elasticity of a farm is 0.75, it
means that a 0.75-perccnt increase in inputs will be
needed to support an output increase of 1 percent. Tliis
suggests that there is an, incentive for the farm to grow
larger. If the elasticity is equal to one (constant returns
to scale), there are no scale economies available. In
this report, we use an input perspective (input distance
function, appendix 1).
Technical Efficiency
Economic efficiency can be decomposed into technical
efficiency and allocative efficiency. A farm is techni-
cally efficient if it uses the minimum possible levels of
inputs to produce a given level of output, given the
technology. An allocative efficient farm produces a
given output using the best {minimum cost) input
proportions given prevailing input prices. Unless speci-
fied otherwise, the efficiency results discussed in this
report involve technical efficiency. :
Technical efficiency is the ratio of ciirreht to maximum
possible or “best practice” productiOh and it is calcu-
lated in this study using an input distance function (see
appendix 1). Technical efficiency is defined relative to
an “efficient frontier” and all farms operating on the
efficient frontier are classified as 100 percent efficient
with an efficiency score equal to 1 . Farms using more
inputs to produce a given output level than those on the
efficient frontier are inefficient atid their efficiency
score is less than I . Technical efficiency is often associ-
ated with managerial ability and experience.
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Off-Farm Work and Income
in U.S. Farm Households
271
Off-fami income received by farm operators and their spouses has risen
steadily over recent decades (fig. ia) as job opportunities have grown and
technological progress, such as mechanization, has lessened onfarm labor
needs. The otf-farm income share of total household income of U.S. farmers
rose from about 50 percent in 1960 to more than 80 percent over the past 10
years (fig. lb). Most of the off-farm income was earned. On average, a
farm household earned about $48,800 from olf-farm sources in 2(X)4,
received about $18,500 in unearned income (Social Security, interest, etc),
and netted nearly $14,200 from farming activities (Covey et al., 2005).^
Fifty-two percent of farm operators worked off farm in 2(X)4 (up from 44
percent in 1979). The share of spouses working off farm grew from 28
percent of spouses in 1979 to 45 percent in 2004 (Mishra et al., 2002; 2004
ARMS data).
The trend is similar in term.s of hours worked ((able 1). Average hours
vs'orked off farm by farm operators has increased (from 830 hours per year
in 1996 to 1,022 in 2004), while the hours devoted to farm work did not
change markedly (1,525 hours in 1996 and 1,574 in 2004). Similarly, the
number of hours worked off the farm by spouses increased from 690 in
1996 to 809 in 2004.
Farmers’ Motivations To Work Off Farm
Once seen as a “temporary response to the Great Depression,” off-farm
employment is now regarded as a “regular feature of almost all farming
societies” (Fuller. 1991; Bartlett, 1986; Bessanl, 2000). More than half of
U.S. farm operators now work off the farm.^ Moreover, off-farm income
appeal's to smooth out household income flows (Mishra and Goodwin,
1997; Mishra and Sandretlo, 2002), and most farmers view off-farm
employment as a permanent rather than a temporary or transitional (into or
out of fanning) pursuit (Aheam and El-0.sla, 1993).^ Farm operators in a
1982 survey felt that full-time farming provided inadequate income (91
percent of the respondents), and that farm income was risky (70 percent)
and offered no fringe benefits such as pensions and health insurance (55
percent). Capital and land constraints were considered less important disad-
vantages to full-time farming (42 and 30 percent) (Barlett, 1991). More
Table 1
Operator and spouse hours worked on and off farm, 1996-2004
Item
1996
2000
2004
Operator hours worked;
On farm
1,525
1,433
1,547
Off farm
830
1.011
1,022
Total
2,355
2,443
2,596
Spouse hours worked:
On farm
366
337
877
Off farm
690
751
809
Total
1,056
1,089
1,686
Sources: 1 996: Hoppe (2001 , p. 29); 2000: Mishra e! al. (2CK32, p. 50); 2004: ARMS data.
'Across all farms, operators earned
64 percent of all household off-farm
earned income in 2001, spouses earned
elose to .^3 percent, and other members
earned 3 percent (O’Donoghue and
Hoppe, 200.‘i).
^There are. however, some issues
regarding the definition of a farm.
Since the USDA definition of a farm is
not adjusted for inflation, the number
of small operations that get defined as
fanns may increase over time, which
may also increase the share of opera-
tors working off the farm.
minority of farmers ( 1 8,4 per-
cent of the total in 1987) may be con-
.sidered as a transitional group, i.c,.
full-time farmers who worked off farm
because they faced heavy losses and
high debts. Some of these farmers
expected to return to full-time farming
when their financial situation was
resolved (Bartlett, 1991). Moreover,
using agricultural census data spanning
1982 to 1997, ERS researchers identi-
fied 644 (out of over 5,000) small part-
time i'anns that managed to grow into
large commercial operations. These
farms are called emergent adaptive
farms (EAF). Off-farm work provided
financial support during the early years
of the typical EAF, but EAF operators
spent more lime on farm activities as
their businesses expanded; 35 percent
of EAF operators worked at least 200
days off the farm in 1987, but that
share declined to 16 percent by 1997
(Newton, 2005).
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recenlly, the 2004 ARMS asked operators and spouses to list the two main
reasons for seeking off-farm work. The primary reason given by 35-50
percent of the operators and 44-63 percent of the spouses (depending on
farm size and occupation of the farm operator) was “to increase income” of
the farm household. Other reasons cited were to obtain fringe benefits (such
as health insurance) and personal satisfaction (Covey et al., 2005),
So most operators and spouses report working off farm primarily to increase
income for the farm household, but how was the additional income used?
Contrary to conventional wisdom, most farm operators and spouses did not
work off the farm to directly support their farm business. USDA suA'eys
indicate reasons unrelated to the farm business, from buying groceries to
funding a retirement account (Hoppe, 2001).
Farmers and spouses hold a variety of off-farm jobs, but especially in
private businesses (54.1 percent of operators with off-farm jobs), self-
employment (22.3 percent), and government (16.0 percent). Only 3.3
percent worked on another fann (Mishra et al., 2002). Spouses with off-
farm work are most likely to be employed in the private sector (55.1
percent) and government (28.4 percent), with less than 1 percent working on
another farm.
Opportunity Cost of Labor for Farm Operators
Opportunity cost is an important economic concept that measure.s the
economic cost of an action or decision in terms of what is given up (oppor-
tunity forgone) to carry out that action. In the case of farm labor, for
example, the opportunity cost of labor for the operator (or spouse) labor is
often measured in terms of the wage that the operator (or spouse) can obtain
working off farm. As the United Nations’ Economic Commission for Europe
notes: “In conventional accounting systems, ‘unpaid’ family labour does not
usually appear as an explicit cost of production. Consequently, (here is no
explicit ‘wage’ paid to the labour that the farmer and his family [contribute
to] production.”
Farm household labor is a critical input in agricultural production. In the
com/soybean-producing States, farm household members provide more than
80 percent of all labor hours. * A significant proportion of those labor hours
is not valued directly in the marketplace (e.g., through wages). Studies have
estimated the opportunity costs of farm labor by using predicted off-farm
wages (El-Osta and Aheam, 1996).
Alternatively, a .simplified approximation of the opportunity cost of labor for
farm operators and their spouses can be obtained directly from ARMS data.
The (nominal) opportunity costs for coni/soybean operators and spouses
appear not to have increased over 1996-2000. ITie cost for the operator
($21.07 per hour for 2000) appears to run about 20 percent higher than that of
the spouse, and both are higher than the actual wage rate for hired farm labor.^
It is also interesting to compare the opportunity cost of labor for
com/soybean farmers with those of dairy farmers. The cost for U.S. dairy
farmers in 2000 was econometrically estimated at $27.58 per hour for oper-
^Corn/soybean-producing States arc
defined as those that account for most
of the U.S com and soybean produc-
tion. States included are Illinois,
Indiana, Iowa, Michigan. Minnesota,
Mi.ssouri, Nebraska, Ohio, South
Dakota, and Wisconsin.
'^he opportunity cost of labor
varies w'ith the farm’s region, size, and
specialization, the operator’s human
capital (education and experience); and
household characteristics (El-0.sta and
Aheam). In addition, opportunity cost
estimates may vary with the character-
istics of the labor markets, the method-
ology used, and data sources.
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alors (30 percent higher than for corn/soybean farmers) and $19.36 for
spouses (18 percent higher) (Lovell and Mosheim, 2005). Given that labor
requirements in dairy production are high and inflexible (El-Osta and
Aheam), dairy farmers likely require a higher “wage” to work off the farm
than fcu-mers working in other enteiprises.
Table 2
Opportunity cost of labor for corn/soybean farm operators and spous-
es, and actual hired farm wage rate, 1996-2000
Year
Operator
Spouse
Hired
Dollars per hour
1996
22.88
17.87
7.42
1997
26.72
19.06
8.01
1998
22.14
18.77
8.30
1999
22.19
17.96
8.67
2000
21.07
17.47
8.99
Source; ERS estimates based on ARMS data for corn/soybean States
analyzed (Nehring, Fernandez-Corneio, and Banker. 2005).
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Off-Farm Income and Farm/Household
Characteristics
Like their nonfarm counteiparts, many farm households are dual career.
While operators and spouses across all sizes and typologies work off-farm or
manage nonfarm businesses, the level of off-farm income varies with farm
size, region, farm type, and the human capital of operators and spouses.
Off-Farm Income and Farm Size
Off-farm income varies inversely with farm size; operators of smaller farms
have higher off-farm incomes, both earned and total.’® Farm households
with gross farm sales less than $10,000 had total off-farm income averaging
nearly $74,000 in 2(K)4 {$54,600 of which was earned), while households
with farm sales between $250,000 and $499,999 had total off-farm income
averaging about $45,000 ($33,200 earned) (table 3). While off-farm income
constitutes the largest component of fann household income on average, its
share decreases with farm size. For farms with gross sales higher than
$250,000 (less than 8 percent of U.S. farms), off-farm income is no longer
the largest component of household income (table 4).
Off-farm household income earned by the operators is more variable across
farm sizes ($27,500 for operators of smaller fanns versus less than $10,000
for operators of the largest farms) than that earned by spouses (between
$12,000 and $14,(K)0 across all sizes in 2004). Off-farm income earned by
other household members averages around $1,000.
To a large extent, the inverse relationship between off-farm earned income
and farm size is due to greater off-farm employment (and more hours
worked off the farm) by operators of smaller fanns. More than 55 percent
of operators with farm sales less than $100,000 reported off-farm hours in
2004 versus 20 percent or less for operators of farms with sales above
$250,000 (table 4). On the otlier hand, off-farm income earned by farm
operators who work off-farm does not vary much with size, averaging
$47,000 for operators of the smallest farms and $39,000 for operators of the
largest farms.
Table 3
*^Smaiier farms represent a very
large share of farm population but a
small share of the farm sales. For
example, about 44 percent of the farms
have sales les.s than $ 1 0,000 and more
than 80 percent of the farms have sales
below SiOO.OOO (table 3). This distri-
bution. however, is dependent on the
definition of farm. In the United
States, a farm is currently defined, for
statistical purpose.s, “as any place from
which Sl.tXK) or more of agricultural
products were sold or normaliy would
have been .sold during the year under
consideration." (USDA, 2005).
Off-farm household income by farm size, 2004
Income
Income
Income
Off-farm
Total
Unearned
Total
Farm sales
Share
earned
earned
earned by
business
earned
income
off-farm
of
by the
by the
other
income
income
income
farms
operator
spouse
members
Percent Dollars
$9,999 or less
43.7
27,457
14,756
1,219
11,209
54,641
19,392
74,033
$10,000-$99,999
40.7
24,295
13,095
1,142
9,889
48,422
19,549
67,971
$100,000-$249,999
7.9
1 1 ,074
14,722
1,158
8,493
35,445
11,467
46,913
$250,000-$499,999
4.2
7,559
13,439
836
1 1 ,404
33,238
11,633
44,870
$500,000-$9g9,999
2.0
7,790
12,816
1,110
8,371
30,086
21,991
52,077
$1,000,000 or more
1.5
4,898
12,017
612
10,744
28,271
12,811
41,082
All farms
100.0
23,318
13,943
1.156
10,402
48,818
18,461
67,279
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Table 4
Farm household income by farm size, 2004
Farm size
(annual sales)
Number of
farms
Share of
farms
income
Total
household
farming
Income
from
income
Share of
farm
Off-farm
income
S9,999 or less
$10,000-$99,999
Number
901,333
838,912
Percent
43.7
40.7
Dollars
71,155
72.061
Dollars
-2,878
4,091
Percent
-8.9
11.7
Dollars
74,033
67,971
S100,000-S249,999
162,782
7.9
«).912
33,999
18.9
46,913
$250,000-S499,999
86,087
4.2
124,386
79,516
23.4
44,870
S500,000-$999,999
41,424
2.0
168,844
116,766
16.5
52,077
S1 ,000,000 or more
30,284
1.5
411,266
370,184
38.3
41 ,082
Ail farms
2,060,822
100-0
81.480
14,201
100.0
67,279
Farm size
(annual sales)
Earned
off-farm
income
Share of
operators
reporting
off-farm
hours
Off-farm
earned
income by
operators
who worked
Off-farm
earned
income of
operators
Share of
spouses
reporting
off-farm
hours
Off-farm
income
earned by
spouses
Off-farm
earned
income of
spouses
who worked
off-farm
Dollars
Percent
Dollars
Dollars
Percent
Dollars
Dollars
$9,999 or less
54,641
58.7
27,457
46,775
44.1
14,756
33.460
Sl0,000-$99.999
48.422
55.5
24,295
43.775
45.5
13,095
28,780
$100,000-$249,999
35,445
31.1
11,074
35,608
54.4
14,722
27,063
$250,000-$499.999
33,238
20.4
7,559
37,054
45.2
13,439
29,732
$500,000'S999,999
30,086
18.6
7.790
41 .882
44,8
12,816
28,607
$1,000,000 or more
28,271
12.6
4,898
38,873
37.2
12,017
32,304
All farms
48,818
52.1
23,318
44.756
45.4
13.943
30,711
Source: 2004 ARMS data.
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The inverse relationship between farm size and off-farm work still holds
after controlling for other factors, as demonstrated econoraetrically by many
researchers (Lass et al., 1989, 1 99 1 ; Yee et aL, 2004). In addition, Goodwin
and Bruer (2(K)3) and Fernandez-Cornejo et al. (2005) showed that the
inverse relationship holds for both operator and spouse.
Time allocation between onfarra and off-farm activities by household
members appears to be the underlying reason for the inverse relationship
between farm size and off-farm work. This relationship appears to be valid
regardless of the sequence in which lime is allocated between farm and off-
farm work. As Olfert ( 1 984) notes, it may be the case that f^mers choose
farm size and type after knowing the time commitments required by an off-
farm job, or farmers may choose the type and amount of off-farm work after
taking into account the nature of the labor requirements on the farm.^ *
Off-Farm Income and Farm Location
Off-farm employment also varies geographically, with widely differing
shares of off-farm income (to total income) even within States (fig. 2). In
general, high ratios of off-farm earned income to total income are exhibited
in the four regions — the Northeast, Appalachian, Southern Plains, and
Northwest — where job opportunities tend to be highest or farm income low-
est. In many cases, one family member may focus on the farm operation
while the spouse and children work off the farm. In other situations, the
farm operation may be a side job and a refuge from urban stress.
The supply of off-farm labor has been shown to be positively related to
urban proximity (Lass et al., 1991). Moreover, Gardner (2001) found that
farmers’ income growth is inversely related to the rural share of a State’s
population. Gardner observed that this finding supports Schultz’s (1950)
hypothesis that “a larger presence of nont'ann people in a State is good for
Figure 2
The importance of off-farm income by ASD*, 2001
(off-farm earned income/totai income)
I ] 71 - 90%
■ >90%
*ASD = Agricultural Statistics District.
Source: 2001 ARMS data.
"The tradeoff beiween time spent
in onfann and off-farm activities also
manifests itself in Conserv'ation
Reserve Program (CRP) participation.
Boisvert and Chang (2006) found
empirical evidence that a household’s
decision to participate in the CRP and
to work off the farm are made Jointly
rather than independently.
Paitieipation in off-farm work with
higher wages provides an incentive for
operators to work less on tlie fann and
to take land out of production and
commit it to the CRP. As a result, par-
ticipation in the CRP and off-farm
work increase hou.sehold income.
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the growth of farmers’ incomes, because it increases their off-farm earnings
opportunities and increases the demand for the goods and services that
farmers produce.” This may be particularly true for agricultural States with
large urban populations such as Texas, where ofF-farm opportunities
increase near one of that State's four major cities — ^Dallas-Fort Worth,
Houston, San Antonio, and Austin.
Off-Farm Income, Type of
Enterprise, and Human Capital
Off-farm work is less likely on farms with labor-intensive enterprises such
as dairy (Leislritz et ai., 1985) and other livestock (Lass et al., 1991;
Goodwin and Bruer, 2003). Moreover, dairy farmei^ who do work off the
farm tend to require higher “wages” (the opportunity cost of labor is higher)
to work off farm than farmers working in other enterprises.
The supply of off-farm labor has also been shown to be positively related to
human capita! such as education and experience of the operator and spouse
(Lass et al., 1991). The number of children is positively associated with off-
farm employment for farm men, but the association is negative for farm
women. More children may imply more need for additional income but also
additional child care at home.
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Off-Farm Work, Scale and Scope
Economies, and Efficiency
The importance of off-farm income to all U.S. farmers is widely acknowl-
edged, and the relative dedication to off-farm work is related to farm size,
location, specialty, and operator characteristics. However, is off-farm
work actually helping farm households in general, and those operating
small farms in particular, to improve their economic performance? Since
scale and scope economies, as well as economic efficiency, are key
concepts used by economists to examine economic performance, this
section introduces those concepts as they relate to off-farm work.
A farm is said to have economies of scale (or increasing returns to scale)
if the average cost of production declines as output (scale of production)
increases (see box, p. 4). This decline in per-unit costs as output increases
suggests that smaller farms can achieve cost advantages by becoming
larger. The concept of economies of scale is an im{K>itant one. For
example, faims with lower average costs are belter able to cope with
higher input prices (Kumbhakar, 1 993). On the other hand, increasing
returns to scale in production may lead to consolidation of firms with
potential effects on competition (Hallam, 1991).
With multiple outputs, the measurement of scale economies becomes
more complicated. In addition to changes in costs that occur as output
expands, there are also changes in costs due to the product mix (Hallam,
1991). If it is cheaper to produce several outputs in one operation than it
is to produce them in separate operations, economies of scope are said to
occur (see box, p. 14).
Off-Farm Work and Scale Economies
We estimated the scale economies for com and soybean farms for 1996-
2000, from an input perspective. Scale economies both at the farm level
(the measure traditionally reported) and at the household level (including
off-farm income-generating activities as an output) are considered. At the
farm level, the elasticity of scale ranges from about 0.56 for smaller farms
(gross sales less than $100,000), to about 0.8 for the larger famis (sales
greater tJian $500,000) (table 5). This means that to support a 10-percent
increase in outputs, smaller farms would require a 5.6-percent increase in
all inputs, while hirger farms would require an 8-percent increase in
inputs. Thus, the greater scale economies available for smaller operations
provide a major inducement to increase farm size (compared with the
larger farms whose scale elasticities are closer to 1).
However, at the household level, with off-farm income-generating activi-
ties included, the scale economies available are lower (scale elasticity is
closer to 1; that is, clo.ser to constant returns to scale). Thus, the scale
elasticity is higher for all sizes, ranging from 0.73 to 0.96 (table 5). So for
smaller farms, a 10-percent increase in all outputs requires a 7.3-percent
increase in inputs, while larger farms require a 9.6-percent increase in
inputs.’^ More importantly, the difference between the scale elasticities at
the household and farm levels is larger for the smaller farms (30 percent)
'-The scale elasticity increases
(moves closer to constant returns
to scale) when off-farm income is
included because of the theoreti-
cal relationship between scale
and scope economies in mulli-
product finns; "the presence of
scope economies ‘magnifies’ the
extent of overall economies of
scale beyond what would result
from a simple weight sum of
product specific economics of
scale” (Baumol ei al,. 1982).
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Table 5
Scale economies for corn/soybean farms, 1996-2000
Elasticity of scale
Farm level Household level
(Excluding (Including off-
Farm type'' Gross sales off-farm farm income)
income)
Farming occupation/
< $100,000
0.56
0.73
lower sales
Farming occupation/
$100,000-$249.999
0.74
0.88
medium sales
Large family farms
$250.000-$499,999
0.77
0.94
Vary large family farms
>$500,000
0.80
0.96
All farms
0.66
0.83
'Excluding limited-resource farms and retirement/residential farms. Limited-resource farms are
small farms with gross sales less than $100,000, total farm assets less than $150,000, and
total operator household income less than $20.(K>0. Limited-resource farmers may report farm-
ing, a nonfarm occupation, or retirement as their major occupation. Relirement/residential
farms are small farms whose operators report they are retired or engaged in a major occupa-
tion other than farming) (Hoppe et a!., 1999)
Source: Nehring et at.. 2005.
than for the larger farms (around 20 percent). Thus, households operating
smaller farms may compensate for the scale disadvantages of their farm
business activities with the advantages of off-farm income-generating activi-
ties. This advantage may also support the notion that integrated farm and
nonfarm labor markets are enabling many small farms to survive and
flourish to an extent not thought possible three decades ago (Gardner, 2005).
Off-Farm Work and Economies of Scope
Scope economies measure the cost savings due to simultaneous production
of outputs relative to the cost of separate production (see box, p. 14). The
concept of economies of scope is useful in assessing the advantages of
output diversification. Given the importance of off-farm income to U.S. farm
households, scope economies may be expanded to include as output any
income-generating activities on or off the farm (household-level scope
economies) (see appendix 1).^ ^ Our estimates for com and soybean farms
show substantial household-level scope economies, 0.24 on average. This
means that farm households engaged in off-farm income-generating activi-
ties together with the production of traditional farm outputs have cost
savings of 24 percent relative to carrying out those activities separately.’^
The cost savings are likely to arise from the sharing of managerial expertise
(of the operator and spouse) between onfarm and off-farm activities.
Economic evaluations of the farm business alone, then, provide an incom-
plete view because they exclude off-farm activities, which are an important
means of output diversification.
'-'Farms that produce the two out-
put groups separately are those that
cither produce conventional outputs
and no orf-fann income or else gener-
ate off-farm income but no conven-
tional outputs. While our sample
includes farm households that produce
conventional outputs with no off-farm
activities, it technically docs not
include households with zero tradi-
tional outputs. However, the sample
does include many farm households
w'iih very small revenues from tradi-
tional outputs because, for statistical
purposes, in the U.S., a fann i.s cur-
rently defined “as any place from
which 5 1 .000 or more of agricultural
products were sold or normally would
have been sold during the year under
consideration" (USDA, 200.5), Wc
consider five outputs (com. soybeans,
other crop.5, livestock, and
operator/spouse off-farm labor) and
five inputs (hired labor, operator labor,
spouse labor, miscellaneous inputs,
and pesticides). The method of calcu-
lating scope economies, as well as the
underlying cost function, is shown in
appendix 1.
'^This result is valid on the aver-
age, not necessarily for all the
com/soybean farms studied. For
example, it is not likely to be valid for
the largest farms in the sample (whose
operators are less likely to w-ork off
the farm, table 4). As shown in
appendix I, the underlying cost func-
tion is a function of the output quanti-
ties (and. thus, gross sales), and so are
scope economies. The values reported
here are calculated at the means of the
sample.
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Scope Economies
ScoF>e economies measure the total cost saviiigs due to simultaneous ,
production of outputs relative to the costs of; separate production {appendix
1 ). Given scope economies, it is less costly to pn^uce several outputs in
one operation than to produce each output in separate operadoiis {or joint
production in one operation generates more output than separate production
in two different operations using the same resources). An often-cited
example of scope economies is fast food outlets, where savings are obtained
by sharing storage, cooking facilities, and customer service in the produc-
tion of many food products. In general, scope economies may arise from
the presence of public inputs or from sharing of imperfectly divisible quasi-
fixed inputs in the production of different goods (Fernandeiz-Comejo et al.,
1992). In our context, farm households achieve scope economic by diversi-
fying or pursuing off-farm activities in addition to the onfirm production of
traditional commodities.
To illustrate the possible advantages of “producing"’ onfarto and off-farm
outputs in a farm household, we may use the example of a production possi-
bilities curve (often used in economics). When the production possibilities
curve fACB) is shaped as in the figure, it is advantageous;tq produce onfarm
and off-farm outputs together. As the figure shows, total output produced by
a farm household at point C (a combination of onfarm and off-farm outputs)
is higher than output produced either at A or B (or a linear combination of
both, line AB) while using the same amount of resources.
Diagram of a production possibilities curve
Onfarm
traditional
output
Scope economies for farm househoid.s are likely to arise from the sharing of
managerial expertise (and its many components, such as accounting and
information processing skills, sales expertise, administrative and technical
know-how, etc.) between onfarm and off*fann activities.^^ The expertise of
many farm operators and/or their spouses is used in off-farm jobs in private
businesses and Government; and in self-employment (Mishra et al., 2002). A
USDA survey shows that the largest share of off-farm work done by opera-
tors and their spouses is accounted by work in executive, administrative, and
managerial positions, service occupations, administrative support, and sales
(Covey et al., 2004).
tSAs is well known, diminishing marginal labor productivity is a detemiinant in die allocation
of lalx>r between onfarm and off-fann activities. In addition, ltdxw requbements for crop pro-
duction are often concentrated in very few months of the year. Tbu;^ the marginal productiv-
ity of managerial labor for the rest of the year is often very low or negKgibie (Olfert, 1984).
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Off-Farm Work and Efficiency
Technical efficiency measures how well a farm transforms inputs into
outputs given the technology at its disposal (Kumbhakar and Lovell, 2000).
Efficiency is of great importance to prevent the waste of resources. Techni-
cally inefficient farmers fail to produce the Tnaximum attainable output with
the amount of inputs used, and therefore can increase output with the
existing level of inputs and available technology.
Two types of technical efficiency are examined here: traditional (farm-level)
technical efficiency of the farm business in the production of commodities;
and technical efficiency at the household level, which considers both on-
and off-farm activities.'''*
Efficiency of the Farm Business
Kumbhakar et al. (1989) examined the effect of off-farm income on farm-
level efficiency for dairy farmers. They reasoned that the larger the off-farm
component of the operator’s income, the less time the operator would spend
managing the farm, eroding farm-level efficiency. Indeed, they found that
farm-level efficiency of Utah dairy farmers in 1985 was negatively related to
off-farm income and that the negative effect was strongest for the smallest
farms, which had the largest off-farm incomes.'^ Femandez-Cornejo (1992)
calculated that the farm-level technical efficiency of vegetable farms in
Florida was negatively related to off-farm work carried out by the operator.
Similar results were obtained by Aigner et al. (2003) for the farm-level effi-
ciency of U.S. corn farmers using 2001 data.
More recently, Goodwin and Mishra (2004) analyzed the relationship
between farm-level efficiency and off-fami labor supply. With data collected
from 7,699 farms in USDA’s 2001 Agricultural Resource Management
Survey (ARMS), they used gross cash income (appendix table 1) over total
variable costs as an operational measure of farm-level economic efficiency.
Greater participation in off-farm labor markets was shown to be signifi-
cantly associated with lower farm-level efficiency. An additional 1 ,000
hours engaged in off-farm work would (end to lower the farm-level effi-
ciency ratio by 0.17 with respect to the mean, which was $1.93 of cash farm
income per dollar of variable cost. This effect, while not large, was statisti-
cally and economically significant. Such findings support the notion hypoth-
esized by Smith (2002) that off-farm work may hinder “smart farming” and
confirm a negative relationship between farming efficiency and the supply
of labor to off-farm employment. As theory predicts, more efficient farmers
are less likely to work off the farm, reflecting the higher opportunity cost
for their labor. Furthermore, the statistical tests performed by Goodwin and
Mishra suggest that off-farm labor supply and farm-level efficiency are
jointly determined."^
Household-Level Efficiency
Rather than estimating the influence of off-farm work on the efficiency of
the farm business, we estimated the household-level technical efficiency
(including on- and off-farm activities), compared it with farm-level effi-
have adopted the tenninology
of “farm-lever' and “houschoki-ievei"
efficiency following a recent publica-
tion by Chavas et al. (2005). Our ear-
lier terminology (as used in Nehring et
al., 2005) was less transparent.
a subsequent article,
Kumbhakar ( 1 993) showed that lower
efficiency is the main reason that small
farms are less profitable than medium
and large farms: another reason being
their higher returns to scale (lower
scale economies).
'^'There is a two-way relation.ship
between the two variables rather than a
cause-and-effect relationship (in eco-
nomic jargon, each variable is endoge-
nous to the other).
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ciency, and examined how those efficiencies vary with farm size. The tech-
nique used in this research isolates the best-practice farm within any size
class, and measures technical efficiency by how close otticr farms are, on
average, to the best-practice fanns, which are assigned a technical efficiency
equal to I and said to be on the “frontier.”
At the farm level, technical efficiencies of com/soybean farms increase with
size from 0.87 to 0.93 {table 6).“^’ However, technical efficiencies at the
household level (when off-farm income is included) are higher (around
0.95) and the measures of technical efficiency do not vary across size
groups. Moreover, while the beneficial effect of off-farm income occurs at
all sizes, it is stronger for smaller farms, whose household-level efficiency
levels are comparable with the farm-level efficiencies of the laiger farms.
This suggests that small com/soybean farmers have adapted to shortfalls In
farm-level efficiency by increasing off-farm income.
^'-'The analysis uses several econo-
metric techniques, including the esti-
mation of an input distance function
and stochastic frontier estimation
(appendix 1; Nchring ct al., 2005) to
estimate technical efficiency at the
farm (excluding off-farm income-gen-
erating activities) and at the house-
hold level (including off-farm
income-generating activities). Data
used were 1995-2003 survey data of
corn/soybean farms from 10 States
(Illinois, Indiana, Iowa, Michigan,
Minnesota. Missouri, Nebraska. Ohio.
South Dakota, and Wisconsin), that
account for most U.S corn and soy-
bean production.
Also, the higher household-level efficiencies are consistent with the positive
scope economies found. Both findings reflect the more efficient use of
resources at the household level, particularly the use of managerial labor
(operator and spouse) shared between onfarm and off-farm activities.
Moreover, as Smith (2002) observes, as farm operators and other household
members engage in off-farm activities, they have less lime available for
fann management. This may inhibit their adoption of management-inten-
sive agricultural innovations and lead to less efficient farming.
-®A farm unit with an efficiency
score of 0.8 is said to be 80 percent as
efficient as the farms on the ‘frontier,"
i.e.. the best performing farms in the
data set.
Table 6
Technical efficiency of corn/soybean farms, 1996-2000
Technical efficiency scores
Farm level (excluding Household level
off-farm income) (including off-
Farm type^ Gross sales ($) farm income)
Farming occupation/
< $100,000
0.87
0.95
lower sales
Farming occupation/
$100.000-$249,999
0.91
0.95
medium sales
Large family farms
$250.000-$499.999
0.91
0.95
Very large family farms
> $500,000
0.93
0.95
Al! farms
0.91
0.95
’Excluding limited-resource and felirement/residential farms.
Source: Nehring el al., 2005
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Off-Farm Work and the Adoption
of Agricultural Innovations
Technological change has been acknowledged as a critical component of
productivity and economic growth (Solow, 1994; Griiiches, 1995). ITie
rapid adoption and diffusion of new technologies in U.S. agriculture has
sustained growth in agricultural productivity and ensured an abundance of
food and fiber (Huffman and Evenson, 1993). Technological innovations
and their adoption have also changed the way farm households regard
employment choices (Binswanger, 1974, 1978). Labor-saving technologies,
in particular, have allowed farm household members to increase income by
seeking off-farm employment (Mishra et al., 2002).^*
While profitability (i.e., the extent of yield increases and/or reduction in
input costs from an innovation relative to the costs of adoption and current
management practices) plays a key role in technology adoption, most
studies acknowledge that heterogeneity among fiirms and farm operators
often explains why not all farmers adopt an innovation in the short or long
run (Bade and Johnson, 1993; Feder and Umali, 1993; Khanna and
Zilberman, 1997; Lowenberg-DcBoer and Swinton, 1997; Rogers, 1961,
1995) (see box, “Factors Influencing Technology Adoption”).
Still, assessments of technology adoption using the traditional economic tools
pioneered by Griiiches (1957) have proven insulficient to explain differing
adoption rates for many recent agricultural innovations. The standard meas-
ures of fai-m (accounting) profits, such as net returns (to management), give an
incomplete picture of economic returns because they usually exclude the
value of management time (Smith, 2002). For example, herbicide-tolerant
soybeans were rapidly adopted despite showing no significant advantage in
net returns over conventional soybeans. On the other hand, adoption of tech-
nologies such as integrated pest management (IPM) has been rather slow
despite explicit economic and environmental advantages (Femandez-Comejo
and McBride, 2002; Smith, 2002). This led to the hypothesis that adoption is
driven by “unquantified” advantages, such as simplicity and flexibility, which
translate into reduced managerial intensity, freeing time for other uses. An
obvious use of managers’ lime is off-farm employment.
Off-Farm Work as a Factor in Early Studies
of Technology Adoption
Early studies of technology adoption viewed off-farm income as influ-
encing adoption of “conservation” practices by providing “supplemental
income” to finance conservation expenditures (Blase, 1960). Ervin and
Ervin (1982), on the other hand, argued that “off-farm income could
reflect the need for supplemental income for family living expenses and
essential farm production expenses other than conservation and less time
to implement and maintain unfamiliar practices.” Survey results on
farmers’ motivation to seek off-farm income and their view of such
employment as permanent rather than temporary, suggest that motivation
is closer the view of Ervin and Ervin.
-'Oft'-fnnn employment was also
facilitated by economic growth in the
nonfarm economy, improved infra-
structure (communications and trans-
portation), as well as education level
of farm household members (Banker
and MacDonald, 2005).
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Factors Influencing Technology Adoption
Rural sociologists recognized early that essential
differences among farmers can explain why they do
not adopt an innovation at the same time. In addition,
the characteristics (perceived or real) of an innovation,
are widely known to influence the adoption decision
(Rogers, 1995; Batz et a!., 1999). Econonnsts and
sociologists have made extensive contributions to the
literature on the adoption and diffusion of technolog-
ical innovations m agnculture (e.g., Griliches, 1957,
Federeta!., 1985; Rogers, 1962, 1995). Such
research typically focuses on the long-term extent of-
adoption and the factors that influence the adoption :
decision.
Farm Stnicture/Size
A basic hypothesis regarding technology transfer is
that the adoption of an innovation will tend to take
place earlier on larger farms than on .smaller farms.
Just et al. (1980) show that, given the uncertainty and
the fixed transaction and information costs associated
with innovations, there may be a critical lower limit on
farm size that prevents smaller farms from adopting.
As these costs increase, the critical size also increase.s.
It follows that innovation.s with large fixed transaction
and/or information costs are less likely to be adopted
by .smaller farms. However, Feder et al. (1985) point
out that lumpiness of technology can be offset by the
emergence of a service sector (i.e., custom service or
consultant). Disentangling farm size from other
factors hypothesized to influence technology adoption
has been problematic. Feder et al. (1985) caution that
farm size may be a surrogate for other factors, such as
wealth, risk preferences, and access to credit, scarce
inputSj or information. Moreover, acce.ss to credit is
related to farm size and land tenure because both
factors determine the potential collateral available to
obtain credit.
Human Capital
The ability to adapt new iechnologie,s for use on the
faiTO clearly influences the adoption decision. Most
adoption studies attempt to measure this trait through
operator age, formal education, or years of fanning
experience (Femandez-Comejo et al., 1994). More
yeais of education and/or experience is often hypothe-
sized to increase the probability of adoption wherea.s
increasing age reduces the probability. Factors
inherent in the aging process or the lowered likelihood
of payoff from a shortened planning horizon over
which expected benefit.s can accrue would be deter-
rents to adoption (Barry et al., 1995; Batte and
Johnson. 1993). Younger farmers tend to have more
education and are often hypothesized to be more
willing to innovate.
Risk and Risk Preferences
In agriculture, the notion that technological innovations
are percdved to be more risky than traditional practices
htK PKirived comsiderabie support in the literature. Many
.resean^ers aigue that the perception of increased risk,
inhibitsadoption (Feder et al.. 1985). Hiebert (1974) and
Feder and O'Mara (1981) show that uncertainty declines
with learning and expenence. Innovators and other early
adopters are believed to be more inclined to take risks
than are the majority of farmers.
Tenure
^VhiJe several empirical studies suppiort the hypothesis
that land ownership encourages adoption, the results
are not unanimous and the subject has been widely
debated (e.g., Feder et al.i. 1985). For example,
Bultena and Hoiberg (1983) found no .support for the
hypothesis that land tenure has a significant influence
on adoption of conservation tillage. The apparent
inconsistencies in the empirical results are due to the
nature of the innovation. Land ownership is likely to
influence adoption if the innovation requires invest-
ments tied to the land. Presumably, tenants are less
likely to adopt these types of innovations because the
benefits of adoption wdll not necessarily accrue to
them.
Credit Constraint, Location, and Other Factors
Any fixed investment requires the use of own or
borrowed capital Hence, the adoption of a non-divis-
ible technology, which requires a large initial invest-
ment, may be hampered by lack of borrowing capacity
(El-Osta and Morehart; 1999). Location factors
as soil fertility, {^st infestations, clihiate, and avail-
ability or access to information-^an influence the
profitability of different technologies across different
farms. Heterogeneity of the resource base has been
shown to influence technology adoption and prof-
itability (Green et al, 1996; Thrikawala et al, 1999).
Irrigation may also influence adoption. Irrigation
generally increases yields and profitability and reduces
production risk. However, irrigation may also increase
risk; for example, it may encourage certain pest popu-
lations (Harper and Zilberman, 1989). Contractual
arrangements for the production/marketing of the crop
are also believed to influence the adoption of certain
technologies. Contracts often specify the acreage to
be growm or quantity and quality of protiuct to be
delivered and may also require the application of
certain inputs and practices.
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McNamara ct ai. ( 1991 ) used empirical evidence from peanut producers to
conclude that integrated pest management (IPM) required substantia! time
for management and that off-farm employment may present a constraint to
IPM participation. Fernandez-Comejo et al. (1994), Femandez-Coraejo
( 1 996 , 1 998 ), and Fernandez-Cornejo and Jans ( 1 996) found similar results
for vegetable and fruit producers. Wozniack (1993) considered livestock
feeding innovations and showed that off-farm wage income w'as inversely
related to the likelihood of early adoption and acquiring information.^^
More recent survey results show that operators of high-sales, large, and very
large farms — which depend on farm revenues more (and therefore less on
off-farm employment) than smaller fanns — tend to adopt more manage-
ment-intensive technologies. For example, around 18 percent of the opera-
tors of larger farms adopted precision farming in 1998. In contrast, only 3
percent of the operators of smaller farms (who worked more off-farm hours)
adopted precision farming (Hoppe, 2001).
Weaknesses of Early Studies
While insightful, early studies failed to model the interaction of technology
adoption and off-farm employment decisions based on the underlying
economic theory and consistent with faiTners’ optimization behavior. Rather,
they simply included some measure of off-farm work as one explanatory
variable in the adoption decision. Early studies also had some econometric
problems, such as not accounting for simultaneity of the off-farm work and
adoption decisions and the possibility of self-selection (see appendix 2)P
Finally, etu'lier studies did not examine the relationship between technology
adoption and household income from farm and off-farm sources.
Modeling the interaction Between Off-Farm
Work and Adoption Decisions
To address these issues, we examine the interaction of off-farm income-
earning activities and adoption of four agricultural technologies (see box, p.
22) of varying managerial intensity, including herbicidc-tolcrant crops
(Fernandez-Comejo and Hendricks, 2003; Fernandez-Cornejo ei al., 2005),
precision agriculture (Femandez-Coraejo and Southern, 2004), conservation
tillage (Fernandez-Comejo and Gregory, 2004), and Bt {Bacillus
ihuringiensis) com (Fernandez-Comejo and Gregory, 2(X)4). We also esti-
mated empirically the relationship between the adoption of these innova-
tions and farm household income from onfarm and off-farm sources.
For this purpose, we expanded the agricultural household model to include
the technology adoption decision together with the off-farm work participa-
tion decisions by the operator and .spouse (appendix 2).^* We developed an
econometric model to examine the interaction of off-tarm work and adop-
tion of agricultural technologies, as well as the impact of technology adop-
tion on farm household income (from onfarm and off-farm sources) after
controlling for such interaction (appendix 2). The model used data from
nationwide surveys of com and soybean farms in 2000-2001.
-'Measures used included off-fann
income as a percentage of total house-
hold income (Ervin and Ervin, 1982)
or days (or hours) per year that the
operator worked off-farm (Fernandez-
Cornejo. 1996, 1998; Fernandez-
Comejo and Ians, 1996).
-■"^Self-scleciion occurs because fann-
ers are not assigned randomly into
groups (e.g., farmers that work off farm
or not. adopt or not) but make the
choices themselves. Therefore, group
members may be systematically differ-
ent, and these differences may manifest
themselves in farm performance and
could be confounded with differences
due purely to working off farm (or
adoption). This situation, calleti self-
sclcclion, may bias the statistical results
unle.ss it is corrected (appendix 2),
‘^The agricultural household model
(Singh et al.. 1986; Huffman. 1980.
199 1; Lass ct al., 1989; Lass and
Gempesaw, 1992; Kimhi. 1994, 2004)
combines in a single framework ail
important economic decisions of the
farm household.
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We hypothesize that adoption of managerial-saving technologies (such as
herbicide-tolerant (HT) soybeans) frees up management time for use else-
where (notably off-fann empIo>Tnent), leading to higher off-farm income. On
the other hand, managerially intensive technologies (such as precision agricul-
ture) would result in less time available for off-farm activities, leading to
lower off-farm income.
It is also possible that farmers already working off farm may be more
disposed to adopt managerial-saving technologies. This may lead to addi-
tional off-farm work and result in even higher off-farm income. Similarly,
farmers who are working off farm may be reluctant to adopt managerially
intensive technologies.^^
In either case, we anticipated that adoption of managerial-saving technolo-
gies would be associated with higher off-farm income and adoption of
managerially intensive technologies would be related to lower off-farm
income. (In this report, we show only the empirical validity of the relation-
ship, but not the direction of the causality.)
A two-stage econometric estimation method was used to estimate the empir-
ical model (appendix 2). The first stage, the decision model, examines the
factors influencing off-farm work participation and technology adoption
decisions. The second stage is used to estimate the relationship between
technology adoption and household income.
Technology Adoption and
Off-Farm Income
We find that the relationship between the adoption of herbicide-tolerant
(HT) soybeans and off-farm household income is positive and statistically
significant (table 7). The elasticity of off-farm household income with
respect to the probability of adoption of HT soybeans (calculated at the
mean) is +1.59.^^ That is, after controlling for other factors, a 15.9-percent
increase in off-fann household income is associated with a lO-perceni
increase in the probability of adopting HT soybeans. The adoption of HT
soybeans is also positively and significantly associated with total household
income (from off-farm and onfarm sources). A 9.7-percent increase in total
household income is associated with a 10-f«rcent increase in the probability
of adopting of HT soybeans. On the other hand, adoption of herbicide-
tolerant soybeans did not have a significant relationship with household
income from farming (table 7).
Results for adoption of conservation tillage are similar to those obtained for
HT soybeans, but of a lesser magnitude (table 7). Controlling for other
factors, the association between the adoption of conservation tillage and off-
farm household income is positive and statistically significant (elasticity
+0.98). An increase in off-farm household income of 9.8 percent is associ-
ated with a 10-percenl increase in the probability of adopting conservation
tillage. The association of adoption of conservation tillage and total house-
hold income (including both off-farm and onfarm sources) is positive and
statistically significant. The elasticity of total household income with respect
to the probability of adopting conservation tillage is +0.46.
Olfert observes: "Given the
nature of nonfarm jobs, where com-
mitments to specific timeframes arc
frequently more precise than is the
case in farming, it is possible that a
nonfarm job receives first priority in
the allocation of time with farm pro-
duction undertaken as a second prior-
ity." However. Olfert adds: “It may
also be the case that the decision
regarding time allocation to farm and
nonfarm work is made simultaneously
or that the off-fann employment deci-
sion influences the type and size of
farm that is optimal. Farm enterprises
that are less demanding in their com-
mitments may be chosen to permit
nonfarm employment. Knowing the
time commitments required by the
nonfarm job. the farm size and type
will be organized to accommodate that
schedule. Similarly, given the nature of
labour requirements on the fann, a
choice will be made about the type
and amount of nonfarm work.”
‘^’Results are expressed in terms of
elasticity — the percent change in a par-
ticular variable (c.g., household
income) relative to a .small percent
change in adoption of the technology
from current levels, controlling for
other factors, The elasticity results can
be viewed in terms of the aggregate
change in a particular variable (across
an entire agricultui'al region or sector)
relative to aggrcgale increases in adop-
tion (as more and more producers adopt
the technology). However, in terms of a
typical farm — that has either adopted
or not — the elasticity is usually inter-
preted as the (marginal) farm-level
change associated with an increase in
the prt)babiliiy of adoption, away from
a given, or current, level of adoption.
As shown in appendix 2. the regression
model controls for fann location and
typology, operator age, education, and
experience, number of children, price
of the crop, a measure of specialization
on soybeai\/com production, a measure
of the extent of livestock operations,
farm size, and proxies for local labor
market conditions.
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Table 7
Elasticities of farm household income with respect to the
probability of adopting technologies of differing managerial intensity
With respect to adoption of:
Elasticity of
Yield
monitors
Bt corn’
Conservation
tillage
Herbicide-
tolerant (HT)
soybeans
Onfarm household annual income
0^
02
02
02
Off-farm household annua! income
-0.84
02
-^0.^8
•1-1.59
Total household annual income
02
-^0.46
+0.97
^Bt = Bacillus thuringiensis)
^Statistically insignificant underlying coefficient. The underlying coefficients and ttieir standard
errors are shown in appendix 2.
On the other hand, the relationship between the adoption of yield monitors
(an important component of precision agriculture) and off-farm household
income is negative and statistically significant (elasticity = -0.84) when wc
control for other factors. That is, a decrease in off-farm household income
by 8.4 percent is associated with a 10-percent increase in the probability of
adopting yield monitors. Adoption of yield monitors did not have a statisti-
cally significant association with either farm household income or total
household income. These results are quite different from those for HT
soybeans and conservation tillage. This empirical evidence suggests that
yield monitoring techniques are management-intensive compared with the
other two technologies, which spare management time.
Finally, the relationship between the adoption of Bt corn with either off-
farm or onfarm household income was not statistically significant, indi-
cating that Bt corn may be manageriaily neutral.
These results are consistent with anecdotal evidence (see box “Selected
Agricultural ...”) that herbicide-tolerant soybeans save managerial time
because of the simplicity and flexibility of weed control. Conservation
tillage is also believed to save managerial labor, but to a lesser degree than
HT soybeans. Our results for yield monitoring are also consistent with
anecdotal evidence that precision farming techniques in general are manage-
rially using. Before the commercial introduction of Bt com in 1996, most
farmers accepted yield losses rather than incur the expense and uncertainty
of chemical control. For those farmers, the use of Bt com was reported to
result in yield gains rather than pesticide savings, and savings in managerial
time were small.
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Selected Agricultural Technologies
and Their Managerial intensity
Herhicide-tolerant (HT) soybeans contain traits that
allow them to sunive certain herbicides that previ-
ously would have destroyed the crop along with the
targeted weeds. This allows farmers to use more effec-
tive poslemergent herbicides, expanding weed
management options (Gianessi and Carpenter, 1999).
The most common herbicide-tolerant crop.s are
resistant to glyphosate, a herbicide effective on many
species of grasses, broadleaf weeds, and sedges.
Adoption of HT soybeans has risen rapidly since
commercial availability in 1996. HT soybean use rose
quickly to about 17 percent of U.S. soybean acreage in
1997 and reached 87 percent in 2005 (Femandez-
Comeio and McBride, 2002; USDA, NASS, 2003):
Herbicide-tolerant soybeans save managerial time
because of the relative simplicity and flexibility of the
weed control program. The herbicide-tolerant tech-
nology allows growers to apply one herbicide product
over the soybean crop at any stage of growth, instead
of using several herbicides, to control a wide range of
weeds “without sustaining crop injury” (Gianessi and
Carpenter. 1 999). In addition, using HT soybeans iS
said to make harvest easier (Duffy, 2001 ).
Conservation tillage is defined as “any tillage or
planting system that maintains at least 30 percent of
the soil surface covered by residue after planting”
(Conservation Technology Information Center, 2004).
It includes no-till, ridge-till, and mulch-tili techniques.
Tlie impact of conservation tillage in controlling soil
erosion and soil degradation is well documented
(Edwards, 1995; Sandretto, 1997). By leaving
substantial amounts of residue eVenly distributed over
the soil surface, conservation tillage reduces soil
erosion by wind/water, increases water infiltration and
moisture retention, and reduces surface sediment and
chemical runoff. Adoption of conservation tillage was
estimated at 2 percent of planted acreage in 1968 and
grew fastest during 1975-85. reaching nearly 28
percent in 1985 (Schertz, 1988). It reached about 37
percent of planted acreage in 2002 (Conservation
Technology Information Center, 2004). Conservation
tillage is used primarily to grow com, soybeans, small
grams, and cotton.
Conservation tillage is believed to save managerial
labor (Sandretto, mi\ USDA, 1998). While it is
accepted that adoption of conservation tillage leads to
labor savings, its slower rate of adoption compared
with HT crops may be because the managenai savings
are less.
Ht crops carry the gene from the soil bactenum
Bacillus ihuringiensis (Bt) and are able to produce
proteins that are toxic to certain insects. Bt corn, orig-
inally developed to control the European com borer,
■wd& planted on 35 percent of com acreage in 2CK)5, up
from 24 percent in 2002. The recent upswing may be
due to the commercial introduction in 2(K)3/04 of a
new Bt com variety that is resistant to the com root-
worm.
Before the commercial introduction of Bt com in
1996, chemical pesticide use was often not profitable
to control the European com borer (ECB) and timely
application was difficult (Femandez-Comejo and
Caswell, 2006). Many farmers accepted yield losses
rather than incur the expense and uncertainty of chem-
ical control. For those farmers, the use of Bt com
resulted in yield gains rather than pesticide savings,
and managerial time savings were minimal.
Precision agriculture (PA) is often characterized as a
suite of technologies used to monitor and manage
subfield spatial variability. It includes, for example,
global positioning systems, grid soil sampling, yield
monitors, and input applicators that ctin vary rates
across a field (Daberkow et al., 2002). These technolo-
gies can be used independently dr as a package of
technologies that includes, for example, the use of grid
soil sampling, a variable-rate input applicator, and a
yield monitor. PA ha.s been growing relatively slowly.
Yield monitors, which provide faimers site-specific
data to allow them to vaiy input application and
production practices, are the most extensively adopted
PA component. Yield monitors were used in about 33
percent of total com acreage in 2001 and in about 25
percent of soybean acreage. Adoption of other compo-
nents of PA is even slower. Adoption of variable-rate
applicators reached just 1 0 percent of com acreage for
fertilizer and 3 percent for pesticides or seeds in 2001
(Daberkow et al. 2002).
Unlike herbicide-tolerant soybeans, which provide
savings in management time (and therefore allow
operators to obtain higher income from off-farm activ-
ities). yield monitors (and precision agriculture in
general) are generally believed to be human capital-
intensive (Griffin at al, 2004).
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Conclusions
As onfarni and off-farrn activiiies compete for scarce managerial time in
U.S. farm operator households, economic decisions (including technology
adoption and other production decisions) are likely to shape and be shaped
by time allocation within the household. Time allocation decisions are
usually not measured directly, but their outcomes, such as onfarm and off-
farm income, are observable.
Our research finds that the farm-level efficiency of farm households
decreases as off-farm activities increase. Smaller farms, which average the
highest off-farm incomes, obtain the lowest farm-level efficiencies. These
results support the hypothesis that farm operators who devote more time to
off-farm activiiies have less time to manage the farm. However, examining
efficiency from a wider perspective, we find that household-level efficiency
(including off-farm income-generating activities) is higher across all farm
sizes than farm-level efficiency alone. Moreover, the beneficial effect of
off-farm income is higher for smaller farms. In fact, farm households oper-
ating small farms achieve efficiency levels comparable to those operating
larger farms when off-fami income is included. These results, therefore,
suggest that farm households operating small farms have adapted to short-
falls in fanning perfonnance by increasing off'-farm income.
By including off-farm income-generating activities in the household output
portfolio (in addition to the traditional farm products), many farm house-
holds, especially those operating smaller farms, are able to enhance diversi-
fication. The advantages of such diversification, measured by the
household-level economies of scope, are substantial. These results suggest
that off-farm employment may enhance onfarm diversification, especially
for households operating small farms.
The economic inducement of smaller farms to increase their size (measured
by the economic concept of scale economies) is reduced when we include
off-farm income. Household-level scale economies (which include off-farm
income-generating activities) are closer to constant returns to scale than are
farm-level scale economies (which only consider the farm business).
However, the beneficial effect of off-farm activities in improving scale
economies is more pronounced for households operating smaller fanns.
These findings provide a different way of measuring the role of off-farm
work in improving the economic condition of farm households, particularly
those operating small farms.
The adoption of agricultural innovations is also linked to off-farm income
through managerial time. For example, the adoption of managerial time-
saving technologies is significantly related to higher off-farm household
income for U.S. corn/soybean farmers, after controlling for other factors. On
the other hand, managerially time-intensive technologies are associated with
significantly lower off-farm income.
In a broader sense, these findings confirm the tradeoff between time spent
on farm and off-farm activities or, in economic terms, the substitution of
economies of scope (derived from engaging in multiple income-generating
activities, on and off the farm) for economies of scale.
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A number of implications follow. Each of these implications reinforces the
importance of understanding farmers’ decisions in the context of the fann
household rather than the farm operation alone. First, our research provides
empirical confirmation of Smith’s suggestion that households operating
small farms, w'hich lack economies of scale, are more likely to devote time
to off-farm opportunities, more likely to adopt management-saving tech-
nologies (like herbicide-tolerant crops), and less likely to adopt manage-
ment-intensive technologies (such as integrated pest management).
The relationship between off-farm work and economic performance also
suggests that a farm household’s dependence on off-farm income has an
effect on the distributional consequences of government policies. Govern-
ment policies affecting agriculture — such as conservation, research and
development, extension, and farm support — may affect farm households
differently depending on the relative importance of onfarm and off-farm
income-generating activities. Thus, the consequences of government policies
depend on the diversity of U.S. farm households, particularly regarding their
income sources. F'or example, a policy promoting the adoption of manage-
ment-intensive agricultural techniques (such as 1PM) may not be fully effec-
tive unless it lakes into consideration the demands in managerial lime
imposed by IPM adoption.
This research also has implications for private agricultural research and devel-
opment (R&D). While innovators often base their economic evaluations of
returns to R&D on the expected profitability of potential innovations for
farmers (i.e., the extent of yield increases and/or input cost reduction resulting
from an innovation relative to the costs of adoption and cuiTcnt management
practices), this report shows that there is an important additional element to be
included in such evaluations: the value of management time.
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Appendix 1 — Economies of Scale and
Scope and Technical Efficiency
This discussion uses two different but related methodologies and data sets
and follows the analysis described in Nehring et al., 2(X)5. First using
1996-2000 survey data, we use an input distance function to estimate scale
economies and technical efficiency, and compare these performance meas-
ures al the farm and household levels. Second, using 2{XX) survey data, W'e
set up a multi-activity cost function to analyze labor aUocation decisions
within the farm operator household and estimate scope economies. We
inteipret off-farm income-generating activities as outputs, along with com,
soybeans, livestock, and other crops. For both estimations, we use detailed
survey information of the farm operator household from USDA’s Agricul-
tural Resource Management Survey (ARMS).
Economies of Scale and Technical Efficiency
The analysis of production structure and performance requires representing
the underlying multi-dimensional (input and output) production technology.
This may be formalized by specifying a transformation fiinction,
T(X,Y,R)=0. which summarizes the production frontier in terms of an input
vector X, an output vector Y, and a vector of external production determi-
nants R. This information on the production technology can also be charac-
terized via an input set, L(Y,R), representing the set of all X vectors that can
produce Y, given the exogenous factors R.
An input distance function (denoted by superscript I) identifies the least
input use possible for producing the given output vector, defined according
to L(Y,R):
(1) D\X,Y,R) = Max{p:(x/p) sUY,R)).
This multi-input, input-requirement function allows for deviations from the
frontier. It is also conceptually similar to a cost function, if allocative effi-
ciency is assumed, in the sense that it implies minimum input or resource
use for production of a given output vector (and thus, implicitly, costs).
However, it does so in a primal/technical optimization or efficiency context,
witli no economic optimization implied.
For the farm-level model, the Y vector contains Yj = crops (corn, soybeans,
and other crops), K, = livestock, and, for the household-level model, * =
crops and livestock, and F,* = off-farm income-generating activities, as
farm “outputs.” With Fj* included, one might think of F as a multi-activity
rather tlian a multi-output vector. The components of X are defined as X/ =
land (LD), X 2 - hired labor (L), = operator labor (including hours
worked off-farm )(K), = spouse labor (including hours worked off-farm)
(E), X- = capital (F), and - materials (M).
The scale economies measure may be computed from the estimated model
via derivatives or scale elasticities: D^(X,Y,t)ldln F^,, =
for M outputs (simiUir to the treatment in Baumol et al. (1982) for a
multiple-output cost model, and consistent with the output distance function
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formula in Fare and Primont (1995). However, the inverse measure is more
comparable to the cost literature, where the extent of increasing returns or
scale economies is implied by the shortfall of the measure from 1. Again,
this measure is based on evaluation of (scale) expansion from a given input
composition base.
The distance function can be approximated by a translog functional
as follows:
(2) In t + I,,, a,,, In +0.5 In In X*^.^
+ a^. In Tj.., + 0.5 In In Yj.^ + 5^^ In In ,
or
(3) -!n Xj,-^ = ay + a, t + X,^, In 0.5 X,„ X„ In In X\.,
+ «i I” y^i, + 0-5 Si 2, In y„-, In 7,, + 2, 2,„ 5,„ In F,,, In - In O',, ,
where i denotes farm and t time period. This functional relationship, which
embodies a full set of interactions among the X, Y and t arguments of the
distance function, can more succinctly be written as: -In Xj.j^ ~ TUX/X^. Y.
t) = TL(X^, Y, /).
The input distance function is well-suited to measure technical efficiency.
For empirical estimation of technical efficiency, we append a symmetric error
term, v, to equation (3) and change the notation in to “u.” Tlie
resulting function (with the subscripts it suppressed for notational simplicity)
is: -In Xi - TL(X^, Y, r) + v - u, where the term (- «) may be interpreted as
inefticiency (as technical efficiency measures the distance from the frontier).
This method is known as a stochastic frontier production function, where
output of a firm is a function of a set of inputs, inefficiency (- u) and a
random error v (Aigner et al., 1977; Greene, 1995, 1997, 2000).
To estimate the function, we used Coelli’s FRONTIER program (Coelli,
1996), based on the error components model of Battese and Coelli (1992).
Since -u represents inefficiency, the technical efficiency scores arc given by
exp(-u) = D^(X*,Y, t). If a firm is not technically inefficient (the firm is on
the frontier), u is equal to 0 and its technical efficiency score is 1.
In the absence of genuine panel data, repeated cross-sections of data across
farm typologies are used to construct a pseudo-panel data set (see Deaton,
1985; Heshmati and Kunibhakar, 1992; Verbeek and Nijman, 1993). The
pseudo-panels are created by grouping the individual observations into a
number of homogeneous cohorts, demarcated on the basis of their common
observable time-invariant characteristics, such as location and ERS farm
typology. The .subsequent economic analysis then uses the cohort means
rather than the individual farm-level observations. ERS farm typology
categories are summarized in Nehring et al. (2005). The resulting pseudo
panel data set consists of 13 cohorts by State, for 1996-2000, measured as
the weighted mean values of the variables to be analyzed. There are a
total of 650 annual observations (130 per year), summarizing the activities
of 1,934 farms in 1996, 3,890 in 1997, 2,311 in 1998, 3,201 in 1999, and
2,394 in 2000.
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Economies o f Scope
When a firm produces more than one output, there is a qualitative change in
the production structure that makes the concept of economies of scale devel-
oped for a single output insufficient. For multipnxluct firms, production
economies may arise not only because the size of the firm is increased but
also due to advantages derived from producing several outputs together
rather than separately. Thus, more than one measure is necessary to capture
the economies (or diseconomies) related to tire scale of operation (volume
of output) and the economies related to the scope of the operation (composi-
tion of output or product mix). The concepts of economies of scale and
scope for multiproduct firms have been developed by Panzar and Willig
(1977, 1981) and Baumol et al. (1982). They have been used in agriculture
by Akridge and Hertel (1986) and Femandez-Comejo el al. (1992).
Economies of scope measure the cost savings due to simultaneous produc-
tion relative to the cost of separate production. In general, scope economies
occur when the cost of producing all products together is lower than
producing them separately.
Fonnally, consider a partition of the output set N into two (disjoint) groups
T and N-T. Let Tp be the output quantity (subveclor) of each of the
two groups and (or simply K) the output vector, which consists of all the
outputs, 'file respective cost functions C(Yj), QY^^j) give the minimum
cost of producing the two output groups separately, and QY^^j denotes the
minimum cost of producing them together (Nehring el al., 2005).
The degree of economies of scope (SC) relative to the (output)
set T is defined as:
(1) SC = - C(Y^)]/aY^)
where SC will be positive if there are economies of scope and negative if
there are diseconomies of scope. In our case, we consider the first subset
of the partition to include the four conventional outputs (corn, soybeans,
other crops, and livestock), N={J.2,3.4j and the second subset the non-
conventional off-farm income-generating activities, N-T-(5}.
Farms that produce the two output groups separately arc lho.se that either
produce conventional outputs with no off-farm activities or else those with
off-farm work but no conventional outputs. While the sample includes farm
households that produce conventional outputs and no off-farm activities, it
technically does not include household widi zero traditional outputs.
However, the sample does include many farm households with very small
revenues from traditional outputs because, for statistical purposes, a U.S.
farm is currently defined as “any place from which $1,000 or more of agri-
cultural products were sold or normally would have been sold during the
yeai' under consideration.” (USDA, 2005).
The well-developed restricted cost function is used to estimate the scope
economies. Consider n outputs, m variable inputs, and s fixed inputs and
other exogenous factors such as location or weather proxies; Y = (YJ,... Yn}'
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denotes the vector of outputs, X = (X!,...Xmy denotes the vector of variable
inputs, Z = (Zj....Zsy is the vector of non-negative quasi-fixed inputs and
other (exogenous) factors, and W = IWl,...Wmy denotes the price vector of
variable inputs. The restricted profit function is defined by:
(3) CflV, Y,Z) = h4m { W' X:&T}.
Under the usual assumptions on the technology (production possibilities set
7), the restricted cost function is well defined and satisfies the usual regular-
ity conditions.
Using a normalized quadratic variable cos! iunction, which can be viewed as a
second-order Taylor series approximation to the true cost function, we obtain:
( 4 )
C(W,Y,Z) = aO + (a'b'c')
w
Y
Z
B E F
W
E'C G
Y
f'g'd
Z
where W is a vector of normalized variable input prices, aQ is a scalar
parameter, and a, b, and c are vectors of constants of the same dimension
as Y, and Z. The parameter matrices B, C, and H are symmetric and of
the appropriate dimensions. Similarly, E, F, and G are matrices of
unknown parameters.
Using Shephard's lemma, we obtain the demand functions for variable
inputs which is estimated together with the cost function. We consider five
outputs Y (corn, soybeans, other crops, livestock, and operator and spouse
off-farm labor), five inputs X (hired labor, operator labor, spouse labor,
miscellaneous inputs, and pesticides), and use the pesticides price as the
numeraire. In addition the cost function is specified with two exogenous
factors (Nehring et al., 2005).
The normalized quadratic variable cost function and the four cost-share
equations are estimated in an iterated seemingly unrelated regression
(ITSUR) framework using data for year 20(X). The adjusted R^’s were 0.99
for the quadratic cost function, 0.26 for the hired labor input, 0.21 for the
operator labor equation, 0.30 for the spouse labor equation, and 0.60 for the
miscellaneous inputs equation. However, 48 percent of coefficients for the
joint estimates are significant at the iO percent level.
The own-price effects for the inputs exhibit the expected negative .signs. The
own-price eifect for hired labor is significant al the 10-perccnt level, while
the own-price effects for operator labor and spouse labor are not significant
in this cross-section. The own price elasticity of demand for hired labor is
highly elastic, with a value of -2.62. In contrast, the own- price elasticities
of demand for operator and spouse labor are highly inelastic, with values of
-0.105 and -0.283. These results, however, are not directly comparable with
cost function studies in the literature that do not include off-farm income-
generating activities as an output.
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Appendix 2 — Incorporating Technology
Adoption in the Farm Household Model
The Theoretical Framework
This model combines in a single framework the technology adoption and
off-farm work decisions by the operator and spouse and follows the analysis
developed by Femandez-Comejo el al. (2005). The mode! expands the farm
household model offered by Huffman (1991) with several additions to allow
for technology adoption. According to the agricultural household model,
farm households maximize utility U subject to income, production tech-
nology, and time constraints. Household memt^rs receive utility' from goods
purchased for consumption G, leisure (including home time) L= (L^, L^} for
the operator and the spouse, and from factors exogenous to current house-
hold decisions, such as human capital H = Hj, and other factors “F
(including household characteristics and weather). Thus:
(1)
Max U= V(G. L, H. F)
Subject to the constraints:
(2)
P^ G = Pfi- X’ + WM’+ A
(income constraint)
(3)
Q = Q[X(n F(r), H. F, Rj, r>o
(technology constraint)
(4)
T = F(rH M + L,M> 0
(time constraint)
where and G denote the price and quantity of goods purchased for
consumption; and Q represent the price and quantity of farm output;
and X are the price and quantity (row) vectors of farm inputs; W -
represents off-farm wages paid to the operator and spouse; M - (M^, is
the amount of time working off-farm by the operator and spouse; F = (F^,
Fp is the amount of time working on the farm by the operator and spouse; A
is other income, including income (from interest, dividends, annuities,
private pensions, and rents) and government transfers (such as Social Secu-
rity, retirement, disability, and unemployment); R i.s a vector of exogenous
factors that shift the production function, and T = (F^, T^) denotes the
(annual) time endowments for the operator and spouse. The production
function is concave and has the usual regularity characteristics. Some tech-
nologies offer simplicity and flexibility that translate into reduced manage-
ment lime, freeing lime for other uses. In these cases, the amount of time
working on the farm by the operator and the spouse F (and possibly the use
of other farm inputs X)is a function of F, the adoption intensity (extent of
adoption) of the technology. A technology-constrained measure of (cash)
household income is obtained by substituting (3) into (2) (Huffman, 1991):
(5 ) G = P^ Q[X(r), F(n H,r,Rj~W^ X(r) A
The first order conditions for optimality (Kuhn-Tucker conditions) arc
obtained by maximizing the Lagrangian expression over (G. L) and mini-
mizing it over the Lagrange multipliers where F = fl^y.
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(6) = U(G. L. H. V) + Xf P Q[X(r). FID. H. F, R]~WxX(r}’
+ WM’ +A-P^Gl + il IT-F(r)- M-LI
The off-farm participation and adoption decisions may be obtained from the
following Kuhn-Tucker conditions;
(7) = A (P^ BQ/dX - WJ - 0
(8) d:^'fdF = A Pq dQ/dF -p, ^0
(9) dWr^ A(p i(dQ/dx)(dx/dry+(dQ/dF)(dF/dry+dQ/dr]-
(dX/dP) 7 - p (dF/dP) ’<0.
p> 0, p ~ddy0p= 0
(10) dWM = XW- p<0, M> a MfAW- p)^0
(Ua, b) A = 0, ^0
(12) P,jQ[X(P), F(P),H, P. R]-W^X(ry+WM^+A-F^G:^0
(13) T F{P) - M ■ L = 0
where U^, Uq are the partial derivatives of the function V. Without loss of
generality, both the operator and spouse are assumed to have positive
optimal hours of leisure and farm work, i.e., equation (8) and (I Jb) are
equalities.
The off-farm participation decision conditions for the operator and the
spouse may be obtained from the optimality conditions for off-fann work,
equation (10), together with equations (8) and (1 lb);
(14) V^^pIX^V^dQldF
where pIX is equal to the marginal rate of substitution between leisure and
consumption goods (from equations 1 la and 1 lb) and dQ/dF repre-
sents the value of the marginal product of farm labor for the operator and
the spouse. Examining the components of (14), W. < p. /A (strict
inequality) indicates that the total time endowment for the operator (/ = o)
or spouse (/ = s) is allocated between farm work and leisure; optimal hours
of off-farm work are zero (comer solution), i.e., M,* = 0. On the other
hand, if = p- /A, optimal hours of off-farm work may be positive (A/, * >
0) and Wj ~ pjX “ P^ dQ/dPj (interior solution) (Lass el al., 1989;
Huffman, 1991; Kimhi, 1994; Huffman and El-Osta, 1997). In this case,
the value of the marginal product of farm labor is equal to the off-fami
wage rate.^"^
When an interior solution for M occurs, equations (7) and (8) can be solved
together, independently of the rest of the Kuhn-Tucker conditions, to obtain
the demand functions for onfarm labor, i.e., the optimal production and
consumption decisions can be separated since the off-farm wage determines
the value of the operator’s and spouse’s time (W = piX ) (Huffman and
Lange, 1989; Huffman, 1991).^^
-^The marginal value of time of the
farm operator (or spouse) when all
his/her time is allocated to farm work
i^nd leisure and none is allocated to
off-farm work dQ/dF,\f_fj^^^)
represents the shadow value of farm
labor and is called the reservation
wage for off-farm work for the opera-
tor {/ = o) or spouse (/ = s). In this
context, the operator (or spouse) will
work off-farm when his/her reservation
wage is less than the anticipated off-
fann wage rate and will not work off-
farm otherwise. Assuming that both
the operator and spouse face wages
that are dependent on their marketable
human capital characteristics , local
labor market conditions, and job char-
acteristics fi, but not on the amount of
olTfarm work (Huffman and Lange,
1989: Huffman, 1991: Tokle and
Huffman. 1991), the off-farm market
labor demand functions arc fo = W.
(li. n ). a = a ij.
-^Moreover, when an interior solu-
tion occurs, from ( i 0), ( 11 a), and
(I lb) we obtain U,/Uq that is.
the marginal rate of substitution
between consumption gocxls and leisure
is equal to the ratio of the wage rate and
the price of consumption grxKis.
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The demand function for onfarm tabor is then F*=F(W, H, F, R)
and the demand for purchased farm inputs X* = X(W, H, F, R).
These optimal input demand functions are substituted in ^e production
function to obtain the supply of fami output Q* - S(W, , P^ H, F, R)
and the maximum net household income may be expressed as:
l\5) NF = S(W, , P^, H,FR}-W^X^’+ WM* + A
Solving jointly equations (10), (1 1), and (15) we obtain the demand for
leisure L* = L(W, P^, NI*. //, *P, T) and for consumption goods G = G(W.
NI*, H, *P, F. T). The supply function for off-farm time is obtained by
substitution of the optimal levels of leisure hours and farm work hours
(Huffman, 1991):
(16) ^ M(W, P^. Pg, NF, H.'PX, aR,T)
Finally, a reduced-form expression of total household income is obtained by:
( 1 7) NF = NI(W^, P^ , P,^ , A, H, W, F, R. T)
As Huffman (1991) notes, when optimal hours of off-farm work hours for
the operator or the spouse are zero, the decision process is not recursive and
production and consumption decisions must be made jointly. In this case,
the arguments for the reduced-form expression of household income are the
same as those in ( 1 7) but exclude the exogenous variables related to the job
characteristics and labor marketability.
The technology adoption decision condition is obtained from the optimality
conditions, equation (9) and equations (8) and (1 lb), noting that the expres-
sion in brackets in (9) is the total derivative dQ/dF. Thus, we obtain:
(18) Pq dQ/dF - (dX/dF ) ' - (^fXHdF/dF) ‘ < 0
But from (11a) and (11b) R,/X =
(19) P^ dQ/F - (dX/dVr- P^ (Vi/Vq )(dF/dFy<0
The left-hand-side of this expression may be interpreted as the marginal benefit
of adoption P^ dQ/dFwAms the marginal cost of adoption, which includes the
mat^inal cost of the production inputs (dX/dF)' and the marginal cost of
the farm work P^ (Uj/Uf'-JidF/dFy (of the operator and the spouse) brought
about by adoption (could be negative if adoption saves managerial lime),
valued at the marginal rate of substitution between leisure and consumption
gcx)ds (which, when off-farm work houre are positive, equals the off-farm wage
rate). It will not be optimal to adopt if the inequality is strict (comer solution),
wherein the marginal benefit of adoption falls short of Uie marginal cost of
adoption. An interior solution for the optimal extent of adoption will occur
when the equality is strict or when the value of the marginal benefit of adop-
tion is equal to the marginal cost of adoption.
Given the cross-sectional nature of the data, one can use the implicit func-
tion theorem to derive expressions for off-farm labor supply for farm oper-
ator and spouse and technology adoption (which affects off-farm labor
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supply of farm operators and spouses) that are functions of wages, prices,
human capital, nonlabor income, and other exogenous factors. TTiese
factors are replaced in reduced-fonn representations of labor supply and
adoption by observable farm, operator, and household characteristics,
including human capital. The “ambient variables” (family size, access to
urban areas), which might affect the productive capacity of the farm oper-
ator and the spouse, are also included. The following section outlines the
empirical model and estimation method used to conduct the analysis.
Empirical Model
A two-stage econometric model is specified. The first stage, the decision
model, examines the off-farm work participation and the technology adop-
tion decisions. The second stage is used to estimate the impact of adoption
on household income.
A simplified “reduced fonn” approach is followed (Goodwin and Holt,
2002; Goodwin and Mishra, 2004) to specify the empirical model, rather
than explicitly estimating a structural model of labor supply. In this
approach, the reduced form of the decision model is obtained by specifying
the endogenous variables (M, F, Q,^, X) in terms of the exogenous variables,
including W^, P^. P^, H, V. ^i, Cl R, T. Equation (14). impUed by the
Kuhn-Tucker conditions, is central to the off-farm work decision of the
operator and the spouse and equation (19) is central to the adoption deci-
sion. Thus, considering a rirst-order approximation (linear terms) and
adding the stochastic terms, the empirical representation of the decision
model, which includes the off-farm participation of the operator (20a) and
spouse (20b), and the technology adoption decision (20c), is:
(20a) A,Z„'+e„^0
(20b) +
(20c) ftZ„- + £„<0
where the (row) vectors Z^, Z^, and Z^ include all the factors or attributes influ-
encing linearly the off-fann participation (operator and spouse) and adoption
decisions, and and are vectors of parameters. Assuming that the
stochastic disturbances are normally distributed, each of these equations may
be estimated by probii. However, because the disturbances (g^, , g^^) are
likely to be correlated, univariate probit equations are not appropriate.
Bivariate probit models have been used to mode! the off-f<uTn employment
decisions by the operator and spouse (Huffman and Lange, 1 989; Lass et al.,
1989; Tokle and Huffman, 1991). Since the decisions to work off fann and the
technology adoption decision may be related, all three decisions are modeled
together in a multivariate probit model (Greene, 1997). Formally, fg^ , g^, ej ~
trivariate nonnal (TVN) [0,0,0; 1,1, 1; pi2.pi3.p23], witli variances (/ =y)
equal to 1 and correlations p-j {i j) where i,j ~ /,2,3.
The joint estimation of three or more probit equations was computationally
unfeasible until recently because of the difficulty in evaluating high-order
multivariate normal integrals. Over the past decade, however, the e,stimation
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has been made possible with Monte Carlo simulation techniques (Geweke et
al., 1994; Greene, 1997).
The vector Z. includes (i) farm factors, such as farm size and complexity of
the operations; (ii) human capital (operator ag^experience and education);
(iii) household characteristics (such as the number of children); (iv) off-farrn
employment opportunities, which will depend on the farms’ accessibility to
urban areas and the change in the rate of unemployment in nearby urban
areas; (v) farm typology; and (vi) government payments.^^ The factors or
attributes influencing adoption, included in the vector are farm factors,
human capital, farm typology, a proxy for risk (risk-averee farmers are less
likely to adopt agricultural innovations), and crop/seed prices.
The second stage, the income impact model, provides estimates of the
impact of adoption on household income after controlling for other factors.
The empirical representation of this model — based on equation (17), the
reduced-form expression of household income — is M* = NJ(W^ P . A,
H, ‘F, r, R, T).
After linearizing this reduced form, separating out explicitly the adoption
indicator variable, and appending a random disturbance assumed to be
normally distributed, we have:
(21) Nl^ = eV' + aI + e
where NI* represents household income; V is a (row) vector of observable
explanatory variables that may influence household income (other than tech-
nology adoption) such as prices, human capital, and “ambient variables”
(family size, access to urban areas) that may affect the productive capacity
of the farm operator and the spouse: / is an indicator variable for adoption
(/=/ if adoption takes place and I-O otherwise); and dand a are appropri-
ately dimensioned parameters. The impact of adoption on household
income is measured by the estimate of the parameter a. However, as noted
by Stefanides and Tauer (1999), if a is to measure the impact of adoption on
income of a representative farm, farmers should be randomly assigned
among adopter and nonadopler categories. This is not the case, since
farmers make the adoption choices themselves. Therefore, adopters and
nonadopters may be systematically different and these differences may
manifest themselves in farm performance and could be confounded with
differences due purely to adoption. This situation, called self-selection, may
bias the statistical results unless corrected (Femandez-Comejo et al. 2002).
To correct for self-selection bias, we follow Maddala (1983) and Greene
(1995) and obtain consistent estimates of the parameters 0and a by
regarding self-selection and simultaneity (discussed earlier) as sources of
endogenity. Because the dummy variable / cannot be treated as exogenous,
instrumental variable techniques are used to purge the dependence of /. The
predicted probability of adoption, obtained from the decision model, is used
as an instmment for / in equation (21).
Unlike the traditional selectivity model, in which the effects are calculated
(separately) using the subsamples of adopters and nonadopters, the impact
model uses all the observations and is known as a “treatment effects model,”
"^Following Goodwin and Hoit
(2002), some prices are not included
in our empirical models since prices
are approximately constant across
households when data consist of cross-
.sectional observations taken at a point
in time. We did include some prices,
like the price of .soybeans, but its coef-
llcicnl was stati.stically insignificant.
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used by Barnow ct al. (1981). The treatment effects model consists of the
regression Y = a I ■¥ £ where the observed indicator variable I (I ~ }
if t > 0 and f =0 if T < 0), indicates the presence or absence of some
treatment (adoption of herbicide-tolerant crops in ibis case) and the unob-
served or latent variable /* is given by t = 5 Zj + V'(Greene, 1995).
Total household income (N!*), as represented in (17), has two components:
household income from farming (FARMHHf) and off-farm household
income (TOTOF!). Household income from farming includes farm business
household income, operator's paid farm income, household members' paid
farm income, etc. (see detailed definitions in appendix table 1). Off-farm
household income includes off-farm business income, income from oper-
ating other farm businesses, off-farm wages and salaries, etc.
The components of vector V include farm location and typology, operator
age, education and experience, number of children, price of soybeans, a
measure of specialization on soybean production, a measure of the extent of
livestock operations, farm size, and proxies for local labor market conditions.
The data are obtained from the nationwide Agricultural Resource Manage-
ment Survey (ARMS) developed by USDA (USDA, ERS, 2003). The
ARMS suiwey is designed to link data on the resources used in agricultural
production to data on use of technologies, other management techniques,
chemical use, yields, and farm financial/economic conditions for selected
field crops. The ARMS is a multiframe, probability-based survey in which
sample farms are randomly selected from groups of farms stratified by
attributes such as economic size, type of production, and land use.
The 2000 data set (u.sed for the HT soybean and Bt com case study) includes
17 soybean (com) producing States: Arkansas, Illinois, Indiana, Iowa,
Kansas, Kentucky, Louisiana, Mississippi, Michigan, Minnesota, Missouri,
Nebraska, North Carolina, Ohio, South Dakota, Tennessee, and Wisconsin.
After selecting those farms tliat planted soybeans (com) in 2000 and elimi-
nating those observations with missing data, there were 2.258 observ'ations
available for the soybean analysis and 2513 observations for com.
The 2001 com data set (used for the yield monitor and conservation tillage
case studies) includes observations of 17 corn-producing States. After elimi-
nating observations with missing data, there were 1,763 observations avail-
able for analysis.
Because of the complexity of the sur\^ey design, a weighted least-squares tech-
nique is used to estimate the parameters using full-.sample weights developed
by the USDA’s National Agricultural Statistics Service. Standard errors are
estimated using a delete-a-group jackknife method (KoU, 1998; Kotl and
Stukel, 1997) where a group of observations is deleted in each replication. Tlie
sample is partitioned into r groups of observations (r = 15) and resampled, thus
fonning 15 replicates and deleting one group of observations in each replicate.
Appendix table 2 shows the parameter estimates a (equation 2 1 ) along with
standard errors. These parameters may be interpreted as the derivatives of
household income with respect to the probability of adoption and are used
to obtain the elasticities shown in table 7.
45
Off-Fann Income, Technology Adoplion, and Fann Economic Performance/ERRS6
Economic Research Service/l'SD.^
312
Appendix table 1
Household (HH) income variable definitions
1. Household income from farming (FARMHH!) = Farm Business Income HH Share
+ Operator Paid on Farm
+ Household Members Paid on Farm
+ Net Income from Rented Land
Where;
Farm Business Income HH Share = Net Cash Farm Business Income
- Depreciation
- Gross income from Rented Land
- Operator Paid Onfarm
- income Due to Other Households
Net Cash Farm Income = Gross Cash Farm Income - Cash Operating Expenses
Gross Cash Farm income = Crop and livestock income including CC loans + Other farm income (includes government
payments, income from custom work and machine hire, income from livestock grazing, other farm-related income, income from
farm iand rented to others, fee income from crops removed under production contract, fee income from livestock removed under
production contract).
Total Cash Operating Expenses (hired labor, contract labor, seed, fertilizer, chemicals, fuel, supplies, tractor and other
equipment teasing, repairs, custom work, general business, real estate and property taxes, insurance, interest, purchased feed,
purchased livestock).
2. Off-Farm Household Income (TOTOFI) = Off-farm business income
+ Income from operating other farm businesses
-»• Off-farm wages and salaries
+ Interest and dividend income
+ Other off-farm income
+ Rental income
3. Total Household Income (TOTHHI) = Household Income from Farming (FARMHH!)
+ Off-Farm Household Income (TOTOFI)
Appendix table 2
Parameter estimates of probability of adoption term of the household income equation for
technologies of varying managerial intensity
Yield monitors
Bt com
Conservation
tillage
Herbicide-tolerant
soybean
Estimate std. err. t-vaiue
Estimate std, err. t-value
Estimate std, err. l-value
Estimate std. err. t-value
Onfarm household annual income
Off-farm household annual income
Total household annual income
25,1 63.8 (0.39)
-124.9 35.3 (-3.54)
-100.8 68.7 (-1.47)
-13.9 10.9 (-1.29)
-36.7 36.2 (-1.07)
-50.6 36.5 (-1.39)
6.4 49.5 (0.13)
87.3 30.3 (2.88)
93,9 51.3 (1.83)
-30.4 29.8 (-1.02)
133.4 67.0 (1.99)
104.1 59.0 (1.76)
Note. Standard errors calculated using the delete-a-group jad<knife method.
46
Off-Farm Income. Technology Adoptiort, and Farm Economic Petffortnance/ERR-56
Economic Research Scrvice/USDA
313
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THE NATIONAL ACADEMIES
Advisers to the ftaiion on Science, Engineering, and Medicine
The National Academy of Sciences is a private, nonprofit, self-perpetuating society of
distinguished scholars engaged in scientific and engineering research, dedicated to the
furtherance of science and technology and to their use for the general welfare. Upon the authority
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to advise the federal government on scientific and technical matters. Dr. Ralph J. Cicerone is
president of the National Academy of Sciences.
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Academy of Sciences the responsibility for advising the federal government. The National
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encourages education and research, and recognizes the superior achievements of engineers. Dr.
Charles M. Vest is president of the National Academy of Engineering.
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COMMITTEE ON THE IMPACT OF BIOTECHNOLOGY ON FARM-LEVEL
ECONOMICS AND SUSTAINABILITY
DAVID E. ERVIN {Chair), Portland State University, Oregon
YVES CARRIERE, University of Arizona, Tucson
WILLIAM J. COX, Cornel! University, Ithaca, New York
JORGE FERNANDEZ-CORNEJO, Economic Research Service, U.S. Department of
Agriculture, Washington, DC’
RAYMOND A. JUSSAUME, Washington State University, Pullman
MICHELE C. MARRA, North Carolina State University, Raleigh
MICHEAL D. K. OWEN, Iowa State University, Ames
PETER H. RAVEN, Missouri Botanical Garden, St. Louts, Missouri
L. LAREESA WOLFENBARGER, University of Nebraska, Omaha
DAVID ZILBERMAN, University of California, Berkeley
Project Staff
KARA N. LANEY, Study Director
KAMWETI MUTU, Research Associate
ROBIN A. SCHOEN, Director, Board on Agriculture and Natural Resources
KAREN L. IMHOF, Administrative Assistant
NORMAN GROSSBLATT, Senior Editor
'The views expressed here are those of the others and may not be attributed to the Economic Research
Service or the U.S. Department of Agriculture.
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BOARD ON AGRICULTURE AND NATURAL RESOURCES
NORMAN R. SCOTT {Chair), Cornell Univereity, Ithaca, New York
PEGGY F. BARLETT, Emory University, Atlanta, Georgia
HAROLD L. BERGMANN, Univet^ity of Wyoming, Laramie
RICHARD A. DIXON, Samuel Roberts Noble Foundation, Ardmore, Oklahoma
DANIEL M, DOOLEY, University of California, Oakland
JOAN H. EISEMANN, North Carolina State University, Raleigh
GARY F. HARTNELL, Monsanto Company, St. Louts, Missouri
GENE HUGOSON, Minnesota Department of Agriculture, St. Paul
KIRK C. KLASING, University of California, Davis
VICTOR L. LECHTENBERG, Purdue University, West Lafayette, Indiana
PHILIP E. NELSON, Purdue University, West Lafayette, Indiana
KEITH PITTS, Marrone Bio Innovations, Davis, California
CHARLES W. RICE, Kansas State University, Manhattan
HAL SALWASSER, Oregon State University, Corvallis
PEDRO A. SANCHEZ, The Earth Institute, Columbia University, Palisades, New York
ROGER A. SEDJO, Resources for the Future, Washington, DC
KATHLEEN SEGERSON, University of Connecticut, Storrs
MERCEDES VAZQUEZ-ANON, Novus International, Inc., St. Charles. Missouri
staff
ROBIN A. SCHOEN, Director
KAREN L. IMHOF, Administrative Assistant
AUSTIN J. LEWIS, Senior Program Officer
EVONNE P.Y. TANG, Senior Program Officer
PEGGY TSAI, Program Officer
CAMILLA YANDOC ABLES, Associate Program Officer
KARA N. LANEY, Associate Program Officer
RUTH S. ARIETI, Research Associate
JANET M. MULLIGAN, Research Associate
KAMWETI MUTU, Research Associate
ERIN P. MULCAHY, Senior Program Assistant
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Preface
Not since the introduction of hybrid corn seed have we witnessed such a sweeping
technological change in U.S. agriculture. Hundreds of thousands of farmers have adopted the
first generation of genetically engineered (GE) crops since their commercialization in 1996.
Although not all GE varieties that have been commercialized have succeeded, those targeted at
improved pest control now cover over 80 percent of the acres planted to soybean, cotton, and
com — that is, almost half of U.S. cropland. Forecasts suggest an expansion in GE-crop plantings
in many other countries.
GE crops originate in advances in molecular and cellular biology that enable scientists to
introduce desirable traits from other species Into crop plants or to alter crop plants’ genomes
internally. Those powerful scientific techniques have dramatically expanded the boundaries that
have constrained traditional plant-breeding. A new technology adopted so widely and rapidly has
substantial economic, social, and environmental impacts on farms and their operators. Inevitably,
both advantages and risks or losses emerge from such massive changes. The National Research
Council has conducted multiple studies of specific aspects of GE crops, such as regulatory-
system adequacy and food safety. However, the assigned tasks re.stricted the scope of their
reports. As pressure mounts to expand the use of GE crops for energy, food security,
environmental improvement, and other purposes, the scope and intensity of impacts will grow.
Now is an opportune time to take a comprehensive look at the track record of GE crops and to
identify the opportunities and challenges looming on the horizon. The National Research Council
therefore supported the Committee on the Impact of Biotechnology on Farm-Level Economics
and Sustainability to investigate this topic.
Despite the rapid spread of GE crops in U.S. agriculture, the technology continues to stir
controversy around scientific issues and ideological viewpoints. The committee focused on the
scientific questions associated with the farm-level impacts of the adoption of genetic-engineering
technology and refrained from analyzing ideological positions, either pro or con. The committee
adopted an “evidentiary” standard of using peer-reviewed literature on which to form our
conclusions and recommendations. It is my hope that the report will give readers a firm grasp of
the state of evidence or lack thereof on the scientific issues.
True to its charge, the committee adopted a sustainability framework that required an
evaluation of environmental, economic, and social impacts of GE crops. Those three dimensions
constitute the essential pillars of sustainability science. The summary and opening and closing
chapters bring together the three perspectives for a fuller view of the technology’s impact.
Given the controversies, readers will want to know the committee’s composition and how it
conducted its work in arriving at conclusions and recommendations. The biographies in
Appendix C show a group of highly accomplished natural and social scientists who possess a
broad array of research experience and perspectives on GE crops. That diversity of disciplines
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and expertise proved beneficial in introducing checks and balances in evaluating information
from many angles. The committee members divided into teams to work on the various sections
of the report on the basis of the members’ expertise. The drafts by each team were reviewed by
the full committee to ensure that everyone had a chance to comment on and improve and approve
each section. I was continually impressed with the members’ dedication to a hard-nosed and
impartial evaluation of the best science on GE crops. Equally important, they kept open minds in
considering new evidence presented by their colleagues and external experts. The result was a
model multidisciplinary research process in which each of us learned from the others and
improved the report quality.
In closing, 1 want to express my deep appreciation to the committee members for their
tireless work and good humor in completing such a challenging task while working full-time at
their regular jobs. Their commitment and professionalism exemplify the best of public science.
Each member made significant contributions to the final report. The committee also benefited
from the testimony of several experts in the field and from the numerous comments of many
conscientious external reviewei^. Finally, the quality of the report would not have been attained
without excellent support and substantive input by study director Kara Laney, the valuable
assistance of Kamweti Mutu, the insightful counsel of Robin Schoen, and the editorial work of
the National Research Council.
David E. Ervin, Chair
Committee on the Impact of
Biotechnology on Farm-Level
Economics and Sustainability
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Acknowledgments
This report has been reviewed in draft form by persons chosen for their diverse perspectives
and technical expertise in accordance with procedures approved by the National Research
Council Report Review Committee. The purpose of the independent review is to provide candid
and critical comments that will assist the institution in making its published report as sound as
possible and to ensure that the report meets institutional standards of objectivity, evidence, and
responsiveness to the study charge. The review comments and draft manuscript remain
confidenlial to protect the integrity of the deliberative process. We wish to thank the following
individuals for their review of the report:
David A. Andow, University of Minnesota, St. Paul
Charles M. Benbrook, The Organic Center, Enterprise, Oregon
Lawrence Busch, Michigan State University, East Lansing
Stephen O. Duke, Agricultural Research Service, U.S. Department of Agriculture,
University, Mississippi
Robert T. Fraley, Monsanto Company, St. Louis, Missouri
Dermot J. Hayes, Iowa State University, Ames
Molly Jahn, Research, Education and Economics, U.S. Department of Agriculture,
Washington, DC
Nicholas Kalaitzandonakes, University of Missouri, Columbia
Peter M. Kareiva, The Nature Conservancy, Seattle, Washington
Michelle A. Marvier. Santa Clara University, California
Paul D. Mitchell, University of Wisconsin, Madison
George E. Seidel, Colorado State University, Fort Collins
Greg Traxler, The Bill & Melinda Gates Foundation, Seattle, Washington
Although the reviewere listed above have provided many constructive comments and
suggestions, they were not asked to endorse the conclusions or recommendations, nor did they
see the final draft of the report before its release. The review of the report was overseen by Drs.
Alan G. McHughen, University of California, Riverside, and May R. Berenbaum, University of
Illinois. Appointed by the National Research Council, they were responsible for making certain
that an independent examination of the report was carried out in accordance with institutional
procedures and that all review comments were carefully considered. Responsibility for the final
content of the report rests with the authoring committee and the institution.
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Contents
ABBREVIATIONS AND ACRONYMS xv
SUMMARY S-I
I INTRODUCTION 1-1
Committee Charge and Approach, 1-2
Study Framework, 1-4
Genetically Engineered Traits in Crops, 1-9
Adoption and Distribution of Genetically Engineered Crops, 1-1 1
Deterrents to Genetically Engineered Trait Development in Other Crops, 1-27
From Adoption to Impact, 1-30
Conclusion, 1-31
References, 1-31
2 ENVIRONMENTAL IMPACTS OF GENETICALLY ENGINEERED CROPS AT
THE FARM LEVEL 2-1
Environmental Impacts of Herbicide-Resistant Crops, 2-2
Environmental Impacts of Insect-Resistant Crops, 2-21
Gene Flow and Genetically Engineered Crops, 2-38
Conclusions, 2-43
References, 2-45
3 FARM-LEVEL ECONOMIC IMPACTS 3-1
Economic Impacts on Adopters of Genetically Engineered Crops, 3-1
Economic Impacts on Other Producers, 3-26
Socioeconomic Impacts of Gene Flow, 3-30
Conclusions, 3-34
References, 3-35
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4 FARM-SYSTEM DYNAMICS AND SOCIAL IMPACTS OF GENETIC
ENGINEERING 4-1
Social Impacts of On-Farm Technology Adoption, 4-1
Social Networks and Adoption Decisions, 4-4
Interaction of the Structure of the Seed Industry and Farmer Decisions, 4-5
Social and Information Networics Between Farmers and Industry, 4-10
Interaction of Legal and Social Issues Surrounding Genetic Engineering, 4-13
Conclusions, 4-16
References, 4-17
5 KEY FINDINGS, REMAINING CHALLENGES, AND FUTURE
OPPORTUNITIES 5-1
Key Findings, 5-1
Remaining Challenges Facing Genetically Engineered Crops, 5-3
Future Applications of Genetically Engineered Crops, 5-5
Research Priorities Related to Genetically Engineered Crops , 5-12
Advancing Potential Benefits of Genetically Engineered Crops by Strengthening
Cooperation Between Public and Private Research and Development, 5-13
References, 5-16
6 APPENDIXES
A Herbicide Selection
B Tillage Systems
C Biographical Sketches of Committee Members
A- 1
B-1
C-1
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List of Tables, Figures, and Boxes
TABLES
1-1 Genetically Engineered Soybean Varieties, by State and United States, 2000-2009,
1- 15
1-2 Insect Pests of Com Targeted by Bt Varieties, 1-17
1-3 Genetically Engineered Com Varieties, by State and United States, 2000-2009, 1-18
1 -4 Insect Pests of Cotton Targeted by Bt Varieties, 1 -22
1-5 Genetically Engineered Upland Cotton Varieties, by State and United States, 2000-
2009, 1-23
1- 6 National Soybean Survey Descriptive Statistics by Adoption Category, 1-27
2- 1 Weeds Thai Evolved Resistance to Glyphosate in Glyphosate-Resistant Crops in the
United States, 2- 1 4
2-2 Weeds Reported to Have Increased in Abundance in Glyphosate-Resistant Crops,
2- 16
2- 3 Regional Effects of Deployment of Bt Crops on Population Dynamics of Major Pests
of Corn and Cotton, 2-26
3- 1 Summary of Farm-Level Impact Evidence for Genetically Engineered Cotton in the
United States, 1996-1999, 3-15
3-2 Fuel Consumption by Tillage System, 3-17
3-3 Value and Relative Importance of Nonpecuniary Benefits to Farmers, 3- 1 9
3-4 Effect of Global Adoption of Genetically Engineered Crops on Commodity Prices,
3-23
3- 5 Adoption of Genetically Engineered Crops and Their Distribution, 3-25
4- 1 Estimated Seed Sales and Shares for Major Field Crops, United States, 1997, 4-7
4-2 Four-Firm Concentration Ratio in Field-Release Approvals from USDA Animal and
Plant Health inspection Service, by Crop, 1990-2000, 4-8
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FIGURES
S- 1 Application of herbicide to soybean and percentage of acres of HR soybean, S-4
S-2 Application of herbicide to cotton and percentage of acres of HR cotton, S-5
S-3 Application of herbicide to com and percentage of HR com, S-6
S-4 Pounds of insecticide applied per planted acre and percent acres of Bt com,
respectively, S-8
S-5 Pounds of insecticide applied per planted acre and percent acres of Bt cotton,
respectively, S-9
I-l Genetically engineered crop adoption and impact framework, 1-8
1-2 Share of major crops in total pesticide expenditures, 1998-2007, 1-10
1-3 Nationwide acreage of genetically engineered soybean, com, and cotton as a fraction
of all acreage of these crops, 1-12
1 -4 Herbicide-resistant soybean acreage trends nationwide, 1-1 6
1-5 Genetically engineered com acreage trends nationwide, 1-2!
1- 6 Genetically engineered cotton acreage trends nationwide, 1-25
2- 1 Application of herbicide to soybean and percentage of acres of herbicide-resistant
soybean, 2-4
2-2 Application of herbicide to cotton and percentage of acres of herbicide-resistant
cotton, 2-5
2-3 Application of herbicide to com and percentage of herbicide-resistant corn, 2-6
2-4 Trends in conservation tillage practices and no till for soybean, com and cotton, and
adoption of herbicide-resistant crops since their introduction time in 1996, 2-8
2-5 Soybean acreage under conservation tillage and no-tili, 1997, 2-9
2-6 Number of weeds with evolved glyphosate resistance, 2-18
2-7 Pounds of insecticide applied per planted acre and percent acres of Bt com, 2-23
2-8 Pounds of insecticide applied per planted acre and percent acres of Bt cotton, 2-24
2- 9 Cumulative number of cotton pests evolving resistance to Bt cotton and DDT in the
years after these management tools became widely used in the United States, 2-34
3- 1 Seed price index and overall index of prices paid by United States farmers, 3-10
3-2 Estimated average seed costs for United States farmer in real (inflation-adjusted)
terms, 3-10
3-3 Real (inflation-adjusted) cotton seed prices paid by United States farmers,
2001-2007, 3-U
3-4 Real (inflation-adjusted) corn seed prices paid by United States farmers, 2001-2008,
3-12
3-5 Real soybean seed price paid by United States farmers, 2001-2008,
3-6 United States com use, 3-27
3-7 United States soybean use, 3-28
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4- ! Public and private research expenditures on plant breeding, 4-6
4-2 Share of planted acres of com and soybean seeds by largest four flmis (CR4), 4-8
4- 3 Evolution of Pioneer Hi-Bred International Inc. / E.I. DuPont de Nemours and
Company, 4-9
5- 1 Number of permits for rele^e of genetically-engineered varieties approved by
APHIS, 5-8
5-2 Approved field releases of plant varieties for testing purposes by trait (percent), 5-8
BOXES
S- 1 Statement of Task, S-2
1 - 1 Statement of Task Summary, I -3
1- 2 Other Commercialized Genetically Engineered Crops, 1-13
2- 1 Limitations to Evaluating the Magnitude of Environmental Effects, 2-2
3- 1 Measuring Impacts, 3-2
5-1 New Traits Reduce Refuge Requirement and Introduce Second Mode of Herbicide
Resistance, 5-6
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Abbreviations and Acronyms
ACC
ALS
AMPA
APHIS
I -aminocycioprpane- 1 -carboxylic acid
acetolactate synthase
aminomethyiphosphonic acid
Animal and Plant Health Inspection Service (U.S. Department of Agriculture)
BST
Bt
bovine somatotropin
Bacillus thuringiensis
Cry
Crystal-like (protein)
DNA
deoxyribonucleic acid
EPA
EPSPS
U.S. Environmental Protection Agency.
enzyme 5-enolpyruvyl-shikimatc-3-phosphate synthase
GE
GMO
genetically engineered
genetically modified organism
HPPD
HR
hydroxyphenyl-pyruvate-dioxygenase
herbicide-resistant
lAA
IPM
IPR
IR
ISHRW
indoleacetic acid: a plant hormone (C10H9NO2) that stimulates growth
integrated pest management
intellectual property rights
Insect-resistant
Internationa! Surv'ey of Herbicide Resistant Weeds
MCL
maximum contaminant level
NOP
NOSB
National Organic Program
National Organic Standards Board
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PPO
pro
PVPA
protoporphyrinogen oxidase
U.S. Patent and Trademark Office
Plant Variety Protection Act
R&D
Research and Development
USDA-ERS
USDA-NASS
U.S. Department of Agriculture, Economic Research Service
U.S. Department of Agriculture, National Agricultural Statistics Service
VR
virus-resistant
WHO
World Health Organization
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Summary
With the advent of genetic-engineering technology in agriculture, the science of crop
improvement has evolved into a new realm. Advances in molecular and cellular biology now
allow scientists to introduce desirable traits from other species into crop plants. The ability to
transfer genes between species is a leap beyond crop improvement through previous plant-
breeding techniques, whereby desired trails could be transferred only between related types of
plants. The most commonly introduced genetically engineered (GE) traits allow plants either to
produce their own insecticide, so that the yield lost to insect feeding is reduced, or to resist
herbicides, so that herbicides can be used to kill a broad spectrum of weeds without banning
crops. Those traits have been incorporated into most varieties of soybean, corn, and cotton grown
in the United States.
Since their introduction in 1996, the use of (GE crops in the United States has grown rapidly
and accounted for over 80 percent of soybean, com, and cotton acreage in the United States in
2009. Several National Research Council reports have addressed the effects of GE crops on the
environment and on human health.’ However, the effects of agricultural biotechnology at the
farm level — that is, from the point of view of the farmer — have received much less attention. To
fill that information gap, the National Research Council initiated a study, supported by its own
funds, of how GE crops have affected U.S. farmers — their incomes, agronomic practices,
production decisions, environmental resources, and personal well-being. This report of the
study’s findings expands the perspectives from which genetic-engineering technology has been
examined previously. It provides the first comprehensive assessment of the effects of GE-crop
adoption on farm sustainability in the United States (Box S-1).
' Safety of Genetically Engineered Foods: Approaches to Assessing Unintended Health Effects (2004);
Environmental Effects of Transgenic Plants: The Scope and Adequacy of Regulation (2002); Ecological Monitoring
of Genetically Modified Crops: A Workshop Summary (2001); Genetically Modified Pest-Protected Plants: Science
and Regulation (2000).
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80XS-i
SUitenitmt of Task
An NRC cxHTimittea Wv Study ira|>arfS: of biotechnology, induaing the
economtcs of aSc^ting {len^tcaffy Ganges in producer decision-making
and agronomic practtcestand^fm sustainabihty.
The study vwH. • - ■
• ; revi€»A’ af)dma^^thapubltstiedittef^um;cKa OE crops on the productivity
and economics of tanrtS « tha United States;
• lQrch.vigi i in j^actices and inputs, such as pesticide and
herbicide use and « n i-'i \ sr management regimes,
• evaluate producer daosioii-^ king wHh regard to the adoptiori of GB crops.
its study and identify
ely to affect agricultural
In interpreting its task, the committee chose to analyze the effects of GE crops on farm-level
sustainability in terms of environmental, economic, and social effects. To capture the broad array
of potential effects, the committee interpreted “farm level” as applying to both farmers who do
not produce GE crops and those who do because genetic engineering is a technology of extensive
scope, and its influences on farming practices have affected both types of fanners. Therefore, to
the extent that peer-reviewed literature is available, the report draws conclusions about the
environmental, economic, and social effects, both favorable and unfavorable, associated with the
use of GE crops for all farmers in the United States over the last 14 years. The report
encapsulates what is known about the effects of GE crops on farm sustainability and identifies
where more research is needed. A full sustainability assessment of GE crops remains an ongoing
task because of information gaps on certain environmental, economic, and social impacts.
Genetic-engineering technology continues to stir controversy around scientific issues and
ideological viewpoints. This report addresses just the scientific questions and adopts an
“evidentiary” standard of using peer-reviewed literature to form conclusions and
recommendations. GE-trait developments may or may not turn out to be a cost-effective
approach to addressing challenges confronting agriculture, but review of their impact and an
exploration of what is possible are necessary to evaluate their relative efficacy. Therefore, the
report details the challenges and opportunities for future GE crops and offers recommendations
on how crop-management practices and future research and development efforts can help to
realize the full potential offered by genetic engineering.
KEY FINDINGS
The order of findings in this summary reflects the structure of the report and does not
connote any conclusions on the part of the committee regarding the relative strength or
importance of the findings. In general, the committee finds that genetic-engineering technology
has produced substantial net environmental and economic benefits to U.S. farmers compared
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with non-GE crops in conventional agriculture. However, the benefits have not been universal;
some may decline over time, and the potential benefits and risks associated with die future
development of the technology are Ukely to become more numerous as it is applied to a greater
variety of crops. The social effects of agricultural biotechnology have largely been unexplored,
in part because of an absence of support for research on them.
Environmental Effects
Generally, GE crops have had fewer adverse effects on the environment than non-GE crops
produced conventionally. The use of pesticides with toxicity to nontarget organisms or with
greater persistence in soil and waterways has typically been lower in GE fields than in non-GE,
nonorganic fields. However, farmer practices may be reducing the utility of some GE traits as
pest-management tools and increasing the likelihood of a return to more environmentally
damaging practices.
Finding 1. When adopting GE hcrbicidc-r^istant (HR) crops, farmers mainly substituted
the herbicide glyphosate for more toxic herbicides. However, the predominant reliance on
giyphosate is now reducing the effectiveness of this weed-management tool.
Glyphosate kills most plants without substantial adverse effects on animals or on soil and
water quality, unlike other classes of herbicides. It is also the herbicide to which most HR crops
are resistant. After the commercialization of HR crops, farmers replaced many other herbicides
with glyphosate applications after crops emerged from the soil (Figures S-1, S-2, and S-3).
However, the increased reliance on glyphosate after the widespread adoption of HR crops is
reducing its effectiveness in some situations. Glyphosate-resistant weeds have evolved where
repeated applications of glyphosate have constituted the only weed-management tactic. Nine
weed species in the United States have evolved resistance to glyphosate since the introduction of
HR crops in 1996 compared with seven that have evolved resistance to glyphosate worldwide in
areas not growing GE crops since the herbicide was commercialized in 1974. Furthermore,
communities of weeds less susceptible to glyphosate are becoming established in fields planted
with HR crops, particularly fields that are treated only with glyphosate.
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— — Glyphosate — a — O ther herbicides - - Percent acres HR
FIGURE S-1 Application of herbicide to soybean and percentage of acres of HR soybean.
NOTE: The strong correlation between the rising percentage of hcrbicide-resistant (HR) soybean
acres planted over time, the increased applications of glyphosate, and the decreased use of other
herbicides suggests but does not confirm causation between these variables.
SOURCES: USDA-NASS, 2001 ; 2003, 2005, 2007, 2009a, b; Fernandez-Comejo et al., 2009.
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Year
— ■ — Glyphosate — o — Other herbicides - o- - Percent acres HR
FIGURE S-2 Application of herbicide to cotton and percentage of acres of HR cotton.
NOTE: The strong correlation between the rising percentage of herbicide-resistant (HR) cotton
acres planted over time, the increased applications of glyphosate, and the decreased use of other
herbicides suggests but does not confirm causation between these variables.
SOURCES: USDA-NASS, 200!; 2003, 2005, 2007, 2009a, b; Femandez-Comejo etal., 2009.
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FIGURE S-3 Application of herbicide to com and percentage of HR com.
NOTE: The strong correlation between the rising percentage of herbicide-resistant (HR) com
acres planted over time, the increased applications of glyphosate, and the decreased use of other
herbicides suggests but does not confirm causation between these variables.
SOURCES: USDA-NASS, 2001 ; 2003, 2005, 2007, 2009a, b; Femandez-Cornejo et al., 2009.
Finding 2. The adoption of HR crops complements conservation tillage practices, which
reduce the adverse effects of tillage on soil and water quality.
Farmers have traditionally used tillage to control weeds in their fields, interrupting weed
lifecycles before they can produce seeds for the following year. However, using tillage to help
manage weeds reduces soil quality and increases soil loss from erosion. Tilled soil forms a crust,
which reduces the ability of water to infiltrate the surface and leads to runoff that can pollute
surface water with sediments and chemicals. Conservation tillage, which leaves at least 30
percent of the previous crop’s residue on the field, improves soil quality and water infiltration
and reduces erosion because more organic matter is left on the soil surface, thereby decreasing
disruption of the soil. The adoption of HR crops allows some farmers to substitute glyphosate
application for some tillage operations as a weed-management tactic and thereby benefits soil
quality and probably improves water quality, although definitive research on the latter is lacking.
However, empirical evidence points to a two-way causal relationship between the adoption of
HR crops and conservation tillage. Farmers who use conservation tillage are more likely to adopt
HR crop varieties than those who use conventional tillage, and those who adopt HR crop
varieties are more likely to practice conservation tillage than those who use non-GE seeds.
Finding 3. Targeting specific plant insect pests with Bt corn and cotton has been successful,
and the ability to target specific plant pests in corn and cotton continues to expand.
Insecticide use has decreased with the adoption of insect-resistant (IR) crops. The
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emergence of insect resistance to Bt crops has been low so far and of little economic or
agronomic consequence; two pest species have evolved resistance to Bt crops in the United
States.
Bt toxins, which are produced by the soil-dwelling bacterium Bacillus thuringiemis, are
lethal to the larvae of particular species of moths, butterflies, flies, and beetles and are effective
only when an insect ingests the toxin. Therefore, crops engineered to produce Bt toxins that
target specific pest taxa have had favorable environmental effects when replacing broad-
spectrum insecticides that kill most insects (including beneficial insects, such as honey bees or
natural enemies that prey on other insects), regardless of their status as plant pests. The amounts
of insecticides applied per planted acre of Bt com and cotton have inverse relationships with the
adoption of these crops over time (Figures S-4 and S-5), though a causative relationship has not
been established or refuted because other factors influence pesticide-use patterns.
Since their introduction in 1996, the use of IR crops has increased rapidly, and they continue
to be effective. Data indicate that the abundance of refuges of non-Bt host plants and recessive
inheritance of resistance are two key factors influencing the evolution of resistance. The refuge
strategies mandated by the Environmental Protection Agency, and the promotion of such
strategies by industry, likely contributed to increasing the use of refuges and to delaying the
evolution of resistance to Bt in key pests. Nevertheless, some populations of tw'o generalist pests
have evolved resistance to Bt crops in the United States, although the agronomic and economic
consequences appear to be minor. With the introduction of multiple Bt toxins in new hybrids or
varieties, the probability of resistance to Bt crops is further reduced.
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Year
-0 — Insecticide pounds — O— Percent acreage Bt corn
FIGURE S-4 Pounds of insecticide applied per planted acre and percent acres of Bt corn,
respectively.
NOTE: The strong correlation between the rising percentage of Bt corn acres planted over time
and the decrease in insecticide pounds per planted acre suggests but does not confirm causation
between these variables.
SOURCES: USDA-NASS, 2001 ; 200.3. 2005, 2007, 2009a, b; Fernandez-Comejo et ai., 2009.
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Year
— 0 — Insecticide pounds — O- Percent acreage Bt cotton
FIGURE S-5 Pounds of insecticide applied per planted acre and percent acres of Bt cotton,
respectively.
NOTE: The strong correlation between the rising percentage of Bt cotton acres planted over time
and the decrease in insecticide pounds per planted acre suggests but does not confirm causation
between these variables.
SOURCES: USDA-NASS, 2001 ; 2003, 2005. 2007. 2009a, b; Femandez-Cornejo et al., 2009.
Finding 4. For the three major GE crops, gene flow to wild or w-eedy relatives ha.s not been
a concern to date because compatible relatives of corn and soybean do not exist in the
United States and are only local for cotton. For other GE crops, the situation varies
according to species. How'ever, gene flow to non-GE crops has been a concern for farmers
whose markets depend on an absence of GE traits in their products. The potential risks
presented by gene flow may increase as GE traits are introduced into more crops.
Gene flow betw’een many GE crops and wild or weedy relatives is low^ because GE crops do
not have wild or weedy relatives in the United States or because the spatial overlap between a
crop and its relatives is not extensive. How that relationship changes will depend on what GE
crops are commercialized, whether related species with which they are capable of interbreeding
are present, and the consequences of such interbreeding on weed management. Gene flow of
approved GE traits into non-GE varieties of the same crops (known as adventitious presence)
remains a serious concern for farmers whose market access depends on adhering to strict non-GE
presence standards. Resolving this issue will require the establishment of thresholds for the
presence of GE material in non-GE crops, including organic crops, that do not impose excessive
costs on growers and the marketing system.
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Economic Effects
The rapid adoption of GE crops since their commercialization indicates that the benefits to
adopting farmers are substantial and generally outweigh additional technology fees for these
seeds and other associated costs. The economic benefits and costs associated with GE crops
extend beyond farmers who use the technology and will change with continuing adoption in the
United States and abroad as new products emerge.
Finding 5. Farmers who have adopted GE crops have experienced lower costs of
production and obtained higher yields in many cases because of more cost-effective weed
control and reduced losses from insect pests. Many farmers have benefited economically
from the adoption of Bt crops by using lower amounts of or less expensive insecticide
applications, particularly where insect pest populations were high and difficult to treat
before the advent of Bt crops.
The incomes of those who have adopted genetic-engineering technology have benefited from
some combination of yield protection and lower costs of production. HR crops have not
substantially increased yields, but their use has facilitated more cost-effective weed control,
especially on fanns where weeds resistant to glyphosate have not yet been identified. Lower
yields were sometimes observed when HR crops were introduced, but die herbicide-resistant trait
has since been incorporated into higher-yielding cultivars, and technological improvement in
Inserting the trait has also helped to eliminate the yield difference. In areas that suffer substantial
damage from insects that are susceptible to the Bt toxins, IR crops have increased adopters’ net
incomes because of higher yields and reduced insecticide expenditures. Before the introduction
of Bt crops, most farmers accepted yield losses to European com borer rather than incur the
expense and uncertainty of chemical control. Bt traits to address com rootworm problems have
lowered the use of soil-applied and seed-applied insecticides. In areas of high susceptible insect
populations, Bt cotton has been found to protect yields with fewer applications of topical
insecticides. More etYective management of weeds and insects also means that farmers may not
have to apply insecticides or till for weeds as often, and this translates into cost savings — lower
expenditures for pesticides and less labor and fuel for equipment operations.
Finding 6. Adopters of GE crops experience increased worker safety and greater simplicity
and flexibility in farm management, benefltting farmers even though the cost of GE seed is
higher than non-G£ seed. Newer varieties of GE crops with multiple GE traits appear to
reduce production risk for adopters.
Fanners who purchase GE seed pay a technology fee — a means by which seed developers
recover research and development costs and earn profits. GE seed is typically more expensive
than conventional seed, and ^e net return in terms of higher yields and lower costs of production
for a farmer considering adoption does not always offset the technology fee. However, studies
have found that high rates of adoption of GE crops can be attributed in part to the value that
fanners place on increased worker safety, perceived greater simplicity and flexibility in farm
management (including more off-farm work opportunities), and lower production risk. Farmers
and their employees not only face reduced exposure to the harsh chemicals found in some
herbicides and insecticides used before the introduction of GE crops but have to spend less time
in the field in applying the pesticides. Because glyphosate can be applied over a fairly wide
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timeframe, farmers who use HR crops have greater flexibility regarding when they treat weeds in
their fields. Those benefits must be balanced with the risk that such flexibility in application
timing may reduce crop-yield potential attributable to weed interference. Newer GE varieties that
have multiple pest-control traits may result in more consistent pest management and thus less
yield variability, a characteristic that has substantial value for risk-averse producers. The value of
those benefits may provide additional incentives for adoption that counteract the extra cost of GE
seed.
Finding 7. The effect GE crops have had on prices received by farmers for soybean, corn,
and cotton is not completely understood.
Studies suggest that the adoption of GE crops that confer productivity increases ultimately
puts downward pressure on the market prices of the crops. However, early adopters benefit from
higher yields or lower production costs than nonadopters even with lower prices. The gains tend
to dissipate as the number of adopters increases, holding technological progress constant. Thus,
as the first adopters, U.S. farmers have generally benefited economically from the fact that GE
crops were developed and commercialized in the United States before they were planted by
fanners in other countries. The extent to which GE-crop adoption in developing countries will
influence productivity and prices, and therefore U.S. farm incomes, is not completely
understood. There is a paucity of studies of the economic effects of genetic-engineering
technology in recent years even though adoption has increased globally.
Finding 8. To the extent that economic effects of GE-crop plantings on non-GE producers
are understood, the results are mixed. By and large, these effects have not received
adequate research.
Decisions made by adopters of GE crops can affect the input prices and options for both
farmers who use feed and food products made with GE ingredients and farmers who have chosen
not to grow GE seed or do not have the option available. The latter effects on those not using
genetic-engineering technology have not been studied extensively. Livestock producers
constitute a large percentage of com and soybean buyers and therefore are major beneficiaries of
any downward pressure on crop price due to the adoption of GE crops. Feed costs are nearly half
the variable costs for livestock producers, so even moderate price fluctuations can affect their net
incomes substantially. Livestock producers also benefit from increased feed safety due to
reduced levels of mycotoxins in the grain. However, no quantitative estimation of savings to
livestock operators due to the adoption of GE crops and the resulting effect on the profitability of
livestock operations has been conducted. Similarly, a number of other economic effects predicted
by economic theoiy have not been documented.
Favorable and unfavorable externalities are not limited to the cost and availability of inputs.
To the extent that genetic-engineering technology successfully reduces pest pressure on a field
and regionally, farmers of fields in the agricultural landscape planted with non-GE crops may
benefit via lower pest-contro! costs associated with reductions in pest populations. However,
nonadopters of genetic-engineering technology also could suffer from the development of weeds
and insects that have acquired pesticide resistance in fields within the region planted to GE
crops. When that happens, farmers might have to resort to managing the resistant pests with
additional, potentially more toxic or more expensive forms of control, even though their
practices may not have led to the evolution of resistance.
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Inadvertent gene flow from GE to non-GE varieties of crops can increase production costs.
Gene flow occurs through cross-pollination between GE and non-GE plants from different fields,
co-mingling of GE seed with non-GE seed, and germination of seeds left behind (volunteers)
after the production year. Similarly, if GE traits cross into weedy relatives, weed-control
expenses will be higher for all fields on to which the weeds spread, whether a farmer grows GE
crops or not. In addition, gene flow of GE traits into organic crops could jeopardize crop value
by rendering outputs unsuitable for high-value foreign or other markets that limit or do not
permit GE material in food products; the extent of that effect has not been documented during
the last 5 years. On the other hand, the segregation of GE traits from organic production may
have benefited organic producers by creating a market in which they can receive a premium for
non-GE products.
Social Effects
The use of GE crops, like the adoption of other technologies at the farm level, is a dynamic
process that both affects and is affected by the social networks that farmers have with each other,
with other actors in the commodity chain, and with the broader community in which farm
households reside. However, the social effects of GE-crop adoption have been largely
overlooked.
Finding 9. Research on the dissemination of earlier technological development in
agriculture suggests that favorable and unfavorable social impacts exist from the
dissemination of genetic-engineering technology. However, these impacts have not been
identified or analyzed.
Because GE crops have been widely adopted rapidly, it is reasonable to hypothesize that
there have been social effects on adopters, nonadopters, and farmers who use GE products, such
as livestock producers. For example, based on earlier research on the introduction of new
technologies in agriculture, it is possible that certain categories of farmers (such as those with
less access to credit, those with fewer social connections to university and private-sector
researchers, or those who grow crops for smaller markets) might be less able to access or benefit
from GE crops. The introduction of genetic-engineering technology in agriculture could also
affect labor dynamics, farm structure, community viability, and farmers’ relationships with each
other and with information and input suppliers. However, the extent of the social effects of the
dissemination of GE crops is unknown because little research has been conducted.
Finding 10: The proprietary terms under which private-sector firms supply GE seeds to
the market has not adversely affected the economic welfare of farmers who adopt GE
crops- Nevertheless, ongoing research is needed to investigate how market structure may
evolve and affect access to non-GE or single-trait seed. Furthermore, there has been little
research on how increasing market concentration of seed suppliers affects overall yield
benefits, crop genetic diversity, seed prices, and farmers’ planting decisions and options.
During the 20th century, the U.S. seed industry evolved from small, family-owned businesses
that multiplied seeds developed by university scientists to a market dominated by a handful of
large, diversified companies. Universities still contribute to seed development, but seed
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companies have invested considerably in the research, development, and commercialization of
patent-protected GE traits for large seed maricets. Thus, com, soybean, and cotton have received
the bulk of private research attention in the last few decades. Large seed companies have not
commercialized GE traits in many other crops because their market size has been insufficient to
cover necessary research and development costs or because of concerns related to consumer
acceptance and gene flow. Public research institutions continue to enhance the genetics of other
crops, but full access to state-of-the-art technology (like genetic engineering) that may be
beneficial to crops in smaller markets is often not available to public researchers because of
patent protections.
Studies conducted in the first few after the introduction of GE crops found no adverse
effects on farmers’ economic welfare from the consolidation of market power in the seed
industry. However, the current developmental trajectory of GE-seed technology is causing some
farmers to express concern that access to seeds without GE traits or to seeds that have only the
specific GE traits that are of particular interest to farmers will become increasingly limited.
Additional concerns are being raised about the lack of farmer input into and knowledge about
which seed traits are being developed. Although the committee was not able to find published
peer-reviewed material that documented the degree of U.S. farmers’ access to non-GE seed and
the quality of the seed, testimony provided to the committee suggests that access to non-GE or
nonstacked seed may be restricted for some farmers or that available non-GE or nonstacked seed
may be available in older cultivare that do not have the same yield characteristics as newer GE
cultivars.
CONCLUSIONS AND RECOMMENDATIONS
Conclusion 1. Weed problems in fields of HR crops will become more common as weeds
evolve resistance to glyphosate or weed communities less susceptible to glyphosate become
established in areas treated exclusively with that herbicide. Though problems of evolved
resistance and weed shifts are not unique to HR crops, their occurrence, which is
documented, diminishes the effectiveness of a weed-control practice that has minimal
environmental impacts. Weed resistance to glyphosate may cause farmers to return to
tillage as a weed-management tool and to the use of potentially more toxic herbicides.
A number of new genetically engineered HR cultivars are currently under development
and may provide growers with other weed management options when fully
commercialized. However, the sustainability of those new GE cultivars will also be a
function of how the traits are managed. If they are managed in the same fashion as the
current genetically engineered HR cultivars, the same problems of evolved herbicide
resistance and weed shifts may occur. Therefore, farmers of HR crops should incorporate
more diverse management practices, such as herbicide rotation, herbicide application
sequences, and tank-mixes of more than one herbicide; herbicides with different modes of
action, methods of application, and persistence; cultural and mechanical control practices;
and equipment-cleaning and harvesting practices that minimize the dispersal of HR weeds.
Recommendation 1. Federal and state government agencies, private-sector technology
developers, universities, farmer organizations, and other relevant stakeholders should
collaborate to document emerging weed-resistance problems and to develop cost-effective
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resistance-management programs and practices that preserve effective weed control in HR
crops.
Conclusion 2. Given that agriculture is the largest source of surface water pollution,
improvements in water quality resulting from the complementary nature of herbicide-
resistance technology and conservation tillage may represent the largest single
environmental benefit of GE crops. However, the infrastructure to track and analyze these
ejects is not in place.
Recommendation 2. The U.S. Geological Survey and companion federal and state environmental
agencies should receive the financial resources necessary to document the water quality effects
related to the adoption of GE crops.
Conclusion 3. The environmental, economic, and social effects on adopters and
nonadopters of GE crops has changed over time, particularly because of changes in pest
responses to GE crops, the consolidation of the seed industry, and the incorporation of GE
traits into most varieties of corn, soybean, and cotton. However, empirical research into the
environmental and economic effects of changing market conditions and farmer practices
have not kept pace. Furthermore, little work has been conducted regarding the effects on
livestock producers and nonadopters and on the social impacts of GE crops. Issues in need
of further investigation include the costs and benefits of shifts in pest management for non-
GE producers due to the adoption of GE crops, the value of market opportunities afforded
to organic farmers by defining their products as non-GE crops, the economic impacts of
GE-crop adoption on livestock producers, and the costs to farmers, marketers, and
processors of the presence of approved or unapproved GE traits and crops in products
intended for restricted markets. As more GE traits are developed and inserted into existing
GE crops or into other crops, understanding the impacts on all farmers will become even
more important to ensuring that genetic-engineering technology is used in a way that
facilitates environment, economic, and social sustainability in U.S. agriculture.
Recommendation 3. Public and private research institutions should allocate sufficient resources
to monitor and assess the substantial environmental, economic, and social effects of current and
emerging agricultural biotechnology on U.S. farms so that technology developers, policymakers,
and farmers can make decisions that ensure genetic engineering is a technology that contributes
to sustainable agriculture.
Conclusion 4. Commercialized GE traits are targeted at pest control, and when used
properly, they have been effective at reducing pest problems with economic and
environmental benefits to farmers. However, genetic engineering could be used in more
crops, in novel ways beyond herbicide and insecticide resistance, and for a greater diversity
of purposes. With proper management, genetic-engineering technology could help address
food insecurity by reducing yield losses through its introduction into other crops and with
the development of other yield protection traits like drought tolerance. Crop biotechnology
could also address “public goods” issues that will be undersupplied by the market acting
alone. Some firms are working on GE traits that address public goods issues. However,
industry has insufficient incentive to invest enough in research and development for those
purposes when firms cannot collect revenue from innovations that generate net benefits
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beyond the farm. Therefore, the development of these traits will require greater
collaboration between the public and private sectors because the benefits extend beyond
farmers to the society in general. The implementation of a targeted and tailored regulatory
approach to G£-trait development and commercialization that meets human and
environmental safety standards while minimizing unnecessary expenses will aid this
agenda (Ervin and Welsh, 2006).
Recommendation 4. Public and private research institutions should be eligible for government
support to develop GE crops that can deliver valuable public goods but have insufficient market
potential to justify private investment. Intellectual property patented in the cour.se of developing
major crops should continue to be made available for such public goods purposes to the extent
possible. Furthermore, support should be focused on expanding the purview of genetic-
engineering technology in both the private and public sectors to address public goods issues.
Examples of GE-crop developments that could deliver such public goods include hut are not
limited to
• plants that reduce pollution of off-farm waterways through improved use of nitrogen and
phosphorus fertilizers,
• plants that fx their own nitrogen and reduce pollution caused by fertilizer application,
• plants that improve feedstocks for renewable energy,
• plants with reduced water requirements that slow the depletion of regional water
resources,
• plants with improved nutritional quality that deliver health benefits, and
• plants resilient to changing climate conditions.
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REFERENCES
Ervin, D., and R. Welsh. 2006. Environmental effects of genetically modified crops:
Differentiated risk assessment and management. In Regulating agricultural
biotechnology: Economics and policy, eds. R.E. Just, J.M. Alston and D. Zilberman, pp.
301--326. New Yoric: Springer Publishers.
Fernandez-Cornejo, J., R. Nehring, E.N. Sinha, A. Grube, and A. Vialou. 2009. Assessing recent
trends in pesticide use in U.S. agriculture. Paper presented at the 2009 Annual Meeting of
the Agricultural and Applied Economics Association (AAEA), July 26-28, in
Milwaukee, WI. AAEA. Available online at http://purl.umn.edu/49271. Accessed June
16, 2009.
USDA-NASS (U.S. Department of Agriculture - National Agricultural Statistics Service). 200 1 .
Acreage. June 29. Cr Pr 2-5 (6-01). U.S. Department of Agriculture - National
Agricultural Statistics Service. Washington, DC. Available online at
http://usda.mannUb.comell.edU/usda/nass/Acre//2000s/2001/Acre-06-29-200I.pdf.
Accessed April 14, 2009.
. 2003. Acreage. June 30. Cr Pr 2-5 (6-03). U.S. Department of Agriculture - National
Agricultural Statistics Service. Washington, DC. Available online at
http://usda.mannlib.comell.edU/usda/nass/Acre//2000s/2003/Acre-06-30-2003.pdf.
Accessed April 14, 2009.
. 2005. Acreage. June 30. Cr Pr 2-5 (6-05). U.S. Department of Agriculture - National
Agricultural Statistics Service. Washington, DC. Available online at
http://usda.manniib.comell.edU/usda/nass/Acre//2000s/2005/Acre-06-30-2005.pdf.
Accessed April 14, 2009.
. 2007. Acreage. June 29. Cr Pr 2-5 (6-07). U.S. Department of Agriculture - National
Agricultural Statistics Service. Washington, DC. Available online at
http://usda.mannlib.comeli.edU/usda/nass/Acre//2000s/2007/Acre-06-29-2007.pdf.
Accessed April 14, 2009.
USDA-NASS. 2009a. Data and statistics: Quick stats. Washington, DC: U.S. Department of
Agriculture - National Agricultural Statistics Service, Available online at
http://’www.nass.usda.gov/Data_and_Statistics/Quick_Stats/index.asp. Accessed June 22,
2009.
— . 2009b. Acreage. June 30. Cr Pr 2-5 (6-09). U.S. Department of Agriculture - National
Agricultural Statistics Service. Washington, DC. Available online at
http://usda.mannlib.comeil.edu/usda/cuiTent/Acre/Acre-06-30-2009.pdf. Accessed
November 24, 2009.
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1
Introduction
Historians often link the advent of human civilizations with the transition of human societies
from food collection primarily through hunting and gathering to food production in established
agricultural systems. In a pattern of parallel development, early agricultural systems began
emerging in separate regions during the Neolithic period some 10,000 years ago (Mazoyer and
Roudart, 2006). Crop-improvement practices based on identification and selection of the best
plant varieties appear to date back to the early days of agriculture itself. Similarly, early
pastoralists engaged in selective animal breeding. That those practices were recognized as
important in the development of ancient human civilizations is apparent in the preservation of
instructions on plant breeding in writing, such as in the works of Virgil and Theopastus (Vavilov,
1951). In the broadest sense, the term biotechnology can encompass a wide array of procedures
used to modify organisms according to human needs. It can be argued that early agriculturalists
engaged in a simple form of biotechnology (Kloppenburg, 2004) in developing the intention and
the techniques to improve plant varieties and animal species.
Although the process of plant and animal improvement has been continuous throughout the
history of agriculture, some historical periods can be identified as singularly transformative. For
example, a major agricultural revolution took place in Europe from the 16th to the 19th century.
It was characterized In part by the extensive use of plants and animals that had been imported
from the Americas (Crosby, 2003) and by animal-drawn cultivation and the use of fertilizers, the
latter permitting cereal and feed-grain cultivation without fallowing (Mazoyer and Roudart,
2006). That revolution led to important increases in the food supply and thus ultimately
permitted increased population growth.
Another important change in agriculture resulted from the application of an increasingly
scientific approach to plant breeding, which developed from the recognition of the cell as the
primary unit of all living organisms in the 1830s (Vasil, 2008) and the work of Mendel
(Kloppenburg, 2004). With the rediscovery of MendeTs principles of genetics in the early 1900s,
progress in plant and animal breeding was accelerated. The continuous growth in crop yields and
agricultural productivity during the 20th century owes much to those biological discoveries and
to a series of mechanical and chemical innovations driven by agricultural research and
development
One of the more significant innovations in plant breeding during the 20th centuty was the
development of hybrid crops, particularly com, in the United States. Hybrid corn varieties, which
are developed from crossing different inbred lines, out-yield pure inbred lines, though the seeds
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produced by hybrid varieties yield poorly. When com hybrids were first developed, they had no
discernible yield advantage over the existing open-pollinated corn varieties of the time
(Lewontin, 1990). However, seed companies were motivated to develop high-yielding hybrid
varieties; saving and planting the seeds of hybrid com did not produce equal yields, so seed
companies had a financial incentive to invest In these varieties. The research and development
efforts devoted to hybrid com produced tremendous yield improvements over the last 70 years. It
is unclear if the same amount of investment could have resulted in similar yield increases for
open-pollinated varieties; regardless, because of their limited potential for return on financial
investment, efforts to develop high-yielding open-pollinated varieties were not made. Modern
hybrids, which have been bred to allocate more of their energy to producing grain rather than
stover {leaves and stalks), also demonstrate an ability to maintain high grain production in
densely planted fields (Liu and Tollenaar, 2009), and they can exhibit increased tolerance to
environmental stresses (such as drought, cold, and light availability).
Plant breeders in the 20th century also identified varieties of wheat and rice with shorter
stalks and larger seed heads. They were crossed with relatives to create semidwarf wheat and rice
varieties, which produced greater yields in part because they responded well to applications of
nitrogen and did not lodge despite having heavier seed heads. The development of semidwarf
wheat and rice spurred the Green Revolution of the 1960s and 1970s in developing countries
(Conway, 1998). Such improvements in plant breeding increased global crop yields in rice and
wheat substantially in countries with suitable growing conditions and markets.
Recent developments in scientific plant breeding have resulted from discoveries in molecular
and cellular biology in the second lialf of the 20th century that laid the foundation for the
development of genetically engineered plants. In 1973, the American biochemists Stanley Cohen
and Herbert Boyer were among the first scientists to transfer a gene between unrelated organisms
successfully. They cut DNA from an organism into fragments, rejoined a subset of those
fragments, and added the rejoined subset to bacteria to reproduce. The replicated DNA fragments
were then spliced into the genome of a cell from a different species, and this created a transgenic
organism, that is, an organism with genes from more than one species. Before the advent of
genetic engineering, plant tissue-culture technology expanded the array of available genetic
materia! beyond what was possible with traditional plant breeding by manipulating the
fertilization and embryos of crosses between more distantly related species (Brown and Thorpe,
1 995). DNA-recombination techniques opened the possibility of augmenting plant genomes with
desirable traits from other species and thus took the science of plant breeding to a stage in which
improvement is constrained not by the limits of genetic traits within a particular species but
rather by the limits of discovery of genes and their transfer from one species to another to confer
desired characteristics on a particular crop.
COMMITTEE CHARGE AND APPROACH
The committee's study was the first comprehensive assessment of the impacts of the use of
genetically engineered (GE) crops on farm sustainability in the United States. The most up-to-
date, available scientific evidence from all regions was used to assemble a national picture that
would refiect important variations among regions. Box 1-1 presents the formal statement of task
assigned to the committee.
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statement of Task Summary
An NRC committee wtll stuciy ttieferm-teveS impat^ of bfotechnofogy, including the economics of
ad n‘>- ] ‘it.’X’.'tica'iy engineered cmps cttanqes in producer decision-making and agronomic
practices, and farm sustainability, v ' '
• review and malyze the published literature* on the impact cr *_V -ocs on *> » r u ■ j
* < ' r- - s f f farms in the United States
• examine evidence cHang^sIn agronomic, prsettces and inputs, such as pesticide and
> ru ' Je SG and soil and wafer man^ement regimes
• ■ yi'jirt ',rj,ir,v jc^is.orr-mak'ngwilhregntd 1 otheadoptK 3 nof< 36 t^op$
In a consensus report, the committee will present ttre ^hdkigs bf its ^udy and identify future
applications of plant and animat biotechnology that are’ Skely to a^ect agricultural producers’
decision-m^lng m the future ^ ^
In conducting its task, the committee interpreted the term sustainability to apply to the
environmental, economic, and social impacts of genetic-engineering technology at the farm
level. That interpretation is in line with the federal government's definition of sustainable
agriculture, which is “an integrated system of plant and animal production practices having a
site-specific application that will over the long-term:
1 . Satisfy human food and fiber needs.
2. Enhance environmental quality and the natural resource base upon which the agriculture
economy depends.
3. Make the most efficient use of nonrenewable resources and on-farm resources and
integrate, where appropriate, natural biological cycles and controls.
4. Sustain the economic viability of farm operations.
5. Enhance the quality of life for farmers and society as a whole.” (U.S.C. Title 7 § 3103,
2009)
This definition conceives of sustainable farming systems that address salient environmental,
economic, and social aspects and their interrelationships.
The report explores how GE crops contribute to achieving several of the conditions
enumerated above. Farmers must continually adapt in response to environmental, economic, and
social conditions by learning and adopting new practices. Adopting GE crops is one option some
farmers make in adapting to changing conditions.
Though the three aspects of sustainability often interact with one another, the report
organizes each in a separate chapter to facilitate access to the information. The chapter on
production economics follows the environmental chapter because many of the economic gains
and losses that farmers experience with GE crops result from changes occurring within the farm
environment from GE-crop adoption. The chapter on social effects is brief because of a lack of
published literature on the subject. Nevertheless, the committee deemed this aspect important to
include for two rea.sons. First, social impacts are widely considered to be a necessary element in
the definition of sustainability as noted earlier. Second, with the sizable shift in cropping
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practices and systems to genetic-engineering technology (and the prospect of more GE crops to
come), the marked expansion of private-sector control of intellectual property related to seeds,
and a growing concentration of private-sector seed companies, it is the committee’s estimation
that GE crops have had and will continue to have social repercussions at the farm and
community levels. The committee agreed that the report should draw attention to need for
research in this area. In this vein, the report highlights issues on which insufficient information is
available for drawing firm conclusions. The final chapter summarizes the main findings of the
assessment and discusses the potential for future GE crops to address emergent food, energy, and
environmental challenges.
The committee interpreted the statement of task to be retrospective in nature, examining the
sustainability effects of GE crops on U.S. farms since their commercialization. For that reason
the committee focused in large part on the experiences of soybean, com, and cotton producers
because GE varieties of those crops have been widely adopted by farmers, those crops are
planted on almost half of U.S. cropland, and most research on genetic-engineering technology in
agriculture has targeted those three crops. However, the committee recognized that most farmers
have been affected by the widespread adoption of GE crops, even if they have chosen not to
adopt them or have not had the option to adopt them. The report examined the effects of genetic-
engineering technology on those producers as well. Because the study was retrospective and
focused on the experience of U.S. farmers, the adoption of GE crops in other countries entered
into the analysis only if U.S. farmers have experienced effects of such adoption, and the
committee restricted its speculations on the future applications and implications of genetic-
engineering technology to the final chapter.
The National Research Council supported the study to expand its contributions to the
understanding of agricultural biotechnology. Committee members were chosen because of their
academic research and experience on the topic. Experts were selected from the fields of weed
science, agricultural economics, ecology, rural sociology, environmental economics,
entomology, and crop science. To prepare its report, the committee reviewed previous studies
and scientific literature on farmers’ adoption of genetic-engineering technology, the impacts of
such technology on non-GE farmers, and environmental impacts of GE crops. It also examined
historical and current statistical data on the adoption of GE crops in the United States. The
committee acknowledges that GE crops in U.S. agriculture continue to stir controversy around
scientific issues and ideological viewpoints. With this in mind, the committee kept its focus on
scientific questions and adopted an evidentiary standard of using peer-reviewed literature upon
which to base its conclusions and recommendations. It refrained from analyzing ideological
positions, either in support of or against the technology, in order to remain as impartial as
possible.
STUDY FRAMEWORK
An analysis of the farm-level sustainability impacts of GE crops requires a framework that
integrates all salient factors that motivate their use. We use the principal theories applied to
agricultural technology adoption to construct a framework that identifies the qualitative factors
that affect U.S. farmers’ decisions to use genetic-engineering technology. With an understanding
of the adoption and use processes, we then outline an evaluation framework that spans
environmental, economic, and social dimensions as noted above.
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Two main theories help in building a fiamework for analyzing a farmer’s decision to adopt a
particular GE crop. First, “diffusion” theory seeks to explain people’s propensities to adopt
innovations as communicated through particular channels and within particular social systems
(Rogers, 2003). Second, “threshold” Aeory delves deeper into the economic influences on
farmer decisions by considering the heterogeneity in farm sizes, in agronomic conditions
(climate, soil, water availability, and pest pressure), in forms of human capital that influence
learning by doing and using, and in operator values (Feder et al., 1985; Foster and Rosenzweig,
1995; Fischer et al., 1996; Maria et al., 2001; Sunding and Zilberman, 2001). Incorporating those
factor allows a belter qualitative understanding of the dynamics of the spread of the
technologies across the landscape and of their impacts. Together, the diffusion and threshold
theories point to five sets of factors that exert influences on a farmer’s decision to use genetic-
engineering technology:
1 . Productivity (yield) effects.
2. Market structure and price effects.
3. Production input effects.
4. Human capital and personal values.
5. Information and social networks.
Productivity Effects
Genetic-engineering technology can directly and indirectly affect crop yields, either
positively or negatively, as explained in Chapter 3 in more detail. The direct route stems from the
effect on a cultivar after the insertion of one or more traits through genetic engineering. The
indirect effect is related to the ability of a GE crop to decrease pest damage (Lichtenberg and
Zilberman, 1986a). Just as natural-resource conditions, including pest pressures, vary among
fields, farms, and regions, so will the indirect effects on yield and the rate of adoption of GE
crops. The technologies tend to be adopted in locations whose agrophysical conditions — such as
land quality, climate, and vulnerability to pests — lead to productivity gains (Marra et al., 2003;
Zilberman et al., 2003). In addition to effects on quantity, genetic engineering may affect the
quality of a crop, which influences its value.
Market-Structure and Price Effects
Fanners who are deciding whether to grow GE crops must consider their access to domestic
and foreign markets. Differential access may stem from country regulations on the entry of GE
crops into their markets or from lack of market infrastructure (for example, segmentation of GE
and non-GE product chains). Farmers who choose to grow GE crops may experience higher or
lower prices than if they grow non-GE crops. For example, if enough farmers adopt a GE crop
and yields increase substantially because of direct or indirect effects, crop prices may be forced
down by increased supplies, other characteristics remaining the same. Consumers of GE crops
may benefit from the lower prices, diough some consumers may be willing to pay more for non-
GE crops for personal reasons, and this may create a premium for non-GE crops. Under other
circumstances, global demand increases may absorb most or all of the increase in supply, in
which case prices would not decline (see Chapter 3).
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Market access and price effecte alter farmers’ revenues and profitability and thus their
disposition to adopt GE crops. The organizational hierarchy of the commodity chain and the
nature of farm policies can create structural conditions that act as impediments to or inducers of
adoption of a technology (Mouzelis, 1976; Bonanno, 1991; Friedland, 2002; Kloppenburg,
2004). For example, the development of crops with more than one GE trait may create a
structural condition for some farmers whereby they may have to pay for traits that they do not
need in order to gain access to the traits that they desire (see Chapter 4).
Production-Input Effects
The adoption and use of GE crops can precipitate changes in the types, amounts, and timing
of pesticide use and in the types, frequency, and timing of tillage operations; both can affect
machinery requirements. Those changes are referred to as substitution effects; an example is the
replacement of some pesticides with a GE crop (Lichtenberg and Zilberman, 1986b). A shift in
labor requirements is another potentially important production-input effect (Femandez-Comejo
and Just, 2007). The availability and quality of GE and non-GE seeds may affect a farmer’s
decision to use either. For example, the commercial success of the application of GE soybean
and com in the 1990s was accompanied by increased consolidation and vertical integration in the
seed industry (Femandez-Comejo, 2004). Indeed, by 1997, two firms captured 56 percent of the
U.S. corn-seed market, and this share has increased even more in recent years (see “Interaction
of the Structure of the Seed Industry and Farmer Decisions’* in Chapter 4) (Boyd, 2003). The
changes in genetic-engineering technology and seed-industry structure may help to explain
anecdotal statements about the reduced availability of some non-GE seed varieties in recent
years (Hill, personal communication). However, the committee is not aware of any published
research confirming the link between seed-industry structure and seed availability.
Human Capital and Personal Values
Every major study of agricultural-technology adoption has found that at least some aspects of
human capital play a role in the process. Frequently, the more education or experience a farmer
has, the more likely he or she is to adopt a new technology. Educational achievement and years
of experience in farming are thought to be proxies for a potential adopter’s ability to learn
quickly how to adapt the new technology to the farm operation and to use it to its greatest
advantage. As noted above, the process of learning and adaptation is critical to the development
of more sustainable farming systems. Farmers also may hold personal values that affect their
decisions to use GE crops beyond the financial effects that may flow from productivity, value,
and production input. A person’s values define preferences and have been shown to influence
decisions on genetic-engineering development and applications (Piggott and Marra, 2008;
Buccola et al., 2009). Examples of personal values include aversion to general and specific risks,
preference for environmental stewardship, and ideological positions about agricultural systems.
An example of the influence of risk aversion is some farmers’ preference for GE crops if they
reduce the variability of yields because they improve control of pests. Such risk reduction can
motivate adoption of GE varieties by risk-averse farmers and may also lead to an increase in use
of complementary practices, such as no-till planting (Alston et al., 2002; Piggott and Marra,
2007).
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Information and Social Networks
Decisions of whether to adopt GE crops hinge on the quantity and quality of farmer’
information about the characteristics and performance of the technologies. Information from
formal sources, such as the agricultural media, on GE traits’ technical aspects, economic
implications, and prospects can shape farmers’ views. Informal sources probably also speed or
slow the adoption of GE crops (Wolf et al., 2001; Just et al., 2002). Social networks can have
favorable or unfavorable effects not only on the adoption of technologies but also on the sharing
of knowledge about GE and non-GE crops and on the development of new technologies and
management strategies (Arce and Marsden, 1993; Busch and Juska, 1997; Hubbell et al., 2000).
They can also mitigate potentially negative social impacts of GE-crop adoption. Recognition of
the importance of social networks has been enhanced by studies of the processes associated with
the use of alternative agricultural practices (Storstad and Bjorkhaug, 2003; Morgan et al., 2006).
Insights derived from the study of social networks also may have great relevance to the
development and dispersion of genetic-engineering technology.
Figure 1-1 portrays the influences of the different factors on GE-crop adoption decisions and
the resultant impacts on environmental, economic, and social conditions. This conceptual model
shows that factors under the control of the farmer, such as human capital, and outside their
control, such as market prices, come together to influence the GE-crop adoption decision
process, depicted by the central box in the figure. It also shows how the factors, up to this point
presented as having distinct effects, may influence each other. Examples of potential interactions
include the effects of information and social networks on persona! values and production inputs
and the effect of production-input substitution on productivity. Other impacts of decisions related
to GE crops (for example, the environmental effect of pest population changes) may feed back to
some influencing factors, such as production inputs. As discussed later in this chapter, empirical
studies have found that factors in each of the categories have influenced GE-crop adoption
patterns. However, it is not possible to rank the magnitude of influences in a general sense.
Rather, we expect that the different factors will vary in influence across types of farms,
geographic regions, and specific crop applications. For example, if a certain pest infestation is
severe in a region, then the productivity gains from adopting a GE crop may far outweigh the
influence of personal values of the adopter. In another case where pest pressures are moderate
compared to other regions, functioning information and social networks may influence the speed
and rate of adoption of genetic-engineering technology.
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Human CapitJl
and Personal
Values
Information and
Production Inputs
GE Crop Adoption Decisions
. Impacts
Social Impacts
economic Impacts
Market Access
Productivity
(Viold) Effects
and Prices
FIGURE 1-1 Genetically engineered crop adoption and impact framework.
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GENETICALLY ENGINEERED TRAITS IN CROPS
For agricultural crops, the first generation of genetic engineering has targeted traits that
increase the efficacy of pest control. Since the introduction of GE crops, new seeds have
provided pest control in one or more of three forms:
• Herbicide resistance.
• Insect resistance.
• Virus resistance.
The terms resistance and tolerance are often used interchangeably in the literature. Tolerance
implies that a crop is affected by a pesticide but has a means to naturally survive the potential
damage sustained. This report uses the more precise term resistance because altered genes either
allow a plant to generate its own insecticide or prevent herbicides from damaging the plant (Roy,
2004).
GE herbicide-resistant (HR) crops contain transgenes that enable sui-vival of exposure to
particular herbicides. In the United States, crops arc available with GE resistance to glufosinate
and glyphosate, but most HR crops grown in the United States are resistant only to glyphosate. a
nonselective chemical that has a low impact on the environment. Glyphosate inhibits the enzyme
5-enolpyruvyl-shikimatc-3-phosphatc synthase (EPSPS), which is part of the shikimate pathway
in plants. The shikimate pathway helps produce aromatic amino acids; it is speculated that
glyphosate kills a plant either by reducing aromatic amino acid production and adversely
affecting protein synthesis or by increasing carbon fiow to the glyphosate-inhibited shikimate
pathway, causing carbon shortages in other pathways (Duke and f’owies, 2008). The
susceptibility of EPSPS to the chemical and the relative case with which it is taken up by a plant
make glypho.sate an extremely elTeclive herbicide. It presents a low threat of toxicity to animals
in general because they do not have a shikimate pathway for protein synthesis (Cerdeira and
Duke. 2006). Glyphosate also has low soil and water contamination potential because it binds
readily to soil particles and has a relatively short half-life in soil (Duke and Powles, 2008).
Insect-resistant (IR) plants grown in the United Stales have genetic material from the soil-
dwelling bacterium Bacillus ihuringiensis (Bt) incorporated into their genome that provides
protection against particular insects. Bt produces a family of endotoxins, some of which are
lethal to particular species of moths. Hies, and beetles. An insect’s digestive tract activates the
ingested toxin, which binds to receptors in the midgut; this leads to the formation of pores, cell
lysis, and death. Individual Bt toxins have a narrow taxonomic range of action because their
binding to midgut receptors is specific: the toxicity of Bt crops to vertebrates and many nontarget
arthropods and other invertebrates in U.S. agricultural ecosystems is effectively absent. The first
Bt crops that were introduced produced only one kind of Bt toxin. More recent varieties produce
two or more Bt toxins: this enhances control of some key pests, allows control of a wider array
of insects, and can contribute to delaying the evolution of resistance in target pests while
reducing refuge size.
Gene sequences of pathogenic vimses have been inserted into crops to confer protection
against related viruses — to make them virus-resisUint (VR). Most transgenic VR plants resist
viruses through gene silencing, which occurs when transcription of a iransgene induces
degradation of the genome of an invading virus. Potential unwanted environmental effects of VR
crops include exchanges between viral pathogens and Iransgene products that could increase the
virulence of viral pathogens, food allergenicity, and transgene movement through pollen, which
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can create VR weeds. Adverse environmental effects of commercialized VR plants have not been
found (Fuchs and Gonsalves, 2008).
HR and IR crops, having been the principal targets of most efforts to develop GE crop
varieties, account for the bulk of acres planted in GE crops in the United States. Consequently,
this report focuses on farmers’ experiences with these types of GE crops. HR varieties of
soybean, corn, cotton, canola, and sugar beots and IR varieties of corn and cotton were grown
commercially in 2009. Herbicide resistance and insecticide resistance are not mutually exclusive;
a number of crop varieties that contain both types of resistance have been developed. GE corn
and cotton may also express more than one type of Bt trait. Seeds with multiple GE
characteristics are referred to as “stacked cullivars".
Herbicide resistance and insect resistance were commercialized because of the relative
simplicity in gene transfer and the utility for farmers. The expression of those traits requires
manipulation of the genetic code at only one site, a relatively straightforward process compared
with such traits as drought tolerance, which involve the action of many genes. Furthermore,
because corn, soybean, and cotton production accounts for the bulk of pesticide expenditures in
the United States (Figure 1-2), herbicide resistance and insect resistance provided important
market opportunities. Those GE crops lit easily into the traditional pest-management approach of
mainstream U.S. agriculture: reliance on the continual emergence of technological advances to
address pest problems, particularly after development of resistance to an earlier innovation.
Therefore, the familiarity of the chemicals involved, the size of the market for the seeds of and
pesticides for GE crops, and the ease of manipulation of the genes for the traits contributed to
HR and IR seeds' being the first GE products to emerge in large-scale agriculture.
1998 1999 2000 2001 2002 2003 2004 2005 2006 2007
1L1 Wheat
tB Cotton
iS Soybean
s Corn
Year
FIGURE 1-2 Share of major crops in total pesticide expenditures, 1998-2007.
NOTE: Includes expenditures in herbicides, insecticides, and fungicides. Genetically engineered
trait technology fees are not included.
SOURCE: Fernandez-Comejo et aL, 2009.
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ADOPTION AND DISTRIBUTION OF GENETICALLY ENGINEERED CROPS
Crops with GE traits aimed primarily at pest control have been widely adopted in the United
States by farmers of corn, cotton, soybean, canola, and sugar beet and have caused subslanliai
changes in farm-management practices and inputs, such as changes in pesticide use. In 2008,
almost half of U.S. cropland was planted with GE seed, even though the technology had been
available to farmers only since the middle 1990s and only a few crops have experienced
commercial success (liSDA-NASS, 2009b). U.S. farmers planted 158 million acres of GE crops
in 2009 — nearly half of all the GE-crop acres in the world (James, 2009). Rates of adoption have
been influenced by the type of crop, the trait expressed in the crop, and the pest pressures
occurring on the farm. For example, adoption of cullivars with Bt traits has been most rapid and
widespread in areas prone to insect infestations that can be curbed by the endotoxins present in
GE crops.
The committee chose to concentrate its study on the farm-level effects of GE soybean, corn,
and cotton because these crops are growm on nearly half of U.S. cropland (USDA-NASS, 2009b)
and because over 80 percent of these crops are genetically engineered (Figure 1-3). The high
level of adoption and the large-scale planting of those crops mean they have a substantially
greater cumulative impact on farm-level sustainability compared to other GE crops, which may
be widely adopted but are planted on few acres or may be adopted by only a small percentage of
growers. Additionally, there are GE crops that have been commercialized but were not sold in
2009 for business or legal reasons. Those crops arc discussed in the report, but they arc not its
primary focus (Box i-2).
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FIGURE 1-3 Nationwide acreage of genetically engineered soybean, corn, and cotton as a
percentage of ail acreage of these crops.
SOURCE: USDA-NASS, 2001, 2003, 2005, 2007, 2009b.
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ind 32 p^^nt of the canot4
m 617.35e
Swrot corn.
iittie less than half,
remaining acres w^^
varieties with high E
protechon against
communication). Bt
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processors have been reluctant to purchase sweet com with GE traits because possible
consumer aversion to GE crops could .have negatively affected purchases of other products
under their brand names (Bradford and Alston; 2004). Commercialized Bt sweet corn also has
been engineered to resist glufosinate, however, glutosinate is not registered for use with Bt sweet
corn because of concerns about consumer acceptance (Fennimore and Doohan, 2008)
Comniorciahzed Genetically Engineered Crops Not Presently Available
Tomato.’ The Flavr Savr tomato, developed by the company Calgene, was commercialized
in 1994 The genetics of the tomato were engineered to slow the softening of the vegetable
during ripening The trait was developed in i tomato variety usually used for processing;
However, a public opposition campaign against GE tomatoes caused some large processors to
refuse to purchase the Flavr Savr variety for their products. In response. Calgene tned to sell the
variety as a fresh-market tomato, but the vegeteSjle brtrised easily That characteristic caused
problems in production, transportation, and distribution. Furthermore, the Flavr Savr did not taste
better than its cheaper competitors. Production of the variety was discontinued. Another GE
tomato, developed for processing by the' company Zeneca, was grown in California in the middle
1990s Those tomatoes had a similar GE trait for delayed ripening and were processed into
tomato paste for sale in the United Kingdom. Hovyever, consumer opposition to GE products
caused Zeneca to discontinue the sale of the tomato paste in 1 998
Potato. A Bt potato resistant to the Colorado potato beetle was .commercialized in 1995*
Three years later, the technology developer, Monsanto, introduced a stacked variety that,
combined the Bt trait with virus resistance Researchers found the Bt trait protected the potato
from insect damage at all stages of the beetle's life (Pertak bt a)., 1993). and Monsanto scientists
noted a targe potential for r^uction in the use of pesticides to treat insect aric
(KamewsW and;Thoraas, ,a)04).: However,, -Monsanto discontinued the sale of GE potatoes ins
2001 . The cultivars fii'iled to capture more than 2-3 percent of the market for two reasons. First, a
newiinsecficide that controlletf the Coloradd pbfeto beetle aritf other pests came on the market at
around the same time as GE potatoes; most farmers chose the insecticidd b
(iyesbttti'2flQS|,Se^nrt; potato processors a public-pressure ;camp i
use of GE potatoes (Kiknan. 200Q; Kaniewski and Thomas. 2004). As food compi
use -non-GE i piaatoes - in their : products, farmers responded to -pro!
eonventional varieties. Thus, although GE potatoes were teohnotog
survive in the marketplace.
AHaifa. Alfalfa is an impor^ffi|®n the United StatestaBd is widely cuttivaled ever a broad
: geographic range.(UStJA-NA^B|W), GE glyphosate-r^Stant alfalfa, was cc
rSoOSi'and about 198,000 acres^iS ^w nted in 2006 (VVei^'‘2007) However, legsj aotbn over
leonceme about the risk of introgrS^Rn of the transgena'k^ nontransgentc alfalfa and' the
finabilltyi te-tirtigate tbis nsk result^B the termination <#SiBher seed sates and pteiiting of
;glyp,h0sate-ra8istaitt,.alfetfa (Charle^gOOT) until USDA aampleted an environmental impact
istaiemei* ThateWteibent was releaBfor public comment.^ December 2009
' ’Adapted from Vogt and Parish (2001)
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TABLE 1-1 Genetically Engineered Soybean Varieties, by Stale and United Stales, 2000-2009
State
2000
2001
2002
Herbicide-Resistant Soybean
2003 2004 2005 2006
Percent of all soybean planted
2007
2008
2009
Arkansas
43
60
68
84
92
92
92
92
. 94
94
Illinois
44
64
7i
77
81
81
87
88
87
90
Indiana
63
78
83
88
87
89
92
94
96
94
Iowa
59
73
75
84
89
91
91
94
95
94
Kansas
66
80
83
87
87
90
85
92
95
94
Michigan
50
59
72
73
75
76
81
87
84
83
Minnesota
46
63
71
79
82
83
88
92
91
92
Mississippi
48
63
80
89
93
96
96
96
97
94
Missouri
62
69
72
83
87
89
93
91
92
89
Nebraska
72
76
85
86
92
91
90
96
97
96
North Dakota
22
49
61
74
82
89
90
92
94
94
Ohio
48
64
75
74
76
77
82
87
89
83
South Dakota
68
80
89
91
95
95
93
97
: 97
98
Wisconsin
5!
63
78
84
82
84
85
88
90
85
Other states®
54
64
70
76
82
84
86
86
87
87
United States
54
68
75
81
85
87
89
9!
. 92
91
“'Includes all other states in soybean estimating program.
SOURCE: USDA-NASS, 2001, 2003, 2005. 2007, 20090.
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2000 2001 2002 2003 2004 2005 2006 2007 2008 2009
Year
FIGURE 1-4 Herbicide-resistant soybean acreage nationwide.
SOURCE: USDA-NASS, 2001, 2003. 2005, 2007, 2009b.
Corn
The first GE variety of corn, which was commercialized In 1996, expressed a Bt toxin that
targeted European corn borer, southwestern corn borer, and several other pests {see Table 1-2).
GE com with resistance to glyphosate was released in 1997, followed by a variety with
resistance to glufosinate in the next year (Dill, 2005). An IR variety with a different Bt toxin to
combat corn rootworm {Diahrotica spp.) was introduced in 2003.
Adoption of HR com proved slower than that of soybean: only 8 percent of the acreage was
planted to HR corn in 2001 (Table 1-3, Figure 1-5). The low adoption rate of HR corn in 2001
w'as consistent among all U.S. regions. The narrow window of time for glyphosate application to
be effective against early-season weed pressure in com may have deterred fanner adoption
(Tharp and Kells, 1999; Johnson et a!., 2000; Gow^er et ai., 2003; Knezevic et aL, 2003; Dailey et
al., 2004: Cox et al., 2005). Grow'ers probably relied on traditional strategies for pre-emergence
herbicide weed control rather than risk missing the glyphosate application window and ending up
with weedier Helds and reduced corn yields. Furthermore, lack of market access for HR com to
the European Union provided an added deterrent against early adoption of HR corn in the late
1990s and early 2000s.
Variable insect pressure also delayed the adoption of IR com, and this resulted in planting of
only 19 percent of the acreage to IR corn in 2001 (Table 1-3, Figure 1-5). European corn borer is
a key pest in the western Corn Belt region (Pilcher et al., 2002; Hyde et ai., 2003; Miingai et a!.,
2005) but causes only a sporadic problem in the eastern Com Belt region (Baule et al., 2002; Ma
and Subedi, 2005: Cox et al.. 2009). Consequently, IR com acreage ranged from 23 to 30 percent
in Iowa, Kansas, Minnesota, Missouri, Nebraska, and South Dakota but from 6 to 11 percent in
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Indiana, Michigan, Ohio, and Wisconsin in 200I (Table i-3). Farmers in regions without
consistent corn borer infestations probably chose not to adopt IR corn.
TABLE 1-2 Insect Pests of Com Targeted by Bt Varieties
Common Name
Latin Binomial
Primary Pest
European corn borer
Ostrinia nuhilcdis
Southwestern corn borer
Diatraea srandiosella
Western corn rootwonTs
Diahrotica virgifera virgifem
Northern corn rootworm
Diahrotica barberi
Corn earworm
Helicoverpa zea
Fall armyworm
SfXidoptera frugiperda
Black cutworm
Ap-istis ipsilon
Secondary Pest
Mexican corn rootworm
Diabrotica vin-ifera zeae
Southern cornstalk borer
Diatraea cramhidokles
Stalk borer
Papaipema nehris
Lesser com stark borer
Elasmopalpus lignosellus
Sugarcane borer
Diatraea saccharalis
Western bean cutworm
Richia albicosta
NOTE; This pest categorization does not describe specific pest pressures in different states or
regions. For example, the sugarcane borer is a primary pest of com in Louisiana.
SOURCE; US-EPA. 2009.
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In 2002, slacked hybrids were introduced, and this led to a further increase in acreage of GE
com. The increasing rate of adoption of stacked hybrids — 2 percent in 2002 and 46 percent in
2009, with all major com states above 30 percent (Table 1 -3) — reflects the popularity of these
traits and the lack of nonstacked GE traits in the seed marketplace. By 2009, 85 percent of U.S.
com acreage was planted with some type of GE seed; more than half these acres were in stacked
varieties {Figure 1-5). In addition, by 2009, all major corn-growing states had GE acreage
exceeding 70 percent except Ohio (67 percent); thus, adoption of IR corn is no longer region-
specific (Table 1-3). Farmers’ preference for multiple traits explains in part the lower rates of
adoption of HR-only and IR-only varieties of com compared with the rates of adoption of HR
soybean (Figure 1-4).
Com rootworm is a destructive and consistent pest in all regions of the United States that
have continuous corn fields (and in some regions where com is planted in fields after soybean).
Bt corn for control of com rootworm, especially western com rootworm, has contributed to
increased acreage of GE com since its introduction in 2003 because growers preferred IR com to
the use of soil-applied insecticides or the use of insecticide and fungicide applied to seed at 1 .25
mg of active ingredient' per seed. Bt com hybrid seed for com rootworm control is sold with
only 0.25 mg of active ingredient per seed of insecticide and fungicide for control of secondary
pests and soil-borne pathogens. Growers can choose to add this feature for an additional cost to
non-GE or HR com hybrid seed. Thus, GE com with the Bt trait for corn rootworm control and
lower levels of seed-applied insecticide and fungicide substituted for the control tactics in
continuous com in the 1980s and 1990s of soil-applied insecticides for rootworm control and
seed-applied products with higher toxicity’ for secondary pest control, which growers had to
manually apply to the seed. In-plant resistance for rootworm control with low levels of
insecticide already applied to the seed by professional seed handlers for control of secondary
com pests is safer for the farmers who plant the crops and for the environment.
‘The active ingredient is the material in the pesticide that is biologically active. The active ingredient is
typically mixed with other materials to improve the pesticide’s handling, storage, and application properties.
’Examples include click beetles (Alaus oculatus), scarab beetles (Scarabaeus sacer). seed com maggot
{Delia platura), and wirewonns (Melanotus spp).
^Examples include 0,0-diethy! 0-2-!Sopropy!-6-methyl(pyrimidine-4-yl) phosphorothioate (commonly
marketed as Diazinon); N-trichtoromethyJthio~cyclohexene- 1,2'dicarboximide (Captan); and gamma-
hexachlorocyclohexane (Lindane).
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100 ^
Year
FIGURE 1-5 Genetically engineered com acreage trends nationwide.
SOURCE: USDA-NASS, 2001; 2003, 2005, 2007, 2009b.
Cotton
Commercialized in 1996, IR cotton rapidly gained substantial market share because of its
control of tobacco budworm, pink bollworm, and cotton bollwomi (Table 1-5). GE glyphosate-
resistant cotton, introduced in 1997, also proved popular with farmers because weed
management has traditionally been more challenging in cotton than in many other field crops
(Jost et al., 2008). The stacked Bt-glyphosate-resistant variety was introduced in 1997. By 2001,
GE cotton had captured 69 percent of the acreage: 32 percent HR-only, 1 3 percent IR-only, and
24 percent stacked varieties (Table 1-4, Figure 1-6). Farmers in the southeast Cotton Belt
adopted GE varieties more rapidly (78-91 percent in Arkansas, Georgia, Louisiana, Mississippi,
and North Carolina) compared with those in Texas (49 percent) and California (40 percent),
reflecting the lower insect pressure in the latter two states, especially California (only 1 1 percent
IR and 2 percent stacked varieties).
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TABLE 1-4 Insect Pests of Cotton Tm^eted by Bl Varieties
Common Name
Latin Name
Primary Pest
Cotton bollworm
Helicoverpa zea
Tobacco budworm
Heliothis virescem
Pink bollworm
Pectinophora gosypiella
Secondary Pest
Salt marsh caterpillar
Estigmene acrea
Cotton leaf perforator
Bucculatrix thurberiella
Soybean looper
Pseudoplusia includens
Beet armyworm
Spodoptera exigua
Fall armyworm
Spodopiera jrugiperda
Yellowstriped armyworm
Spodoptera ornilhogalli
European com borer
Ostrinia nubilalis
NOTE: This pest categorization does not describe specific pest pressures in different states or
regions. For example, the cotton bollworm and tobacco budworm are minor pests of cotton in
Arizona.
SOURCE: US-EPA, 2009.
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A new HR variety introduced in 2006 provided growers with a wider window for glyphosate
application and the possibility of using higher glyphosate dosages (Mills et al., 2008). At around
the same time, !R cotton with two Bt endotoxins was commercialized and offered improved
control of cotton bollworm, increased protection against such secondary pests as beet armyworm
and soybean looper, and advantages in resistance management (Mills et al., 2008; Siebert et al.,
2008). The introduction of the improved traits alone or in stacked cultivars contributed to the
increase in GE cotton to 88 percent in 2009; 23 percent HR-only, 17 percent IR-only, and 48
percent stacked (Table 1-5). As in 2001, farmers in the southeastern states had a higher adoption
rate of GE cotton in 2009 (91 percent or greater) than Texas (81 percent) and California (73
percent). Pink bollworm and cotton bollworm are not major insect pests in California, so
adoption of IR cotton (8 percent) and stacked varieties (I I percent) are particularly low; HR
cotton (54 percent) makes up most of GE cotton in California.
100
FIGURE 1-6 Genetically engineered cotton acreage trends nationwide.
SOURCE: USDA-NASS, 2000-2008, 2001, 2003, 2005, 2007, 2009b.
An Early Portrait of Farmers who Adopt Genetically Engineered Crops
A study of cotton farmers’ planting decisions in four southeastern U.S. states in 1996 and
1997 provided early evidence on the various factors that influenced the choice to adopt
transgenic cotton (Marra et al., 2001). The growers were asked about their human capital (stock
of knowledge and ability), farm-specific characteristics, reasons for adopting or not adopting Bt
cotton in 1996, and the pest-control regimens that they used on both their conventional and their
Bt cotton acres (if applicable), including amounts and types of insecticides applied and their
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costs. Comparing the farmers’ actions on fields planted to Bt and non-Bt cotton on the same farm
controlled for variation in management, land quality, and machinery complement.
The study found that one measure of human capital that was associated with a higher
likelihood of adopting Bt cotton was experience (number of years of growing cotton). The age of
the farmer was not significant. The pro|^nsity to adopt because of higher profit potential of
genetic-engineering technology — ^related to higher yields, decreased costs, or both — was also
affirmed by the responding farmers. They reported higher yields on their Bt acres than on their
non-Bt acres (6.58 Ib/acre more on fields with Bt cotton than those without in the Upper South
and 16.43 Ib/acre more in the Lower South) and large reductions in pesticide costs in both
regions (about $6.00/acre less for fields with Bt cotton in the Upper South and about S 1 0.00/acre
less in the Lower South). Similarly, farmers who had previously experienced a high degree of
pest infestation or pest resistance to currently used pesticides were more inclined to grow Bt
cotton. Adopters reported higher past boll damage (7 percent higher on average compared with
nonadopters) and higher incidence of past pest resistance to conventional insecticides (31 percent
reported pest resistance compared with 18 percent of nonadopters in the combined sample).
Those findings on human capital, yields, and the influence of pest problems are in accord with
the explanations for adoption put forth by the diffusion and threshold theories.
Farm characteristics can also play a role in the decision to adopt a new technology. If the
technology requires a high initial investment (such as for new machinery), farmers with more
acres over which to spread the fixed costs might be more likely to adopt. Although the
production technology itself is considered to be scale-neutral (i.e., the technology should not
have differential impacts based on the size of the farm operation into which it is adopted),
adopters in the study in both regions tended to have much larger farms and to farm more cotton
acres than nonadopters; this supports the idea that the costs of learning may not be scale-neutral
and thus that there is a possibility that differential farm-level social impacts have been associated
with the adoption of GE crops (explained further in Chapter 4).
In 2001, farmers in Indiana, Illinois, Iowa, Minnesota, and Nebraska were surveyed to
analyze the differences between adopters and nonadopters in farm and farmer characteristics
(Wilson et al., 2005). The responses revealed that farmers growing com on farms of less than
160 acres planted a greater percentage to GE com for Eurupwan coni borer coiiirol (54.5 percent)
than farmers growing com on farms of over 520 acres (39.2 percent). The same small-large
differential held for aerial application of an insecticide (73.8 percent of farmers with less than
160 acres versus 57.3 percent with more than 520 acres); this suggests that smaller farmers place
greater reliance on both chemical and GE controls of European com borer than larger farmers.
Just over one-fifth of the farmers (21.1 percent) reported a yield increase with the use of
transgenic com for European com borer in all five states, from 11.2 percent in Indiana to 29.9
percent in Minnesota; 2.8 percent reported a yield decrease; and the rest reported no change in
yield or that they did not know if there was a change or not. The surveyed farmers’ greatest
concerns were the ability to sell GE grain (59.3 percent), a market-access factor, and the
additional technology fee (57.3 percent), a production-input factor that affected profits. Finally,
the responding farmers indicated that a reduction in exposure to chemical insecticide (69.9
percent of the farmers), a personal health concern, and a reduction in insecticides in the
environment (68.5 percent), a personal value, were the primary benefits of transgenic com.
A more recent study of GE-crop adoption pertains to soybean (Marra et al., 2004). Table 1-6
presents the average total number of operated acres, the proportion of operated acres owned, age,
education, and Income (by category) for the different classes of adopters with the results of
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pairwise t-test results. The t-test results show that adopters (both partial and full) in this survey
tended to be younger and operated more acres than nonadopters. Income, education, and
percentage of operated acres the farmer owned do not show statistically significant differences
among classes of adopters (Marra et al., 2004).
TABLE 1-6 National Soybean Survey Descriptive Statistics by Adoption Category
Farm Characteristics
Nonadopters
Partial Adopters
Full Adopters
Total Operated Acres
916.9*
1237.5“
(N)
(44)
(66)
(136)
Proportion of Acres Owned
0.6®
0.5“
.05*
(N)
(59)
(78)
(167)
Year Bom
1944.7*
1947.8“
1946.3“
(N)
(54)
(72)
(150)
Years of Formal Education
13.2"
13.7*
13.3“
(N)
(44)
(62)
(131)
Total Income (by category)
3.3*
2.8*
3.0®
(N)
(34)
(49)
(103)
NOTE: If a superscript letter is different, the mean for this class of adopters is statistically
significantly different from the others in that category.
NOTE: Income categories ranged from 1= <$50, 000/year to 5 - >$500,000/year.
SOURCE: Marra et al., 2004.
The importance of social netwoiics in influencing patterns of adoption of GE crops has been
highlighted in another recent study of the adoption of Bi com in the Midwest. It described how
farmers, whom the author of the study termed reflexive producers, negotiate between the advice
and claims of experts, who do not farm, and local forms of knowledge that are conveyed by
members of farmer networks. The study found that farmers’ determination of whether pest
problems that require the use of Bt com exist depended more on local than on expert knowledge
(Kaup, 2008).
DETERRENTS TO GENETICALLY ENGINEERED TRAIT DEVELOPMENT IN
OTHER CROPS
Soybean, com, and cotton represent a substantial number of acres planted in the United
States, but they do not reflect the diversity of American agriculture. GE varieties have not been
developed by private firms for most U.S. crops, in part because the small markets for these crops
will not generate sufficient returns on the necessary investment in research, technology
commercialization, and marketing infrastructure. Furthermore, concern about selling food with
GE-derived ingredients in some markets and the resistance of some grower organizations have
limited the commercial application of genetic-engineering technology to just a few crops.
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Market Conditions Inifluencing the Commercialization of Genetically Engineered Varieties
Most research in and development of GE crops are conducted by private firms. Private
companies must produce profits for Uieir shareholders, so the marketability of a crop plays a
determining role in decisions as to which GE crops are brought to commercialization. Market
size, trait value, regulatory costs, environmental concerns, and technology access influence
biotechnology firms’ decisions to develop and sell GE seeds.
The market for seeds must be large enough to warrant the investment in commercialization.
If markets are too small or are characterized by farmers with low ability to pay for the
technology, the benefits to firms are too low to induce them to introduce GE varieties. That is
one of the reasons that specialty crops have largely been overlooked in genetic engineering. The
VR papaya, for example, was developed through public research. In addition, the number of
researchers in these types of crops is considerably smaller and the marketing infrastructure less
extensive than for soybean, com, and cotton. That lack of resources, the diversity of species, the
relatively short marketing season, and the small number of planted acres combine to deter
private-sector investment in genetic-engineering technology for specialty crops (Bradford and
Alston, 2004). To collect sufficient returns, firms instead invest in widely grown crops that have
long storage life and that have year-round marketing potential. That generally means that farmers
growing such crops have access to genetic-engineering technology, whereas the option is not
available to fanners growing specialty crops or crops that are not widely grown in the United
States.
The cost of regulatory compliance to ensure that GE crops do not pose unacceptable food
safety and environmental risks has become an important component of the overall cost of new
biotechnologies (Kalaitzandonakes et al., 2007). These costs may have contributed to limiting
the development of GE minor crops, as was the case with pesticide development during the
1970-1990 period. As Ollinger and Femandez-Comejo (1995) found, “pesticide regulations have
encouraged firms to focus their chemical pesticide research on pesticides for larger crop markets
and abandon pesticide development for smaller crop markets.” Obtaining regulatory clearance of
GE crops in the United States is a long process, and the cost per crop can be very high.
Furthermore, for crops with wild, weedy relatives (e.g., wheat), the potential for gene flow raises
their environmental risk and expense (see “Gene Flow and Genetically Engineered Crops” in
Chapter 2). Large private firms have concluded that Investment in less widely grown crops does
not generate adequate returns to justify the development and regulatory cost of bringing them to
market.
Research and development in genetic-engineering technology have been stimulated by the
development of patent protection for GE organisms. Changes in intellectual-property rights (IPR)
law in the 1970s and 1980s are largely responsible for creating a profitable environment for
biotechnology research. However, that protection may also create constraints on the development
of GE varieties of more crops. Companies that control the patents may be unwilling to provide
licenses or offer licenses at affordable prices to public-sector researchers or other companies that
would like to develop seeds for smaller markets. A similar restriction may occur when university
scientists patent genetic material that becomes essential for development of GE crops by other
university scientists. Thus, the mechanism that generated the incentives to develop and
commercialize genetic engineering may limit its applicability to most crops (Alston, 2004). The
influence of IPR on the commercialization of genetically engineered crops will be discussed
further in Chapter 4.
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Marketing decisions are also influenced by perceived consumer acceptance of GE products.
If technology providers have reason to believe that a GE crop will not be purchased by
consumers, the technology will not be commercialized regardless of the potential benefits of the
technology to producers. Indeed, a product may even be decommercialized if consumer
avoidance, or the fear of it, is high enough. For example, consumer concerns and competing
pest-control products caused the GE potato to be discontinued (see Box 1-2). The perceived
potential loss of markets has also postponed the commercial iziation of GE wheat (this is covered
further in Chapter 4). Consumers appear to be more accepting of products that are further
removed from direct consumption, although additional research is needed in this regard (Tenbult
et al., 2008). Thus, companies have been more willing to invest in com and soybean, which are
used primarily for animal feed and processed products, and cotton, a fiber crop. Even though
wheat and rice are grains (like com), are widely planted, and have a considerable storage life,
their proximity to the consumer in the food supply chain has contributed to additional pressures
on the private sector, which may explain finns’ wariness to introduce genetic-engineering
technology into them (Wisner, 2006).
Resistance to Genetic-Engineering Technology in Organic Agriculture
As outlined above, genetic-engineering technology is not available to farmers of most crops.
However, some producers have chosen not to adopt the technology regardless of its accessibility.
That attitude is typified by organic production in the United States.
As American agricultural practices incorporated greater use of synthetic chemicals in the
i950s and 1960s, organic production gained popularity as an alternative farming system. By the
1980s, the organic movement was large enough to justify the establishment of national
certification standards. The proliferation of standards, inconsistency in labeling, difficulty in
marketing, and inability to police violators of standards prompted organic groups to push for
passage of the Organic Foods Production Act (OFPA) of 1990 (Rowson, 1998). The OFPA
authorized a National Organic Program (NOP) in the U.S. Department of Agriculture (USDA) to
define organic farming practices and acceptable inputs. The act established an advisory group,
the National Organic Standards Board (NOSB), to provide recommendations to USDA on the
structure and guidelines of the NOP. The NOSB viewed GE organisms as inconsistent with the
principles of organic agriculture and recommended their exclusion (Vos, 2000). Opponents of
genetic-engineering technology in organic production raised concerns about food safety and
environmental effects. They also argued that organic agriculture is based on a set of values that
places a high priority on “naturalness” (Verhoog et al., 2003), a criterion that in their view
genetic engineering did not meet.
The proposed rule that was issued in 1997 deemed GE seeds permissible in organic
agriculture; subsequently, USDA received a record number of public comments, almost entirely
in objection to the proposal (Rowson, 1998). In response to the opposition, USDA rewrote the
standards. When the NOP final rule went into effect in 2001, GE plants were not considered to
be compliant with standards of organic agriculture (Johnson, 2008).
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FROM ADOPTION TO IMPACT
The assessment framework d^cribed earlier in this chapter spans all the qualitative
dimensions necessary to evaluate the potential sustainability of genetic-engineering technology.
Therefore, this report’s structure covers environmental, economic, and social changes, and the
following chapters report progress and conclusions in these realms.
Environmental Effects
The landscape-level environmental effects of GE crops, both potential improvements and
risks, did not receive extensive study when such crops were first planted widely (Wolfenbarger
and Phifer, 2000; Ervin et al., 2001; Marvier, 2002). Since then, many studies on nontarget
effects, including further studies requested by the U.S. Environmental Protection Agency, have
accumulated. Other studies and analyses have related adoption of GE crops to changes in
pesticide regimens and tillage practices. However, longitudinal data are still needed to better
understand the effects of changes in farm management on environmental sustainability, such as
on water quality or on resistance to glyphosate in weeds. Comprehensive evidence on other
environmental dimensions — such as some aspects of soil quality, biodiversity, water quality and
quantity, and air-quality effects — is also sparse. The environmental effects of farmers’ adoption
of genetic-engineering technology are discussed in Chapter 2.
Economic Effects
The economic effects of genetic-engineering technology in agriculture, which are addressed
in Chapter 3, stem from effects on crop yields; the market returns received for the products;
reductions or increases in production inputs and their prices, such as the costs of GE seeds and
pesticides; and such other effects as labor savings that permit more off-farm work or that result
in changes in yield risk. Those effects have received considerable study, particularly in the early
stages of adoption of GE crops. However, recent information is sparse even though new GE
varieties continue to be introduced. Less farm-level economic analysis has been conducted,
perhaps because of the near dominance of the technologies in soybean, cotton, and corn
production, because serious production or environmental problems have not surfaced, and
because there is less interest for conducting additional research in a well-studied arena. More
extensive studies of some economic effects, such as those on yield, have been conducted more
recently in developing countries than in mature markets such as the United States.
Social Effects
The social effects of the adoption or nonadoption of genetic-engineering technology have not
been studied as extensively as those attributed to previous waves of technological development
in agriculture, even though earlier studies demonstrated that revolutionary agricultural
technologies generally have substantial impacts at the farm or community level (Berardi, 1981;
DuPuis and Geisler, 1988; Butte! et al., 1990) and that there was a high expectation that genetic-
engineering technology would also have substantive and varied social impacts (Pimentel et al.,
1989). It is thus surprising that there has been relatively little research on the ethical and
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socioeconomic effects of the adoption of agricultural biotechnology at the farm or community
level (e.g., Buttel, 2005). A few studies have explored the economic effects of structural changes
(integration and concentration) in the seed and agrichemical industries (Hayenga, 1998; Brennan
et al, 2000; Fulton and Giannakas, 2001; Femandez-Comejo and Schimmelpfennig, 2004;
Femandez-Comejo and Just, 2007). However, though the issue of how farmers might be socially
impacted by the increasing integration of seed and chemical companies was first raised more
than 20 years ago (Hansen et al., 1986), the organizations responsible for conducting or
sponsoring research on the effects of genetic-engineering technology have generally fallen short
of promoting the comprehensive and rigorous assessment of the possible social and ethical
effects of GE-crop adoption. That responsibility rests not only with federal agencies (Kinchy et
al., 2008) but with state governments, universities, nongovernment organizations, and the private
for-profit sector. The absence of such research reduces our ability to document what the effects
of the adoption of genetic-engineering technology have been on farm numbers and structure,
community socioeconomic development, and the health and well-being of farm managers, family
members, and hired farm laborers. A particularly significant question that has not been
adequately assessed is whether the adoption of GE crops has exacerbated, alleviated, or had a
neutral effect on the steady decline of farm numbers and the vitality of rural communities often
associated with the industrialization of U.S. agricultural production. Because of the comparative
dearth of empirical research findings on the social impacts of GE-crop adoption in the United
States, we offer in Chapter 4 a discussion of the potential effects of the introduction of genetic-
engineering technologies on farming-system dynamics in the form of testable hypotheses and
piece together the ancillary literature on documented social effects, such as legal disputes.
CONCLUSION
Genetic-engineering technology has been built on centuries of plant-breeding experiments,
research, and technology development. Commercialized applications have focused on pest
management, primarily through resistance to the herbicide glyphosate and the incorporation of
endotoxins that are lethal to some insect pests. Those traits have provided farmers of soybean,
com, and cotton additional tools for combating pests. The popularity of GE crops is evidenced
by their widespread adoption by farmers. In the following three chapters, we examine how their
adoption has changed or reinforced farming practices and what implications the changes have for
environmental, economic, and social sustainability at the farm level. At the close, we identify
remaining challenges and opportunities for GE crops in the United States and draw conclusions
and recommendations for increasing their contributions to farm sustainability.
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Vos, T. 2000. Visions of the middle landscape: Organic farming and the politics of nature.
Agriculture and Human Values 17(3):245-256.
Weise, E. 2007. Effects of genetically engineered alfalfa cultivate a debate. USA Today,
February 15. p. lOD, Life section. Available online at http://www.usatoday.com/
news/heaIth/2007-02- 14-alfalfa_x.htm. Accessed June 4, 2009.
Wiesbrook, M.L., W.G. Johnson, S.E. Hart, P.R. Bradley, and L.M. Wax. 2001. Comparison of
weed management systems in narrow-row, glyphosate- and glufosinate-resistant soybean
{Glycine max). Weed Technology 15(1):!22— 128.
Wisner, R. 2006, Potential market impacts from commercializing Round-Up Ready® wheat.
September. Western Organization of Resource Councils. Update ed. Billings, MT.
Available online at http://www.worc.org/userfiles/file/Wisner-Market%20Risks-Update-
2006.pdf, Accessed July 5, 2009.
Wolf, S.A., D.R. Just, and D, Zilberman. 2001. Between data and decisions: The organization of
agricultural economic information systems. Research Policy 30(1):121-141.
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2
Environmental Impacts of Genetically Engineered Crops at the
Farm Level
The environmental impacts of planting genetically engineered (GE) crops occur within the
context of agriculture’s general contribution to environmental change. Agriculture has
historically converted biologically diverse natural grasslands, wetlands, and native forests into
less diverse agroecosystems to produce food, feed, and fiber. Effects on the environment depend
on the intensity of cultivation over time and space; the inputs applied, including water, fertilizer,
and pesticides; and the management of inputs, crop residue, and tillage. With 18 percent of the
land area in the United States planted to crops and another 26 percent devoted to pastures (FAO,
2008), the huge scale of these impacts becomes obvious. In general, tillage, crop monoculture,
fertilizers, and pesticide use often have adverse effects on soil, water, and biodiversity.
Agriculture is the leading cause of water-quality impairment in the United States (USDA-ERS,
2006). No-tiilage systems, crop rotations, integrated pest management, and other
environmentally friendly management practices may ameliorate some of the adverse impacts, but
the tradeoff between agricultural production and the environment remains. With agricultural
lands approaching 50 percent of U.S. land, developing more ecologically and environmentally
sound agricultural management practices for crops, soil, and water is a central challenge for the
future (Hanson et al, 2008). Against that backdrop, we evaluate the impact of GE crops on the
environmental sustainability of U.S. farms.
This chapter examines the changes in farm practices that have accompanied the adoption of
GE crops and the evidence on how such adoption affects the environment, it addresses impacts at
the individual farm level and also at the landscape level, given that impacts from individual
farms accumulate and affect other farms and their access to communal natural resources in the
region. The use of GE crops has altered farmers’ agronomic practices, such as tillage, herbicides,
and insecticides; these alterations have implications for environmental sustainability both on and
off the farm, which are evaluated to the extent possible at this point in time (Box 2-1). In
particular, we examine the effects of the adoption of GE crops on soil quality, biodiversity, and
water quality.
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BOX 2>1
Limitations to Evaluating the Magnitude of Environmontai Effeuti
Although environmental risk assessment is conducted for ati GE vaneties before regulatory
approval, m some cases, the absehce of ensrironirientai monitoring at the landscape level
prevents calculating the magnitude of eiTects (e.g., Water quality) following commercialization
Where monitoring data on agncuttuiet predtces aier Svailable (e g., tillage practices, pesticide
use), simple correlations of the adoption rates wdth .trends^in agricultural practices do not capture
the complexity required to quanti^ the magnitude of any environmental effect The lack of
spatially-explicit data linking the use of GE crops- wte data-monilormg agncultural practices
stymies any accurate calculation of the ma^wtude of environmental effects at national or even
regional levels (NRG, 2002). Envifonmentai (^hsequ^ces of agnculturat practices can vary
greatly at a sub-regionat scale. For example> the adoption of a herbicide-resistant crop may
facilitate use of no-til! practices, but the amrironmentei effects of no-ti!l practices depend on
existing soil texture, structure, and erosion potential fix' each Individual farm Though models may
exist to quantify soil retention given erosion poterjtiai, 'what amount of retention can be attributed
to HR crops requires two additional calculations: ^ ■
1 Quantifying ffwhat extent HR cr^ caused the adt^jtfpi^ conservation tillage practices,
given that tt« is a two-way reiat^ship, and
2;:i; Spatially lin® the ^option of crops with data on the occ irrence. of Highly- ErodibJe
Land. some^% not feasible wfthM spatial|y-expA^^ H
l^nd pest control measures fluctuate year and crop to crop as
W active ingredients. Detennlning ' » extent to wh c" adc^tio®':of GE crops
esticides over time requires incorpo' suite of factors SuCh as charges
ir pest-management, strategies {e«g.. see^’tootnote ccH Aeevil erad cation
ractices, technology, and public p( i (eg pesticide equlation qoverin-T
dez-Cornejo et.al:, 2009). SpatF:ii d i**® oh the evolution af weed^rstan^ are
preventing any. calcuiation of envircnmefttar consequence of the Jeciiring
'phosate with glyphos^e^resistant crop^t » v
ENVIRONMENTAL IMPACTS OF HERBICIDE-RESISTANT CROPS
The adoption of herbicide-resistant (MR) crops has affected the types and number of
herbicides and the amount of active ingredient applied to soybean, corn, and cotton. This section
first examines the substitution of glyphosate for other herbicides that has taken place and how
the use of HR crops has interacted with tillage practices. It then assesses ecological etYects of
those changes on soil quality, water quality, arthropod biodiversity, and weed communities.
Lastly, the implications for weed management in cropping systems with HR crops are
considered, especially for systems in which giyphosate-resistant weeds evolve.
Herbicide Substitution
A higher proportion of herbicide-resistant GE soybean has been planted than of any other GE
crop in the United Stales. Adoption has exceeded 90 percent of the acres planted to soybean by
U.S. farmers (Figure 2-1). HR cotton acreage reached 71 percent in 2009 (Figure 2-2), while
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planted HR corn acres were 68 percent that year (Figure 2-3). The HR crops planted thus far
have altered the mix of herbicides used in cropping systems and allowed the sub.stitution of
glyphosate for other herbicides. Figures 2-1 through 2-3 summarize the trends in the use of
glyphosate and other herbicides on com, soybean, and cotton (expressed in pounds per planted
acre of these crops) and the adoption of HR com, soybean, and cotton (Fernandez-Cornejo et al.,
2009). It is important to recognize that, depending on the metrics used, the substitution of
glyphosate for other herbicides has resulted in the use of fewer alternative herbicides by growers
of HR crops. However, glyphosate is often applied in higher doses and with greater frequency
than the herbicides it replaced. Thus, the actual amount of active ingredients (glyphosate and
other herbicides) applied per acre actually increased from 1996 to 2007 in soybean (Figure 2-1)
and cotton (Figure 2-2) but decreased over the same period in corn (Figure 2-3).
Glyphosate is reported to be more environmentally benign than the herbicides that it has
replaced (Fernandez-Cornejo and McBride, 2002: Cerdeira and Duke, 2006). It binds to soil
rapidly (preventing leaching), it is biodegraded by soil bacteria, and it has a very low toxicity to
mammals, birds, and fish (Malik et al., 1989). Glyphosate can be detected in the soil for a
relatively short period of time compared to many other herbicides, but is essentially biologically
unavailable (Wauchope et al., 1992). Formulations that contain the surfactant polyoxyethylene
amine can be toxic to some amphibians at environmentally-expected concentrations and may
affect aquatic organisms under some environmental conditions (Folmar et a!., 1979; Tsui and
Chu, 2003; Relyea and Jones, 2009); however, these formulations are labeled for terrestrial uses
only with restrictions with respect to waterways. The greater use of postemergence glyphosate
applications has been accompanied by modifications of agronomic practices, particularly with
regards to weed management and tillage. The interactions of those practices have implications
for environmental sustainability.
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— A — Giyphosate — — Other herbicides - -a- - Percent acres HR
FIGURE 2-1 Application of herbicide to soybean and percentage of acres of herbicide-resistant
soybean.
NOTE: The strong correlation between the rising percentage of herbicide-resistant (HR) soybean
acres planted over time, the increased applications of giyphosate, and the decreased use of other
herbicides suggests but does not confirm causation between these variables.
SOURCES: USDA-NASS. 2001; 2003, 2005, 2007, 2009a, b; Fernandez-Comejo et al., 2009.
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40
20
0
— ■ — Glyphosate — □ — Other herbicides - -o - Percent acres HR
FIGURE 2-2 Application of herbicide to cotton and percentage of acres of herbicide-resistant
cotton.
NOTE: The strong correlation between the rising percentage of herbicide-resistant (HR) cotton
acres planted over time, the Increased applications of glyphosate, and the decreased use of other
herbicides suggests but does not confirm causation between these variables.
SOURCES: USDA-NASS, 2001 ; 2003, 2005, 2007, 2009a, b; Femandez-Comejo et al., 2009.
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FIGURE 2-3 Application ofherbiclde to com and percentage of herbicide-resistant corn.
NOTE: The strong correlation between the rising percentage of herbicide-resistant (HR) com
acres planted over time, the increased applications of glyphosate, and the decreased use of other
herbicides suggests but does not confirm causation between these variables.
SOURCES: USDA-NASS. 2001 : 2003, 2005, 2007. 2009a, b; Femandez-Cornejo et al., 2009.
Tillage Practices
Tillage is one process used by farmers to prepare the soil before planting. In conventional
tillage, all poslharvest residue is plowed into the soil to prepare a clean seedbed for planting and
to reduce the growth of weeds; in conservation Ullage, at least 30 percent of the soil surface is
left covered with crop residue after planting. In the 1970s and 1980s, innovations in cultivators
and seeders enabled fanners to plant seeds at a reasonable cost with residue remaining on the
field. Those developments encouraged the adoption of one fonn of conservation tillage called
no-till, in which the soil and surface residue from the previously harvested crop are left
undisturbed as the next crop is seeded directly into the soil without tillage. After soil-
conservation policy was Incorporated into the Food Security Act of 1985, conservation tillage
accelerated in the 1990s (Figure 2-4). The introduction of HR soybean and cotton has supported
the trend because the use of glyphosate allowed weeds to be controlled after crop emergence
without the need for tillage to disrupt weed development before or after planting. Indeed, in the
last 10 years, the use of conservation tillage has continued to increase, with the exception that it
has remained constant in the case of com (Figure 2-4). *
The adoption of conservation tillage practices by U.S. soybean growers increased from 5i
percent of planted acres in 1996 to 63 percent in 2008 (Figure 2-4), or an addition of 12 million
‘More information on difTerent types of till^e systems can be found in Appendix B.
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acres. The adoption of no-till practices accounted for most of the increase and was used on 85
percent of these additional 12 million acres. Over the same lime period, the acreage planted to
soybean increased at most nine million acres. In cotton there was a doubling of the percentage of
acres managed using conser\'ation tillage from 1996 to 2008. and no-till is the predominant
conservation tillage practice (Figure 2-4). Cotton acreage declined over the same lime period.
For corn between 1 996 and 2008. an additional 4.8 million acres of corn were planted. At the
same time, the use of conservation tillage practices remained at a fairly constant 40 percent of
planted acreage (Figure 2-4). No-till practices increa.sed by 4 percent over the same lime period
(4.3 million acres) but this was disproportionate relative to overall increases in conservation
tillage practices (1. 9 million acres), indicating that farmers converted from other conservation
tillage practices to no-till.
According to IJ.S. Department of Agriculture (IISDA) survey data for I997. a larger share of
acreages planted to MR soybean was managed with con.servation tillage than was planted to
conventional soybean (Fernandez-Comejo and McBride. 2002) — about 60 percent versus about
40 percent (Figure 2-5). fhe difference in the use of no-lill between adopters and nonadoplers of
FIR soybean was even more pronounced: 40 percent of acres planted with MR soybean were
under no-lili. double the corresponding share of acres of non-CE soybean under no-lill
management practices (I'ernandez-Cornejo and McBride. 2002).
From the perspective of fan7K'r decision-making, the availability of MR technology may
affect the adoption of consenation tillage, and the use of conservation tillage may affect the
decision to adopt HR crops. Several economists have tried to understand how closely the two
decisions arc linked. An econometric model developed to address the simultaneous nature of the
decisions was used to determine the nature of the relationship between the adoption of GE crops
with FIR traits and no-till practices on the basis of 1997 national survey data on soybean farmers
(Fernandez-Cornejo el al., 2003). Farmers using no-till were found to have a higher probability
of adopting HR cullivars than farmers using conventional tillage, but using HR cultivars did not
significantly affect no-till adopti<ai. That result suggested that farmers already using no-liil
incorporated HR cultivars seamlessly into their weed-management program; but the
commercialization of HR soybean did not seem to encourage the adoption of no-till. al least at
the time of the survey.
More recently, however. Mensah (2007) found a two-way causal relationship on the basis of
more recent data. Using a simultaneous-adoption model and 2002 survey data on soybean
farmers, Mensah found that fai-mcrs who adopted no-till were more likely to adopt HR soybeans
and that farmers who adopted the HR technology were more likely to adopt no-lill practices.
In the case of cotton, the evidence also points tow^ard a two-way causal relationship. Roberts
et al. (2006) evaluated the relationship between adoption of HR cotton and conservation tillage
practices in Tennessee from 1992 to 2004. Using two methods," they found that the adoption of
HR cotton increased the probability that farmers would adopt conservation tillage and conversely
that farmers that had previously adopted conservation tillage practices were more likely to adopt
HR cotton. Thus, the adoption of no-lill practices and the adoption of FIR cotton are
complementary practices.
V‘\n application o!' Bayes's theorem and a two-equation logit model.
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Consenetion >30% residue [1^31:137111396 leaving < 30% residue
— X— No-till . - . o HR soybeans
mn Conservation tillage: 230% residue r"— -j Tillage leaving < 30% residue
— X— No-til! I o I HR cotton
ConservatiCHt tillage: 233% residue Tillage leaving < 30% residue
—X— No-till ■ ■ ' O HR corn
FIGURE 2-4 Trends in conservation tillage practices and no-till for soybean, com and cotton,
and adoption of herbicide-resistant crops since their introduction time in 1996.
SOURCE: C TIC, 2009; USDA-ERS, 2009.
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Herbicide-resistant Conventional varieties
varieties
u:! Conventional tillage
m other conservation
tillage
sS No till
FIGURE 2-5 Soybean acreage under conservation tillage and no-till, 1997.
SOURCE: Adapted from Femandez-Cornejo and McBride, 2002.
Kaiaizandonakes and Suntompithug (2003) also studied the simultaneous adoption of HR
and stacked cotton varieties and conservation tillage practices on the basis of farm-level data.
They concluded that conservation tillage practices both encouraged the adoption of HR and
stacked cotton varieties and were encouraged by their adoption. Using state-level data for 1997-
2002 and using a simultaneous-equation econometric model, Frisvold et al. (2007) studied the
diffusion of HR cotton and conservation tillage. They found strong complementarity between the
two practices and rejected the null hypothesis that the diffusion of one is independent of the
diffusion of the other. They also observed that an increase in the probability of adoption of HR
cotton increased the probability of adoption of conservation tillage and vice versa.
Thus, most empirical evidence points to a two-way causal relationship between the adoption
of HR crops and conservation tillage.^ Farmers using conservation tillage practices are more
likely to adopt HR crop varieties than those using conventional tillage, and those adopting HR
crop varieties are more likely to change to conservation tillage practices than those who use non-
HR cultivars. The analytical techniques used do not reveal the relative strength of each causal
linkage, so it is not clear which factor (adoption of HR varieties or use of conservation tillage)
has a greater influence on the other.
Soil Quality
The relationship between the adoption of conservation tillage practices and the adoption of
HR crops is relevant to farm sustainability because conservation tillage has fewer adverse
environmental impacts than conventional tillage (reviewed by Uri et al., 1999). On the farm,
conservation tillage reduces soil loss from erosion, increases water infiltration, and can improve
'Most published evidence i.s for the cases of soybean and cotton given that extensive adoption of HR corn
is relatively more recent (HR com adoption only exceeded 20 percent of com acreage in 2005).
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soil quality and moisture retention (reviewed by Uri et al, 1999; Holland, 2004). Com and
soybean are grown in regions where highly erodible land is common, and conversion to
conservation tillage for these crops results in substantial reduction in soil loss and wind erosion
even on non-highly erodible land (Uri et al., 1999). Leaving more crop residue on fields
strengthens nutrient cycling and increases soil organic matter, a key component of soil quality
(reviewed by Blanco-Canqui and Lai, 2009). Soil organisms decompose plant residue, and this,
in turn, cycles nutrients and improves soil structure. In general, soil organisms have greater
abundance or biomass in no-till systems than in conventional tillage systems because soil is
disturbed less (reviewed by Wardle, 1995; Kladivko, 2001 ; Liebig et al., 2004).
In addition to tillage, the use of herbicides can affect soil quality through their impact on soil
organisms, so interpreting the effects of HR crops on soil quality requires an undei^tanding of
how tillage practices interact with herbicide use to influence the soil microorganism community.
In laboratory studies, glyphosate can inhibit or stimulate microbial activity, depending on soil
type and glyphosate formulation (Carlisle and Trevors, 1986, and references therein). Some
microorganisms can use glyphosate as a substrate for metabolism (increased activity); whereas
others are susceptible to the herbicide because they have an enzyme 5-enolpyruvyi-shikimate-3-
phosphate synthase pathway that glyphosate inhibits. When species-level responses were
measured, roots of glyphosate-resistant soybean and com treated with glyphosate had
significantly more colonies of the fungus Fusarium than did non-HR cultivars or HR cultivars
not treated with glyphosate (Kremer and Means, 2009). In contrast, fluorescent Pseudomonas
populations, an antagonist of fungal pathogens like Fusarium, were significantly lower in
soybean that were both glyphosate resistant and treated with glyphosate compared to untreated
HR cultivars or a non-HR cuitivar treated with other herbicides (Kremer and Means, 2009).
Those results indicate a change In the antagonistic relationship between Fusarium and
Pseudomonas attributable to the formulation of glyphosate used. Whether magnitude of change
in this antagonistic relationship would have consequences on soil quality of disease control was
not a part of the study.
With respect to general microbial activity, three studies in the United States have detected no
uniform changes in soil organism profiles in association with tillage or with the use of
glyphosate on glyphosate-resistant cropping systems (Liphadzi et al., 2005; Weaver et al., 2007;
Locke et al, 2008). Soil microorganisms in fields planted with glyphosate-resistant com and
soybean varieties were similar with and without tillage (Liphadzi et al, 2005). HR fields treated
with glyphosate and non-GE fields treated with other herbicides were also similar in soil microbe
activity (Liphadzi et al, 2005). On tilled, experimental plots of glyphosate-resistant soybean,
transient changes in the soil microbial community were detected in the first few days after
application of glyphosate compared to no application (Weaver et al, 2007), but the differences
disappeared after 7 days. When there was continuous cotton cropping, soil quality did not differ
between HR and non-HR systems. In contrast, soil under continuous HR-com cropping
contained more carbon and nitrogen than soil with non-HR com (Locke et al, 2008), which
would be considered a benign change. Differences in carbon and nitrogen contents could have
been due to glyphosate use, but they were also probably influenced by changes in the detrital
food web associated with the higher biomass of winter weeds in the HR-com cropping system
(Locke et al, 2008). Subtle differences in the structure of the soil microbial community were
also detectable in those same exj^riments; the significance of the differences for soil quality
were not discussed. Thus, species-level studies suggest that glyphosate can alter the microbial
composition in the rhizosphere. General studies of the interaction of tillage and glyphosate use in
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HR crops have indicated transient benign effects of glyphosate and neutral, or in one case
favorable, effects of conservation tillage on the soil communities in HR crops.
Water Quality
Conservation tillage practices can have off-farm benefits for water quality that are potentially
more important than onsite productivity effects (Foster and Dabney, 1995). Because
conservation tillage practices improve soil-water infiltration, the volume of runoff is less than
when conventional tillage is used. Reduced tillage and no-till practices can improve water quality
by reducing the amounts of sediments and sediment-associated chemicals in runoff from farm
fields into surface water. Similarly, lower volumes of runoff can decrease the transport of soil
nutrients and agricultural inputs, such as fertilizers and pesticides, although the decrease will
vary with soil type, tillage practice, and nutrient or pesticide input. For example, although the
concentration of herbicide in runoff from no-till fields can be higher than when other
conservation tillage practices are used, the total amount of herbicide in runoff may be similar
because runoff volume is reduced (Fawcett et al., 1994; Locke and Bryson, 1997; Mickelson et
ah, 2001; Shipitalo and Owens, 2006; Zeimen et aL, 2006). That phenomenon has been observed
with the use of glyphosate in no-til! fields (Shipitalo et al., 2008).
Studies have suggested that the use of glyphosate poses less risk to water quality than the use
of other herbicides; this is attributable in part to the production systems typically used in GE
crops and to the physical chemistry and relatively low toxicity of glyphosate (Estes et al., 2001;
Wauchope et al., 2002; Peterson and Hulling, 2004). However, there are no regional-scale
analyses of the effects of HR-crop adoption on water quality. One study conducted in a small
Ohio watershed that compared herbicide runoff in HR and non-HR soybean fields found that the
amount of glyphosate in the runoff was nearly one-seventh that of the herbicide metribuzin and
about half that of alachlor, even though glyphosate was applied to soybean twice and alachlor
and metribuzin once to soybean (Shipitalo et al., 2008). Those results are consistent with known
characteristics of glyphosate, which strongly absorbs to soil and has a half-life in soil of 6-60
days, depending on soil characteristics. Microbial processes degrade glyphosate into two
metabolites: sarcosine and aminomelhylphosphonic acid (AMP A). Sarcosine degrades quickly to
carbon dioxide and ammonia. AMPA is more persistent than glyphosate in the soil environment
but is considered equally or less toxic (reviewed by Giesy et al., 2000). Numerous studies have
documented the occurrence of glyphosate and AMPA in surface waters (Kolpin et ah, 2006), but
they have rarely been found in groundwater (Borggaard and Gimsing, 2008). Concentrations of
glyphosate reported in surface water have not exceeded the maximum contaminant level (MCL)
for drinking water set by the U.S. Environmental Protection Agency (EPA); in accordance with
World Health Organization recommendations, MCLs have not been set for AMPA (WHO,
2005).
Shifts to conservation tillage attributable to the availability of HR crops have contributed to
reductions in soil loss and probably in herbicide runoff. The magnitude and spatial distribution of
the benefits is not precisely known, but the implications are that those are important
environmental benefits of these cropping systems. However, as discussed later in this chapter
(see “Other Shifts in Weed Communities”), some of the environmental benefits may be
threatened in the future.
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Arthropod Biodivereity
Changes in herbicide use and tillage practices like those accompanying the adoption of HR
crops can affect such organisms as natural enemies of pests or pollinators, which provide
ecological services to agriculture. Weeds provide an ecological disservice to farms by competing
with crop plants for nutrients and light even at low population densities, but weeds can also
support a broad array of nonpest species. Pollinators feed on nectar or use some weeds as hosts
for their larval stage; weed species can be food for herbivores that in turn are preyed on by
predators that also control pests of crops. In particular, more effective weed management could
decrease the abundance of beneficial organisms, depending on the mobility of a species and how
closely its resource base is associated with weed abundance. In contrast, the increase in no-till
practices that leave more plant material undisturbed in fields may increase the resource base for
beneficial insects.
Evidence indicates that the planting of HR cultivars does not consistently affect the weed
diversity and abundance that support beneficial species. Whether a farmer used a GE crop or a
conventional crop, better weed control has generally reduced the numbers of arthropods and
other organisms in com, sugar beet, and rapeseed fields (Hawes et al., 2003) and decreased the
abundance of the predatory big-eyed bug (Geocoris punctipes) in soybean fields (Jackson et al.,
2003; Jackson and Pitre, 2004). When HR crops improved weed management (decreased weeds),
populations of natural enemies and pollinators decreased (Hawes et al., 2003). When
conventional weed-management tactics (such as the use of the herbicide atrazine) were more
effective at weed control on non-HR com relative to HR com, beneficial insect abundance was
greater within the HR side of the field where more weeds occurred (Hawes et al., 2003).
Subsequent analyses of these same data in more depth have revealed detailed associations
between properties of the weed community and the accompanying arthropod food web (Hawes et
al., 2009) and strengthened the conclusion that weed management accounts for the relationships
observed. However, weed management was not the largest influence on the abundance of
beneficial organisms. Rather, there were differences of a factor of 3-10 in abundance among
different crops and between early and late in the growing season, compared with differences of a
factor of 2 associated with weed management (Hawes et al., 2003).
Weed Biodiversity and Weed Shifts
Crop-production practices inevitably influence the composition of the weed community.
Typically, only a few weed species are economically important in a particular crop-production
system (Owen, 2001; Tuesca et al., 2001). When a production practice changes, for example, a
change in herbicide, it may ultimately select for weed biotypes that are resistant to that herbicide
(Baker, 1991). Other elements of production practices that have selective effects on the weed
community include harvesting techniques, irrigation, fertilization, planting dates, soil
amendments, and tillage (Hilgenfeld et al., 2004; Murphy and Lemerle, 2006; Owen, 2008).
The stronger the selective force of those practices (e.g., the level of disturbance caused by
tillage), the more consistent the selective force (e.g., continuous planting of the same crop as
opposed to annual crop rotations), and the simpler the selective force (e.g., the recurrent use of
one herbicide), the greater the effect on the composition of the weed community (Owen, 2001).
Changes in the kinds of weeds that are important locally are termed weed shifts (which implies
changes in weed species composition) (Givnish, 2001); in the following discussion, weed shifts
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are the ecological process by which an initial weed community is replaced by a new community,
including better-adapted species, in response to changes in agricultural practices. Weed shifts are
generally followed by a period of stability, given the longevity of weed seeds in the soil, as long
as the agricultural systems that resulted in the shift remain constant (Buhler, 1992; Buhler et a!.,
1997). They are a common and inevitable result of agriculture and are not unique to the adoption
of HR crops, but it is essential to understand and manage them well if agriculture is to be
productive and sustainable. Such shifts are particularly relevant for managing weeds in HR-crop
systems, in which tillage practices and herbicide use both play major roles in shaping the weed
community.
Herbicide Resistance in Weeds
The International Survey of Herbicide Resistant Weeds (ISHRW) provides a historical
account and extensive list of weeds that have evolved resistance to herbicides (Heap, 2010).
Although the ISHRW reflects the efforts of many weed scientists in reporting weed populations
that have herbicide resistance, the voluntary basis of the contributions likely results in
underestimation of the extent of resistance to herbicides, including glyphosale. The evolution of
herbicide-resistant weeds is not unique to the herbicides for which HR traits exist. Currently, 195
species (115 dicots and 80 monocots) have evolved resistance to at least one of 19 herbicide
mechanisms of action in at least 347 herbicide-resistant weed biotypes distributed over 340,000
fields (Heap, 2010).
Glyphosate, first commercialized in 1974, has been extensively used for weed control in
perennial crops (fruits, trees, nuts, and vines), along roadsides and irrigation canal banks, and in
urban areas and national parks (Powles, 2008). The first case of evolved resistance to glyphosate
was reported in 1996 in rigid ryegrass {Lolium rigidum) (Powles et al., 1998). The glyphosate-
resistant population originated in an orchard in a large winter cropping region of southern
Australia, where glyphosate had been used intensively for the control of rigid ryegrass for more
than 15 years. Since the initial report, at least six other weed species have been reported as
resistant to glyphosale in environments where glyphosate-resistant crops were not planted
(Powles, 2008; Heap, 2010).
Emergence of Glyphosate-Resistant Weeds In Herbicide-Resistant Crop Fields
Eight or nine species have evolved resistance to glyphosate independently in glyphosate-
resistant crops over 13 years in the United States (from 1996 to 2009) (Heap, 2010). Gene flow
between HR crops and closely related weed species does not explain the evolution of glyphosate
resistance in U.S. fields because sexually compatible weeds are absent where com, cotton, and
soybean are grown in the United States. However, the nearly exclusive reliance on glyphosate for
weed control, a practice accelerated by the widespread introduction of glyphosate-resistant crop
varieties, has caused substantial changes in weed communities. The first report of glyphosate
resistance associated with a GE glyphosate-resistant crop involved horseweed {Conyza
canadensis) in Delaware (VanGessel, 2001); once resistance evolved, growers found it difficult
to control this weed in no-till glyphosate-resistant soybean (VanGessel, 2001). Since the initial
report in 2000, glyphosate-resistant populations of horseweed have been documented throughout
the Mid-Atlantic, Mid-South, Mississippi Delta, and Midwest states (Heap, 2010). The weed
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grows particularly well in no-till production systems, producing a large number of wind-carried
seeds that are dispersed over long distances (Buhler and Owen, 1 997; Ozinga et al, 2004).
Subsequent to that discovery in 2000, odier weed species have evolved resistance to
giyphosate in glyphosate-resistant crops in the United States (Table 2-1). They include two
species of pigweed, Palmer amaranth {Amaranthus palmeri) and waterhemp {Amaranthm
tuberculatm), which have become economically important in glyphosate-resistant cotton and
soybean production (Zelaya and Owen, 2000, 2002; Culpepper, 2006; Culpepper and York,
2007; Legleiter and Bradley, 2008). Infested areas are increasing rapidly in the Southeast, the
Mississippi Delta (Palmer amaranth and Johnsongrass, Sorghum halepense), and the Midwest
(waterhemp) (Culpepper and York, 2007; Legleiter and Bradley, 2008). Glyphosate-resistant
populations of giant ragweed {Ambrosia trifida) have been reported in several states (Leer,
2006), primarily in or adjacent to glyphosate-resistant soybean. Kochia {Kochia scoparia) with
evolved resistance to giyphosate has recently been identified in Kansas (Heap, 2010). Another
weed, common lambsquarters {Chenopodium album) (Kniss et al., 2004, 2005; Schuster et al.,
2007; Scursoni et al., 2007) may have also evolved glyphosate-resistant biotypes (Boerboom,
2005), but it has not yet appeared on the ISHRW list.
TABLE 2-1 Weeds That Evolved Resistance to Giyphosate in Glyphosate-Resistant Crops in
the United States
Species
Crop
Location
Acreage*
Amaranthus palmeri
Com, cotton.
Georgia, North Carolina,
200,000-2,000,000
(Palmer amaranth)
soybean
Arkansas, Tennessee, Mississippi
Amaranthus Iuberculatus
(waterhemp)
Com, soybean
Missouri, Illinois, Kaitsas,
Minnesota
1,200-11,000
Ambrosia artemisiifoUa
(common ragweed)
Soybean
Arkansas, Missouri, Kansas
<150
Ambrosia trifida
(giant ragweed)
Cotton, soybean
Ohio, Arkansas, Indiana, Kansas,
Minnesota, Tennessee
2,000-12,000
Conyza canadensis
(horseweed)
Com, cotton,
soybean
14 states
> 2,000,000
Kochia scoparia
(kochia)
Com, soybean
Kansas
51-100
Lolium muUiflorum
(Italian lyegrass)
Cotton, soybean
Mississippi
1000-10,000
Sorghum halepense
(Johnsonerass)
Soybean
Arkansas
Unknown
‘’Minimum and maximum acreages are based on expert judgments provided for each state. The
estimates were summed and rounded to provide an assessment of the minimum and maximum acreages in
the United States. These values indicate orders of magnitudes but do not provide precise information on
abundance of resistant weeds.
SOURCE; Data from Heap, 2010.
‘‘in some literature, Amaranthus iuberculatus is referred to as Amaranthus rudis.
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Other Shifts in Weed Communities
Factors other than the evolution of giyphosate resistance affect the composition of weed
species in the field. Changes in the tillage system used in growing HR crops are probably the
most important factor in promoting weed shifts because disturbance is a primary selective force
(Buhler, 1992). In addition, weeds diat escape giyphosate applications by germinating after the
last application can have an advantage in glyphosate-resistant crops (Hilgenfeld et al., 2004;
Owen and Zeiaya, 2005; Puricelli and Tuesca, 2005; Scursoni et al., 2007; Wilson et al., 2007;
Owen, 2008). Table 2-2 lists weed species that have been found to be naturally tolerant to the
conditions prevalent in the fields where glyphosate-resistant crops are grown and have become
more abundant after the widespread adoption of these crops. Shifts in local weed communities
have been observed more frequently in glyphosate-resistant cotton and soybean than in
glyphosate-resistant com, probably because glyphosate-resistant cotton and soybean are more
widely cultivated than glyphosate-resistant com (Culpepper, 2006). However, where glyphosate-
resistant com and glyphosate-resistant soybean are commonly rotated (e.g., in the Midwest),
strong selection pressure exists for the evolution of glyphosate-resistant weeds because the
management tactics vary so little between the two crops.
Farmers’ Response to Giyphosate Resistance in Weeds
The evolution of giyphosate resistance in some kinds of weeds and other weed shifts can
diminish the technical and economic efficiency of weed control. However, because giyphosate
allows producers to control a wide array of weeds conveniently and economically, they have
been reluctant to stop using glyphosate-resistant crops and giyphosate when facing control
problems arising from a few glyphosate-resistant or naturally glyphosate-tolerant weed species.
For controlling problematic weeds, they prefer increasing the magnitude and frequency of
giyphosate applications, using other herbicides in addition to giyphosate, or increasing their use
of tillage.
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TABLE 2-2 Weeds Reported to Have Increased in Abundance in Glyphosate-Resistant Crops
Species
Crop
Location
Reference
Acalypha spp.
(copperleaf)
Soybean
—
Owen and Zelaya, 2005;
Culpepper, 2006
Amaranthus tuberculatus
(waterhemp)
Soybean
—
Owen and Zelaya, 2005
Amaranthus palmeri
(Palmer amaranth)
Cotton
—
Culpepper, 2006
Annual gr^ses
Cotton
—
Culpepper, 2006
Chenopodium album
(common lambsquarters)
Soybean
Iowa, Minnesota
Owen, 2008
Commelina communis
(Asiatic dayflower)
Cotton, soybean
Midwest,
Midsouth,
Southeast
Owen and Zelaya, 2005;
Culpepper, 2006; Owen,
2008
Commelina benghalensis
(tropical spiderwort)
Cotton
Southeast, Georgia
Owen, 2008; Mueller et
al., 2005
Cyperus spp.
(nutsedge)
Cotton
—
Culpepper, 2006
Equisetum arvense
(field horsetail)
Herbicide-resistant
crops
—
Owen, 2008
Oenothera biennis
(evening primrose)
Herbicide-resistant
crops
iowa
Owen, 2008
Oenothera laciniata
(cutleaf evening primrose)
Soybean
—
Culpepper, 2006
Pastinaca saliva
(wild parsnip)
Herbicide-resistant
crops
Iowa
Owen, 2008
Phytolacca americana
(pokeweed)
Herbicide-resistant
crops
—
Owen, 2008
Ipomoea spp.
(annual morning glory)
Cotton
—
Culpepper, 2006
For example, soybean growers in Delaware continued planting glyphosate-resistant soybean
even in the presence of widespread glyphosate resistance in horseweed (Scott and VanGessel,
2007). Most producers addressed the problem by applying an herbicide with a different mode of
action, increasing the frequency of glyphosate applications, or using tillage before planting.
Some 76 percent of growers estimated that resistance in horseweed increased their management
costs by more than $2.02/acre, and 28 percent reported cost increases of over $8.09/acre (Scott
and VanGessel, 2007). Similarly, a survey of 400 com, soybean, and cotton producers in 17
states found that most would not limit the use of glyphosate-resistant crops when facing
problematic glyphosate-resistant weeds (Foresman and Glasgow, 2008). Instead, producers
planned to increase the rotation of herbicides, the use of tank-mixes, or the amount of tillage.
They expected that additional measures for the control of glyphosate-resistant weeds would cost
$13.90-16.30/acre (Foresman and Glasgow, 2008).
In an economic analysis of weed-management costs with a hypothetical reduction of control
with glyphosate in three regions of the United States, the projected cost of new resistance-
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management practices for horseweed was $12.33/acre in a cotton-soybean-corn rotation in
western Tennessee (Mueller et ai., 2005), Additional costs were due to a shift from no-tiil to
conventional tillage for cotton and the need for new preplant herbicides for soybean. The
projected cost of new herbicide resistance-management practices for waterhemp was $17.91/acre
in a corn-soybean rotation in souftiem Illinois; this cost resulted from use of different pre-
emergence and postemergence herbicides for soybean (Mueller et al., 2005). For cotton grown in
Georgia, the extra cost of controlling shifts in tropical spiderwort {Commelina benghalensis), a
weed that is naturally tolerant to glyphosate, was predicted to be $14.91/acre; an additional
herbicide application after cotton emergence explained this cost (Mueller et al., 2005).
Those studies indicate that the evolution of glyphosate resistance and weed shifts could lead
to two important changes in practices: increased use of herbicides generally and reductions in
conservation tillage (Mueller et a!,, 2005). Such changes would also increase weed-management
costs and reduce producer’ profits, and the environmental consequences of those practices, if
they were widely adopted by producers of HR crops, would negate the environmental benefits
previously achieved.
In summary, most giyphosate-resistant weeds in HR crops are of economic importance in
row crops grown in the Southeast and Midwest. The number of weed species evolving resistance
to glyphosate is growing (Figure 2-6), and the number of locations with giyphosate-resistant
weeds is increasing at a greater rate, as more and more acreage is sprayed with glyphosate.
Though the number of weeds with resistance to glyphosate is still small compared to other
common herbicides,^ the shift toward giyphosate-resistant weed biotypes will probably become
an even more important component of row-crop agriculture unless production practices (such as
recurrent use of glyphosate) change dramatically (Gressel, 1996; Owen and Zelaya, 2005;
Johnson et al., 2009).
Implications of Weed Shifts In Herbicide-Resistant Cropping Systems
As noted above, because the adoption of HR crops has facilitated an increase in conservation
tillage and reduced the number of herbicides that growers use to control weeds, the selection
pressures affecting weed communities has changed. Unsurprisingly, managing weeds through
glyphosate applications to HR crops favors the evolution of glyphosate resistance in weeds
occurring in these crop fields (Shaner, 2000; Mueller et al., 2005; Foresman and Glasgow, 2008;
Powlcs, 2008). Addressing the problem of resistance — a problem not unique to HR crops —
requires careful thought about management practices and other potential solutions based on a
clear understanding of how genes that code for resistance are distributed throughout a population
of a weed species.
Principles of Population Genetics Underlying Resistance in Weeds
Similar concepts have been used to understand the evolution of resistance to glyphosate in
weeds and to the Bt toxin in insects. Population-genetic models and empirical data on factors that
^For example, 38 weeds have developed resistance to some acetyl-CoA carboxylase (ACCase), and
resistance to some acetolactate synth^e (ALS) iiUtibitors has been documented in 107 worldwide.
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20
1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 *
Year
FIGURE 2-6 Number of weeds with evolved glyphosate resistance.
* Weed numbers are updated through March 2010.
SOURCE: Adapted from Heap, 2010.
affect how resistance evolves have been applied to the management of both herbicide-resistant
weeds and Bt-resistant insects (Jasieniuk et al., 1996; Werth et al., 2008). However, strategies for
delaying the evolution and spread of resistance are not the same because there are important
underlying differences in the population genetics of herbicide resistance and insect resistance.
Resistance to herbicides, and in particular to glyphosate, is often conferred by a single
nuclear gene (Jasieniuk et al., 1996; Powles and Preston, 2006). Herbicide resistance in weeds is
rarely recessive;*’ in all cases studied, resistance to glyphosate was additive to dominant, that is,
individuals with a single resistance allele can survive applications of glyphosate (Jasieniuk et al.,
1996; Zelaya et al., 2004; Powles and Preston, 2006; Zelaya et al., 2007; Neve, 2008).
Furthermore, even if resistance is recessive in some weeds, many weeds are self-pollinating, so a
recessive gene for resistance could become homozygous in only a few generations and thus
confer resistance to all offspring (Gould, 1995; Jasieniuk et al., 1996). Some agronomically
important weeds (such as, pigweed) are dioecious (having separate male and female plants) and
thus are cross-pollinated. They have demonstrated the ability to evolve resistance to glyphosate
although the genetics of the process have not been described.
Finally, even though the seeds of some weed species can disperse over long distances
(Shields et al., 2006), dispersal of viable pollen generally occurs over short distances (Jasieniuk
et al., 1996; Roux et al., 2008). Therein lies an important difference between weeds and insects
and hence the availability of strategies, such as refuges, to control weed resistance. For all the
reasons described above, maintaining a refuge — an area where susceptible weeds are not
‘Plants cany two alleles (forms) of the same gene for glyphosate resistance. Each allele exerts influence on
the nature of that trait; saying that resistance is recessive means that one allele is not sufficient to confer resistance.
Offspring that inherit one allele with the resistant trait and one without will not be resistant, while offspring that
inherits two of the same form of the allele that confers resistance wiil be resistant.
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exposed to giyphosale and would persist to interbreed with resistant biotypes — cannot be
expected to lower the heritability of herbicide resistance in weeds as it lowers the heritabiiity of
Bt resistance in insects targeted by Bt crops (Jasieniuk et al., 1996). The refuge strategy for Bt-
resistant insects is discussed later in this chapter (see '‘Evolution and Management of Insect
Resistance"').
Although the use of refuges cannot be expected to delay the evolution of glyphosate
resistance in weeds, the spread of herbicide resistance can be delayed by reducing the selective
differential (the difference in survival and other fitness traits) between individuals with and
without resistance alleles (Gressel and Segel, 1990: Jasieniuk et al., 1996; Werth et al., 2008).
That can be accomplished by using control practices that kill weeds that have the resistance
alleles. For example, the use of tank-mixes that contain two or more herbicides with dilTerent
modes of action may be effective if tlie herbicides have high efficacy in controlling the target
weeds. Similarly, herbicides with different modes of action or methods that combine herbicides
and mechanical weed control (tillage) may be used sequentially to control the same generation
(i.e.. emergence cohort) of weeds.
The selective differential between individuals with and without resistance alleles can also be
reduced by rotating the types of herbicides used to control the target weeds so that selection for
resistance to a specific herbicide occurs only in alternate growing seasons (Jasieniuk et al., 1996;
Roux et a!.. 2008). When no fitness costs^ are associated with resistance, the rotation of
herbicides contributes to equalizing the fitness of individuals that are resistant to and susceptible
to a herbicide during seasons when the herbicide is not used. Models suggest that the evolution
of resistance to the rotated herbicides will be delayed by 1 year for each year that the rotation
tactic is used (Maxwell and Jasieniuk, 2000). When fitness costs are associated with resistance to
a herbicide (Gressel and Segel, 1990; Jasieniuk et al., 1996; Baucom and Mauricio, 2004), the
fitness of individuals that have resistance alleles is lower than the fitness of individuals that do
not during seasons when the herbicide is not used. Therefore, herbicide rotation contributes to
reducing the selective ditTerential between individuals with and without resistance alleles over
lime, which may delay the evolution of resistance (Jasieniuk et al., 1996; Roux et al., 2008).
Reduction in the selective differential can be accomplished by rotating the type of crops
grown in a field between growing seasons; this may result in drastic changes in the types of
herbicides used. Changes in ecological conditions associated with cultivation of different crops
could favor declines in particular weed species (which could be resistant or tolerant to
glyphosate) or induce competitive disadvantages in herbicide-resistant weeds through negative
cross-resistance, in which resistance to one chemical confers hypersensitivity to another
chemical (Gressel and Segel, 1990; Boerboom, 1999; Owen and Zelaya, 2005; Beckie et al.,
2006; Murphy and Lemerlc, 2006).
Developing Weed-Management Strategies for Herbicide-Resistant Crops
How might the various strategies be used in the context of HR cropping systems? Tank-
mixes and sequences of herbicides to extend the useful life of herbicides could be employed if
’Some genes that confer resistance affect the biological or physiological viability of an organism adversely
in absence of a pesticide, and carriers of such a gene tend to become rarer in the population over time. The fitness
cost is the extent to which such a penalty on fitness exists.
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crop cultivars that are resistant to two or more hert>icides are developed; this strategy is currently
favored by biotechnology companies (Duke, 2005; Behrens et al., 2007; Green et al., 2008;
Green, 2009). As for using crop rotations, the increasingly common practice of farmers
throughout the United States of using glyphosate as the primary or only weed-management tactic
in rotations of different glyphosate-resistant crops limits the application of the rotation strateg)',
even if the change in crop-induced ecological changes might improve weed management. A
possible solution could be to combine the rotation of two or more HR cultivars that each can
tolerate only one herbicide with the use of a different herbicide at each rotation. For example,
different varieties of GE canola {Brassica napus L.) grown in the prairie provinces of Canada
were engineered for resistance to glufosinate or glyphosate. That allowed producers to include
two types of FIR canola into a canola-wheat-barley rotation so that canola resistant to
glufosinate or glyphosate would be grown only once every 4 years in a particular field (Powles,
2008). In contrast with com, soybean, and most cotton production, growing crop species like
canola, in which hybridization between the crop and weedy relatives is possible, poses a risk of
gene flow between the HR crop and the weedy relatives (Beckie et al., 2003; Legere, 2005; see
also “Gene Flow Between Genetically Engineered Crops and Related Weed Species”).
The same rotation strategy could be used with HR crops that are resistant to two (or more)
herbicides; the same crop would be grown twice during the rotation” cycle, but ^ch of the two
herbicides that it can resist would be applied only every other year. Genes that confer resistance
to some acetyl-CoA carboxylase (ACCase) inhibitors, synthetic auxins (e.g., 2, 4-D), acetolactate
synthase (ALS) inhibitors, dicamba, glufosinate, glyphosate, and hydroxyphenylpyruvate
dioxygenase (HPPD) inhibitors are the most likely candidates for production of the next
generation of HR varieties that are resistant to multiple herbicides (Duke, 2005; Behrens et al.,
2007; Green, 2009). So far, weed resistance to glufosinate and HPPD inhibitors has not been
reported. Weed resistance to dicamba has not been reported in com, cotton, or soybean but has
appeared in other crops in the United States (Heap, 2010). However, weed resistance to some
ACCase inhibitors, synthetic auxins, and ALS inhibitors has been reported in com, cotton, and
soybean (Heap, 2010). Moreover, most weed species that have evolved resistance to glyphosate
in fields of HR crops (Table 2-1) also have evolved resistance to ALS inhibitors (Heap, 2010).
From the point of view of herbicide-resistance management and the long-term efficacy of an
HR crop, it may be better to engineer a crop for resistance to herbicides that can efficiently
control most weeds associated with the crop. For example, genes that confer resistance to ALS
inhibitors, to which many weed species are already resistant, could be inferior to genes that
confer resistance to dicamba, glufosinate, and HPPD inhibitors to produce durable HR com,
cotton, and soybean resistant to two or more herbicides. Similarly, care should be taken to
engineer crops for resistance to specific ACCase inhibitors and synthetic auxins that will still be
effective in controlling weeds associated with future HR crops.
If crops that are resistant to multiple herbicides — including ALS inhibitors, ACCase
inhibitors, synthetic auxins, and glyphosate — are widely planted, continued use of the herbicides
in fields that contain weeds already resistant to some of them could involve a risk of selecting for
high levels of multiple herbicide resistance. The ability of weeds to evolve biotypes that have
multiple herbicide resistance has already been demonstrated in waterhemp populations in Illinois
and Missouri that are resistant to three herbicide mechanisms of action (Patzoldt et al., 2005;
Legleiter and Bradley, 2008). Evolved multiple resistance will exacerbate problems of
controlling some key herbicide-resistant weeds, and local and regional spatially explicit
information on the distribution of weeds that are resistant to glyphosate and other herbicides
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could be useful in helping to manage such a situation (Werth et al., 2008). Tank-mixes and
sequencing herbicides rely on redundancy to be effective. Models assessing sequential use of
herbicides only, or of herbicides and mechanical weed control, indicate that a low frequency of
alleles conferring resistance to herbicides and high weed mortality are critical factors for these
strategies to substantially delay the evolution of weed resistant to glyphosate in HR crops (Neve
et al., 2003; Neve, 2008; Werth et ai., 2008).
In conclusion, regardless of the specific herbicide for which HR crops are genetically
engineered, only appropriate stewardship by the grower will delay the evolution of resistance to
the herbicide. Resistance management is voluntary in the United States for all pesticides except
Bt produced by Bt crops (Berwald et al,, 2006; Thompson et al., 2008). Given the rapid increase
in and expansion of weeds that are resistant to glyphosate in HR crops, herbicide-resistance
management needs national attention. As discussed previously, the rapid evolution of weed
resistance to glyphosate has probably been a consequence of growers’ management decisions
that favored the use of glyphosate as the primary, if not sole, tactic to control weeds despite
efforts in the private and public sectors to strongly recommend alternative strategies (Johnson et
al., 2009). Without changes in production practices, the increase in weeds resistant to glyphosate
will likely increase weed-management expenses for farmers. The evolution of herbicide
resistance and other weed shifts associated with the adoption of GE crops requires the
development and use of more effective weed-management strategies and tactics (Beckie, 2006;
Murphy and Lemerle, 2006; Green et al., 2008; Gustafson, 2008; Powles, 2008; Werth et al.,
2008).
Diversification of weed-management strategies can be accomplished by integrating several
weed-control tactics; herbicide rotation, herbicide application sequences, and the use of tank-
mixes of more than one herbicide; the use of herbicides that have different modes of action,
methods of application, and persistence; cultural and mechanical control practices; and
equipment-cleaning and harvesting practices that minimize the dispersal of herbicide-resistant
weeds. Although the strategies to mitigate weed shifts are readily identified, they have largely
been ignored because of the scale of commercial agriculture, which favors the simplicity,
convenience, and short-term success of herbicide use over more time-consuming strategies that
can be burdensome to implement on farms (Shaner, 2000; Mueller et al., 2005; Johnson and
Gibson, 2006; Sammons et al, 2007; Owen, 2008). Furthermore, increased reliance on
glyphosate for weed control in glyphosate-resistant crops has reduced the price of other
herbicides in the United States and has limited efforts to develop new herbicides (Shaner, 2000;
Duke, 2005). Companies are increasingly focused on expanding the use of currently registered
herbicides, which can be achieved by commercializing GE crops that are resistant to more than
one herbicide (Duke, 2005; Green, 2007, 2009). Delaying the evolution of resistance to
herbicides that are used with HR crops and minimizing other weed shifts are particularly
important in this context because new herbicides may not be readily available to replace ones
that become ineffective when resistance evolves. Therefore, farmers would benefit from focusing
on more diverse, longer-term weed-management sfrategies to preserve the effectiveness of HR
crops and to minimize the possibility of more expensive control tactics in the future.
ENVIRONMENTAL IMPACTS OF INSECT-RESISTANT CROPS
The adoption of Bt crops has changed insect-management strategies for most com and cotton
farmers in the United States. Those chjuiges have implications for pest populations, soil
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conditions, and the management of insect pests in the future. The following section evaluates the
impact of insect-resistant (IR) crop adoption on pest populations, on nontarget insects, and on
soil quality. It also investigates resistance-management strategies and concerns related to the
continued effectiveness of IR crops.
Levels of Insecticide Use
Insecticide Use in Corn
Insecticide use in com (in pounds per acre) has steadily declined since 1997 as the adoption
of Bt com (which reached 50 percent of com acres planted in 2007) has increased (Figure 2-7).
Bt com was introduced in the mid-1990s to control the European com borer (Ostrinia nubilalis).
Because chemical control of the European com borer was not always profitable (and timely
application was difficult) before the introduction of Bt com, many fanners accepted yield losses
rather than incur the expense and uncertainty of chemical control. For those farmers, the
introduction of Bt com resulted in yield gains rather than pesticide savings (Femandez-Comejo
and Caswell, 2006). However, a new type of Bt com introduced in 2003 to protect against com
rootworm (Diabrotica spp.), which was previously controlled with chemical insecticides and
crop rotation, has provided substantial insecticide savings (Fernandez-Comejo and Caswell,
2006).
Insecticide Use in Cotton
Cotton has the highest traditional use of insecticides per acre and the highest rate of adoption
of Bt crops, reaching almost 60 percent In 2007, 12 years after Bt cotton was first
commercialized (Figure 2-8). Insecticide use has fallen (in pounds per acre) over the same
period, but fluctuations in total cotton insecticide applications have also been strongly affected
by the boll weevil eradication program*^ (Femandez-Cornejo et al., 2009).
*Since the 1970s, cotton growCTS and governments have worked toward eradicating the boll weevil, a beetle
that affects cotton and that is not directly affected by Bt cotton. Different cotton-growing regions joined the program
in different yeare. Typically, the first year of participation entails heavy application of pesticides (generally
malathion). In subsequent years, the boll weevil population is monitored and treated as needed. A new wave of
cotton-growing regions began participating in 1993. The spike in cotton insecticide applications in 1999 and 2000
coincides with the entry of 2 million cotton acres into the program in Texas (Femandez-Comejo et al., 2009).
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Year
— ^ — Insecticide pounds — .0— Percent acreage St com
FIGURE 2-7 Pounds of insecticide applied per planted acre and percentage of acres of Bt com,
respectively.
NOTE: Seed-applied insecticide not included. Furthermore, the strong correlation between the
rising percentage of Bt com acres planted over time and the decrease in insecticide pounds per
planted acre suggests but does not confirm causation between these variables.
SOURCES: USDA-NASS, 2001; 2003, 2005, 2007, 2009a, b; Femandez-Comejo et al., 2009.
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■m — Insecticide pounds — .q— Percent acreage Bt cotton
FIGURE 2-8 Pounds of insecticide applied per planted acre and percentage of acres of Bt
cotton, respectively.
NOTE: The strong correlation between the rising percentage of Bt cotton acres planted over time
and the decrease in insecticide pounds per planted acre suggests but does not confirm causation
between these variables.
SOURCES: USDA-NASS, 2001 ; 2003, 2005, 2007, 2009a, b; Femandez-Comejo et al., 2009.
Regional Pest Reductions
Com and cotton that produce Bt toxins can cause high mortality in insect pest populations in
which Bt-resistance alleles are rare. For example, mortality in pink bollworm {Pectinophora
gossypielld) and tobacco budworm (Heliothis virescens) on Cry I Ac cotton is virtually 100
percent throughout the growing season (Tabashnik et ai., 2000; Showalter et al., 2009) .
Ilowever, mortality in the moths Helicoverpa armigera and Helicoverpa zec^ on Cry 1 Ac cotton
is typically lower than 95 percent and declines during the growing season (Kennedy and Slorer,
2000; Olsen et al., 2005; Tabashnik et al., 2008; Showalter et al., 2009). Crops that produce more
than one Bt toxin generally cause higher mortality than crops that produce a single toxin
although declines in mortality during the growing season may still be observed (Adamczyk et al.,
2001; Bommireddy and Leonard, 2008; Mahon and Olsen, 2009; Showalter et al., 2009).
Because Bt crops can cause high pest mortality, it has been postulated that one effect of the
widespread use of Bt crops is a reduction in some pest populations regionally (Kennedy et ai.,
1987; Alstad and Andow, 1995; Roush, 1997; Gould, 1998; Kennedy and Storer, 2000; Stoier et
‘^Helicoverpa armigera and Helicoverpa zea are known by many common names, depending on the host
plant. Helicoverpa armigera is referred to as old world bollworm or cotton bollworm (when it feeds on cotton), pod
borer (when it feeds on chickpea or pigeon pea), tomato fruit borer (when it feeds on tomato), and com earworm
(when it feeds on com). Helicoverpa zea is often called cotton bollworm, com earworm, or tomato fruitworm.
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al., 2003). According to that idea, an area-wide decline in pest abundance could occur because
replacing non-Bt crop fields with Bt crop fields eliminates suitable habitats for the pests. If
females lay eggs on Bt plants and on non-Bt host plants, laying eggs on Bt plants could
substantially reduce the number of surviving offspring produced by females and cause a decline
in pest density (Riggin-Bucci and Gould, 1997; Carriere et ai., 2003; Shelton et al, 2008).
Models have suggested that the suppression of pest populations is more likely as mortality
induced by Bt crops increases, the abundance of Bt crops and female movement between patches
of Bt and non-Bt plants increase, and the net reproductive rate in patches of non-Bt hosts
decreases (Carriere et al, 2003). However, polyphagous pest species (those able to feed on
multiple types of plants) often exploit crops sequentially during the growing season, tracking
changes in host suitability (Kennedy and Storer, 2000). In some cropping systems, the feeding
options of such pests might be limited to only a Bt crop for a few generations, when it is the only
suitable resource available. Thus, Bt crops could affect pest population dynamics even when the
crops are relatively rare (Kennedy et al, 1987; Wu et al, 2008).
Long-term monitoring of insect-pest density before and after commercialization of Bt crops
has provided evidence that deployment of Bt crops influences pest population dynamics
regionally. Table 2 3 contains the results of pest-monitoring studies in the United States and
China. Most of the studies covered a single region where spatially explicit data on the
distribution of Bt crops were not available, but in one study of pink bollworm population density
in Arizona from 5 years before to 5 years after introduction of Bt cotton, the abundance of Bt and
non-Bt cotton fields in 15 cotton-growing regions was quantified with geographical information
system technology (Carriere et al, 2003). In regions with less than an average of 65 percent Bt
cotton in the second 5-year period, the introduction of Bt cotton had no consistent effect on
population density of pink bollworm; in regions with more than 65 percent Bt cotton, the
introduction of Bt cotton decreased pink bollworm population density, and the extent of the
decline increased as the percentage of Bt cotton increased. Those data are consistent with
modeling results and suggest that pest-population suppression occurs if the area of Bt crops
exceeds a threshold percentage of Bt cotton (Carriere et al, 2003). Another recent study of the
European com borer conducted in five major U.S. corn-producing states indicated that
suppressive effects of Bt com depended on the extent of adoption of the technology (Hutchison
et al, 2007).
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Storer et al. (2008) noted that producers, extension agents, and pesticide appliers reported
less serious insect-pest control problems in non-Bt crops, such as soybean and vegetables, after
the regional suppression of the European com borer and the com earworm {H. zed) by Bt com in
Maryland. As a comparison to the U.S. experience, a study conducted in six provinces of China
from 1997 to 2006 documented a progressive decline in the population density of cotton
bollworm {H. armigera) after the introduction of Bt cotton (Wu et al., 2008) (Table 2-3). The
significant suppression of cotton bollworm occurred not only in Bt and non-Bt cotton but in com,
peanut, soybean, and vegetables. Wu et al. (2008) proposed that the regional decline of cotton
bollworm populations could reduce insecticide use in crops other than cotton. Nevertheless, the
economic consequences of the regional suppression of pests by Bt crops have been investigated
only for European com borer in five U.S. Com Belt states (Hutchison et al, 2007). It was
estimated that regional declines in European com borer population densities during the last 14
years in those states saved at least $3.9 billion for producers of non-Bt com and $6.1 billion for
producers of Bt and non-Bt com combined. Further detailed spatially explicit studies of the
association between the distribution of Bt crops and pest problems on different scales will be
helpful in improving understanding of how the use of Bt crops can reduce pest abundances
(Marvier et al., 2008).
The use of Bt crops sometimes changes pest-management practices enough to increase
problems related to pests that are not killed by Bt toxins. For example, substantial reductions in
the use of synthetic insecticides on Bt cotton favored outbreaks of mirids and leafhoppers in
China (Wu et al, 2002; Men et al, 2005). Those pests had been well controlled by insecticides
before the introduction of Bt cotton. Similarly, lower use of insecticides in Bt cotton probably
contributed to the higher slink bug damage in cotton in some southern U.S. states although the
regional increases in stink bug populations were probably influenced by other factors as well
(Greene et al., 2001; Greene et al., 2006). Changes in pest-management practices in connection
with Bt crops can also have favorable consequences for the control of some pests that are not
killed by Bt toxins. For example, a reduction in insecticide use on Bt cotton was sometimes
associated with greater predator abundance and better pest control in cotton aphid in the United
States (see section “Natural Enemies”).
Reversal of Insect Resistance to Synthetic Insecticides
The deployment of Bt crops is known to promote a reversal of pest resistance to synthetic
insecticides, but this has not yet been observed in United States. In northern China, the reduction
in use of insecticides on Bt cotton contributed to restoring cotton bollworm (//. armigera)
susceptibility to some synthetic insecticides (Wu et al., 2005; Wu, 2007) although fitness costs
associated with insecticide resistance likely helped to increase susceptibility. Similarly,
resistance to pyrethroid insecticides declined considerably in tobacco budworm (H. virescens)
after the introduction of Bt cotton in southern Tamaulipas, Mexico (Teran-Vargas et al, 2005).
The renewed efficacy of insecticides provided more pest-management options to producers in
those regions. However, such reversals in insecticide resistance do not always occur. For
example, the planting of Bt cotton in Louisiana did not change the high levels of pyrethroid
resistance in tobacco budworm {H. virescens) and cotton bollworm (H. zed) (Bagwell et al,
2001), and H. zea resistance to pyrethroids increased substantially after the planting of Bt cotton
in several regions of Texas (Pietrantonio et al, 2007).
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Effects on Nontarget Species
Bt toxins are considered acutely toxic to a relatively narrow array of invertebrate taxa when
compared with broad-spectrum insecticides because toxicity through direct ingestion of a Bt
toxin is typically restricted to insects in the same order as the target pest (Schnepf et al., 1 998;
Glare and O’Caliaghan, 2000; van Frankenhuyzen and Nystrom, 2002; Mendelsohn et al., 2003).
For example, the endotoxins CrylAa, CrylAb, and CrylAc kill mainly particular moths and
butterfly species, while CrySAa and Cry3Bb mainly kill particular beetle species. Furthermore,
because Bt toxins are specific, they cause different mortality within targeted insect orders. For
example, the cotton cultivar Bollgard I®, which produces the toxin CrylAc and targets
lepidopteran pests, kills virtually 100 percent of pink bollworm and tobacco budworm {H.
virescensX between 24-95 percent of cotton bollworms H. zea and H. armigera, and less than 4
percent of fall armyworm {Spodoptera jrugiperda) and beet armyworm (Spodoptera exigua)
(Showalter et aL, 2009). Field studies have revealed relatively few adverse effects of Bt crops on
arthropods that are not closely related to the target pests (Cattaneo et ah, 2006; Romeis et al.,
2006). In contrast, broad-spectrum insecticides, such as pyrethroids and organophosphates had
consistent, adverse effects on a wide array of nontarget arthropods (Cattaneo et al., 2006; Romeis
et al., 2006).
Although the high specificity of Bt crops for the control of target pests is consistent with
integrated pest management, they may have effects on beneficial organisms. For example, the
larvae of nontarget moths or butterflies in the landscape surrounding farms may be susceptible to
Bt toxins that target pests in this group, but they would need to eat the Bt plant material to be
affected. Bt corn byproducts that enter streams may affect aquatic insects in related taxa (Rosi-
Marshall et al., 2007). The abundance of some natural enemies may decrease when their host or
prey species are susceptible to Bt toxins and as a result become rare or nutritionally less suitable
(Romeis et al., 2006).
Quantifying and predicting the effects of Bt crops on nontarget invertebrate species has been
the subject of considerable work. As compiled by Marvier et al. (2007) and Naranjo (2009),
research on the nontarget effects of Bt crops includes 135 laboratory studies of nine Bt crops and
22 Bt Cry proteins or protein combinations and 63 field studies of five Bt crops and 13 Bt
proteins. In total, field and laboratory studies of at least 99 and 185 invertebrate species,
respectively, have been conducted although not with equal effort. Most of the field studies have
been of com and cotton. Individual study results vary, so evidence-based generalizations are
elusive in the absence of formal approaches. A review of recent syntheses provides an overview
of the generalizations that have emerged thus far from those efforts.
For cotton and com, whether Bt crop fields have more or fewer nontarget invertebrates
depends on whether one compares the Bt crop to a conventional counterpart that received
insecticide treatments (Marvier et al., 2007; Woifenbarger et a!., 2008; Naranjo, 2009).
Collectively, studies have indicated that a higher total abundance of arthropods occurred in Bt
fields than in conventional fields sprayed with insecticides and a lower abundance than in
conventional fields with no insecticide treatment (Marvier et al., 2007). For Bt com, the
magnitude of the effect also depended on whether studies tested Btl76 (no longer registered for
use) or the MON810 (commercially used) Bt events. Lower abundance of specific taxa was
found in Bt fields than in unsprayed, non-Bt fields; the taxa in question included moths,
butterflies, beetles, and true bugs on cotton and wasps on com. Differences in the availability of
prey or in survival may explain those results (Marvier et al., 2007).
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Bt potato crop fields without insecticide use contained higher abundances of predators,
natural enemies as a whole, and nontarget pests compared to conventional potato fields, whether
or not insecticides were applied to the conventional fields (Wolfenbarger et al., 2008).
Natural Enemies
Maintenance of healthy populations of predators of crop pests is a desirable goal for ensuring
long-term environmental sustainability of farms. Decreasing the numbers of predators, which in
practice will be related to the overall bi<x!iversity in an area and to on-farm pest control (Landis
et al., 2008), would be undesirable. Even in systems where a single predator may suffice as a
biocontrol agent, redundancy is an important tool for ensuring ecosystem services.
The few studies comparing biological control (by parasitism and predation rates) between Bt
and conventional crops have suggested that control of nontarget pests on Bt crops was enhanced
on cotton (Head et ah, 2005) or similar on cotton (Naranjo, 2005) and com (Pons and Stary,
2003; Naranjo, 2005) and that control of target peste on Bt crops was enhanced on cotton (Head
et ah, 2005), similar on cotton (Sisterson et ah, 2004b; Naranjo, 2005) and com (Orr and Landis,
1997; Sisterson et ah, 2004b; Naranjo, 2005), or reduced on com (Siegfried et al., 2001;
Bourguet et al., 2002; Manachini, 2003; cited by Naranjo, 2009). Maintenance of biological
control of nontarget pests in one study occurred in Bt cotton fields in spite of about a 20 percent
reduction in the abundance of some common predators (Naranjo, 2005). When Bt crops have
completely replaced insecticide-treated conventional crops, studies have consistently reported
higher numbers of predators on cotton, com, and potato. When Bt crops have replaced non-
insecticide-treated conventional crops, results studies have consistently indicated slightly fewer
predators on Bt cotton and no detectable difference on Bt com (Wolfenbarger et ah, 2008;
Naranjo, 2009).
Field studies of parasitoids have overemphasized specialist species of the target pest of Bt
com, so generalizations to parasitoids as a group are premature. The studies have revealed a
pattern similar to that of predators: fewer parasitoids in conventional com fields sprayed with
insecticides and no detectable difference between Bt com fields and conventional com fields not
treated with insecticides. Laboratory studies indicate that effects of Bt toxins on parasitoids
depend on whether they are fed prey that arc susceptible to Bt toxins (Zwahlen et ah, 2000;
Dutton et ah, 2002; Schuler et ah, 2003; Schuler et a)., 2004; Romeis et al., 2006). Syntheses of
laboratory studies of 14 parasitoid species indicate a favorable or neutral effect on life-history
traits when they were fed prey that had ingested a Bt toxin but were not affected by it (high-
quality prey). Conversely, studies have shown longer development times, lower reproduction,
and lower survival if the parasitoids were fed prey that had ingested a Bt toxin that was toxic to
them (low-quality prey) (Naranjo, 2009).
The adoption of Bt cotton increases abundances of natural enemies and hence the potential
for biological control when it completely replaces insecticide treatments. Moth larvae were
responsible for a large fraction of cotton insect losses before the adoption of Bt cotton, but
cotton-insect losses caused by these larvae have become less important now that Bt cotton has
been widely adopted. The five major insect pests of cotton in the United States in 2008 were
lygus bugs (I percent yield loss), bollworms and budworms (0.76 percent yield loss), stink bugs
(0.75 percent yield loss), thrips (0.52 percent yield loss), and cotton fleahoppers (0.23 percent
yield loss) (Williams, 2008). Among those, only bollworms and budworms are controlled by Bt
cotton, so the use of Bt cotton rarely eliminates all insecticide applications. Actual farm-level
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reductions in insecticide use for Bt cotton would probably increase the abundance of nontarget
insects less consistently (e.g., Cattaneo et al., 2006; Sisterson et al., 2007) than what has been
observed in experimental studies in which the use of Bt cotton completely replaced insecticide
treatments.
Pollinators and Other Valued Insects
The honey bee (Apis mellifera) is one of the agricultural sector’s most important pollinators.
Laboratory toxicity studies of honey bees have consistently found no evidence that Bt pollen or
Bt proteins decrease honey-bee larval or adult survival (Duan et al., 2008) even at toxin
concentrations well beyond what would be encountered in the field. There have been laboratory
or field studies of few other species (Wolfenbarger et al., 2008; Naranjo, 2009); no consistent
effect on development time (eight studies) or survival (20 studies) has been detected in
laboratory tests, but effects varied widely among studies, particularly for development lime
(Naranjo, 2009). Laboratory studies collectively have indicated longer development time and
lower survival of valued insect herbivores, a category that includes charismatic species (e.g.,
monarch butterfly larvae), and moths of economic importance (e.g., the silkworm) (Naranjo,
2009).
Summary of Nontarget Effects
The abundance of natural enemies on Bt crops can be greater than, the same, or lower than
on non-Bt crops. The magnitude of the benefit depends on the extent to which a Bt crop
substitutes for the use of insecticide treatments of non-Bt crops and on whether insecticides for
other pests are used on the Bt crop. Honey-bee adults and larvae were not harmed by Bt pollen or
Bt proteins, but too few pollinators have been studied to support generalizations about die group
as a whole. As the sophistication of GE-crop varieties increases and the functional roles of
arthropods become understood more fully, it should be possible to develop strategic pest-
management systems that maintain high crop productivity while avoiding effects on nontarget
moths, butterflies, and beetles.
Soil Quality
Overall, it appears that current Bt crops have no greater or less effect on soil quality than the
crops that they have replaced. Many peer-reviewed studies have addressed the nontarget impacts
of Bt crops on soil organisms. Specifically, studies have considered the effects of plant residues
on the soil community because plants are the primary source of carbon in soils. If Bt toxins affect
soil microorganisms, rates of decomposition and nutrient cycling may be altered. Studies have
also focused on the consequences of Bt-containing root exudate. Root exudate influences the soil
community, especially the community of distinct, specialized soil microorganisms associated
with roots.
Most assessments of the effects of Bt insecticidal proteins on soil microorganisms and other
organisms have found that these proteins do not substantially alter microbial populations and
measured functions (Icoz and Stotzky, 2008). Over four years of continuous com cultivation, Bt
plant residues and root exudates had no consistent or persistent effect on a breadth of
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microorganisms or their enzymatic activity in the soil, but differences were detected according to
plant species, variety, and age as well as other environmental factors (fcoz et al., 2008). With
respect to macroorganisms, Lang et al. (2006) found no significant differences in earthworm or
springtail population density or biomass between soils with Bt and with non-Bt com or between
soils with com treated and not treated with insecticide (baythroids) at five sites during 4 years of
com cultivation. Instead, the site and the sampling years had a greater influence on earthworm
population density and biomass than the presence of the Cry protein. Those results corroborate
other laboratory and field studies of the effect of Bt toxins on survival, growth, and reproduction
of an array of soil invertebrates, including woodlice, springtails, and mites (Ahl Goy et al., 1995;
Saxena and Stotzky, 2001a; Zwahlen et al., 2003; Clark et al., 2006; Vercesi et al., 2006; Krogh
et al., 2007). Similarly, Birch et al. (2007) detected transient and site-specific reductions in the
biomass of oribatid mites and total microarthropods in fields under Bt and non-Bt com.
However, the differences between populations under different non-Bt com varieties were often
of the same magnitude as those between Bt and non-Bt com; this led to the conclusion that the
effects in the field were varietal effects and not due specifically to the Bt trait (Cortet et al.,
2006).
When the effects of Bt toxins on nematodes were studied, season, soil tillage, soil type, crop
type, and cultivar influenced nematode number to a greater extent than whether the corn was a Bt
variety. Under field cultivation for Bt-crops with the Cry3Bbl protein and non-Bt crops, no
effect was detected on the abundance of the nematode Caenorhabditis elegam on com (Al-Deeb
et al., 2003, com) or on the relative abundance of species of nematodes in the soil with eggplant
(Manachini, 2003; eggplant, cited by Icoz and Stotzky, 2008). When soils from Bt com with the
CrylAb protein and non-Bt com in cultivation were compared, there were no effects on
nematode communities and diversity (Manachini, 2003; cited by Icoz and Stotzky, 2008) or on
the nematode Pratylenchus spp. (Lang et al., 2006). However, in experiments in cultivated Bt
and non-Bt com fields, adverse effects on growth and abundance of C. elegans were observed
(Manachini, 2003; Lang et al., 2006; cited by Icoz and Stotzky, 2008), and a lower abundance of
natural populations occurred transiently in Bt fields and consistently at one Bt site (Griffiths et
al, 2005; Griffiths et al, 2006).
Similarly, the CrylAb insecticidal protein for European corn borer control had less effect on
the bacterial community structure than other environmental factors (Baumgarte and Tebbe,
2005). In one study, a transient decrease occurred in the numbers of protozoa in soil with Bt corn
under field conditions (Griffiths et al, 2005); otherwise, no toxic effects of the Cry proteins on
protozoa have been observed (Donegan et al, 1995; Saxena and Stotzky, 2001a; Griffiths et al,
2005; Icoz and Stotzky, 2008). No changes in microbial activity and other assays (i.e., nitrogen
mineralization potential, short-term nitrification, and soil respiration rate) occurred when soils
cropped with com that produced the Cry3Bb toxin for com rootworm protection were compared
with soils cropped with the nontransgenic isoline (Devare et al, 2004; Devare et al, 2007).
Those studies have indicated that Bt and non-Bt crops have comparable effects on soil bacteria
and protozoa.
Rates of residue decomposition and the associated accumulation of soil organic matter affect
soil productivity and soil ecological functions; therefore, if residues of Bt com differ from
residues of non-Bt com in decomposition rates, there might be long-term implications for soil
quality and soil carbon sequestration. Reduced decomposition rates might increase the time that
Bt toxins remain in the environment Chemical bonds in lignins are more resistant to microbial
decomposition than other chemical bonds in plant cells. Some studies have demonstrated higher
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lignin content in Bt com hybrids compared to their respective isoiines (or near-isolines) (Saxena
and Stotzky, 200 !b; Poerschmann et a!., 2005), but other studies have found no differences (Jung
and Sheaffer, 2004). Decomposition rates have more importance for soil quality than relative
lignin contact. In some laboratory research, plant residue of Bt hybrids decomposed at a lower
rale in soil than residue of non-Bt hybrids (Flores et al., 2005), but field studies have not detected
differences in decomposition rates (Lehman et al, 2008). Similarly, Hopkins and Gregorich
(2003) reported no differences in carbon dioxide production from Bt and non-Bt com in soil over
a 43-day incubation period. No differences in mass losses in the field were detected between Bt-
glyphosate-resistant and glyphosate-resistant cotton lines, indicating that there were no
differences in the rate of decomposition or change in nutrient content in the litter over the 20-
week experiment (Lachnicht et al, 2004). When the whole soil organism community was
allowed to access the residue, the decomposition of Bt and non-Bt residue was similar (Zwahlen
et al, 2007). Tarkalson et al. (2008) also reported no differences in residue decomposition rates
or in mass of total carbon remaining over time betw'een Bt and non-Bt corn hybrids observed in a
field study although the study did detect differences in rates of decomposition for leaf, stalk, and
cob plant parts. Finally, after seven years of continuous corn cultivation, no differences between
Bt and non-Bt com treatments were detected in total carbon or nitrogen in soil, indicating that
plant decomposition rates were similar (Kravchenko et al, 2009). On the basis of those studies,
the plant residue from Bt and non-Bt com hybrids decomposed at similar rates and would have
similar effects on soil quality and on potential carbon sequestration.
Evolution and Management of Insect Resistance
Evolution of Resistance
Insects can adapt to toxins and other tactics used to control them (Palumbi, 2001; Onstad,
2008). When Bt crops were first considered for commercial introduction, EPA recognized their
potential to reduce human and environmental exposure to broad-spectrum insecticides, increase
growers’ ability to manage pests and improve crop quality, and increase profits at the farm and
industry levels (Berwald et al, 2006; Matten ct al, 2008). Those benefits had already been
demonstrated by sprayed Bt insecticides that are critical pest-management tools for many fruit
and vegetable crops in the United States (K. Walker et al, 2003). As the regulatory agency
overseeing the introduction of biological pesticides, EPA concluded that the potential for rapid
evolution of insect resistance to Bt toxins produced by GE crops was a threat to the benefits
provided by Bt crops and to the efficacy of Bt sprays in organic and conventional production
systems (Matten et al, 2008; Thompson et al, 2008). Accordingly, it mandated the use of a
refuge strategy (described later in this chapter) to delay the evolution of resistance in major
insect pests controlled by Bt corn and cotton (US-EPA, 2008a).
Extensive monitoring of 1 1 major lepidopteran pests of com and cotton over the last 14 years
has revealed that some populations of one moth species, cotton bollworm {Helicoverpa zed),
evolved resistance to the Bt toxins Cry 1 Ac and Cry2Ab found in some cotton cultivars in the
United States (Tabashnik and Carriere, 2008; Tabashnik et al, 2008; Tabashnik et al, 2009a). In
addition, some populations of fall armyworm evolved resistance to CtylF com in Puerto Rico
(Matten et al, 2008), and some populations of com stem borer (Busseola fused) evolved
resistance to Cry lAb com in South Africa (van Rensburg, 2007; Kruger et al, 2009).
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That resistance has evolved in only three pest species in the last 14 years suggests that the
refuge strategy has successfully delayed the evolution of resistance to Bt toxins (Tabashnik et al.,
2008; Tabashnik et al., 2009a). Comparisons between pests that have and have not evolved
resistance to Bt crops suggest that recessive inheritance of resistance and abundant refuges of
non-Bt host plants are two key factors that delay the evolution of resistance (Tabashnik et al.,
2008; Tabashnik et al., 2009a). In accordance with these findings, EPA demands that GE seed
companies require producers to plant refuges to delay the evolution of resistance where such
refuges are deemed necessary and develop compliance assurance programs (Thompson et al.,
2008). The promotion of precise resistance-management guidelines by the industry has
undoubtedly contributed to increasing the use of refuges for managing the evolution of resistance
to Bt crops in the United States. In some regions, compliance to the mandated refuge strategies
has been high since the introduction of Bt crops (Carriere et al., 2005). However, levels of
compliance have substantially and regularly declined in other parts of the country, possibly
because the use of Bt crops has increased globally and producers can no longer rely on non-Bt
users to provide refuges for their farms (Jaffe, 2009).
Although the theory, resistance-monitoring data, and experimental work conducted in the
laboratory suggest the refuge strategy has been useful, detailed field experiments are still needed
to demonstrate how the refuge strategy can delay the evolution of resistance to Bt crops. There is
usually a delay between the introduction of a novel pesticide and the rapid rise in the number of
species that have evolved resistance to it (Georghiou, 1986). That is illustrated in a comparison
of the cumulative number of cotton pests that evolved resistance to Bt toxins in crops and to the
insecticide dichlorodiphenyltrichloroethane (DDT) after the introduction of these pest-
management tools in the United States (Figure 2-9).
After commercialization of Bt cotton in 1996, its use increased rapidly in the United States.
Similarly, the use of DDT in cotton increased rapidly after it became widely commercially
available in 1946. For example, 90 percent of agricultural DDT applications in the United States
targeted cotton pests in 1962 (Walker et al., 2003). Similar to Bt cotton that produces high
concentrations of Bt toxins over much of die growing season, DDT was applied repeatedly in
cotton and retained toxicity for extended periods (US-EPA, 2000). The recessive mutations kdr
and super-kdr confer recessive resistance to DDT in many agricultural pests (Davies et al., 2007;
APRD, 2009); this is similar to the inheritance of resistance to Bt toxins in cotton, which is often
recessive (Tabashnik et al., 2008).
With respect to the evolution of resistance, Bt cotton and DDT differ in at least two
important ways. First, DDT kills a wide array of insects regardless of their feeding habits
whereas Bt cotton kills only some lepidopteran pests that feed on the cotton. Second, no refuge
strategy was mandated to manage die evolution of insect resistance to DDT. Those differences
suggest that the evolution of DDT resistance in cotton pests should have been more rapid than
the evolution of resistance to Bt cotton. However, the cumulative number of cotton pests that
evolved resistance to Bt cotton and the number that evolved resistance to DDT after their
introduction in the United States have been strikingly similar (Figure 2-9). That comparison
indicates that it may still be too soon to claim that the refuge strategy has substantially delayed
the accumulation of pests resistant to Bt. While seed companies are in a better position to
commercialize more efficient Bt cultivars for delaying the evolution of resistance (see below),
the possibility remains that the accumulation of resistant pests could accelerate. Thus,
complacency in the implementation of resistance-management strategies is not warranted
(Hurley and Mitchell, 2008; Jaffe, 2009; Tabashnik et al., 2009a).
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FIGURE 2-9 Cumulative number of cotton pests evolving resistance to Bt cotton and DDT in
the years after these management tools became widely used in the United States.
SOURCE: APRD, 2009.
Principles of Population Genetics Underlying the Refuge Strategy
Population-genetic models and empirical data on factors that affect the evolution of insect
resistance to Bt crops have been central in the development of the refuge strategy. Models
generally assume that resistance to a toxin produced by Bt crops is conferred by mutations at a
single locus (gene location) (Gould, 1998; Tabashnik and Carriere, 2008). That is a reasonable
assumption because resistance to the intense selection imposed by Bt crops and insecticides is
likely to involve genes that have major effects (Carriere and RoiT, 1995; McKenzie, 1996).
Furthermore, most of the observed cases of evolved resistance to Bt crops have involved
mutations at a single locus (Gahan et al., 2001; Morin et al., 2003; Yang et al., 2007; Pereira et
al., 2008). For simplicity, models assume the presence of one allele that confers susceptibility
and one allele that confers resistance even if more than one allele at a single locus can confer
resistance to Bt crops (Morin et al., 2003; Yang et al., 2007).
The refuge strategy relies on two basic principles. The first principle is that the dominance of
resistance*^ is reduced by increasing the dose of Bt toxins (Gould, 1998; Tabashnik et al., 2004).
When the concentration of a Bt toxin in a plant is low, the resistance trait in the insect population
is nonrecessive, but when it is high, the resistance trait in the insect population becomes
recessive, and resistance becomes rarer. Accordingly, resistance to commercialized GE crops
’”The dominance of resistance depends on die response of heterozygoles compared to the response of
homozygous-susceptible individuals and homoi^gous-resistant individuals. If heterozygotes respond like
homozygous-susceptible individuals, resistance is recessive; if heterozygotes respond like homozygous-resistant
individuals, resistance is dominant.
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that produce high concentrations of Bt toxins is recessive in many, but not ail, target pests
(Tabashnik et al., 2008). The refuge strategy requires the presence of refuges of non-GE host
plants in or near Bt crop fields (US-EPA, 2008b, a). For refuges to be effective, the susceptible
insects produced in refuges must be in sufficient numbers and mate with the rare resistant pests
that survive on GE crops. With effective reftiges and recessive resistance, most hybrid offspring
produced by resistant pests that survive on Bt crops are killed when they feed on GE crops. That
reduces the heritability of resistance (the degree of genetic similarity between resistant parents
that survive on Bt crops and their offspring) and delays its evolution (Gould, 1998; Sisterson et
al., 2004a; Tabashnik and Carriere, 2008).
The second principle underlying the refuge strategy is that the evolution of resistance can be
delayed or prevented by reducing the selective differential between individuals with and without
resistance alleles (Gould, 1998; Carriere and Tabashnik, 2001; Andow and Ives, 2002;
Tabashnik et al., 2005; Crowder and Carriere, 2009). The selective differential between resistant
and susceptible individuals can be affected by crop-management practices, such as increasing
refuge size that increases relative fitness of susceptible individuals (Mitchell and Onstad, 2005;
Onstad, 2008). In fields of Bt crops, where resistant individuals are more abundant than
susceptible individuals, the selective differential between resistant and susceptible individuals
can be reduced by such crop-management practices as pheromone mating disruption and the
elimination of crop residues that contain insects (Andow and Ives, 2002; Yves Carriere et al.,
2004).
The selective differential between resistant and susceptible individuals can also be affected
by pest biology and genetics. Fitness costs associated with resistance to Bt toxins occur in
environments that lack Bt toxins if individuals with one or more resistance alleles have lower
fitness than individuals without such alleles (Gassmann et al, 2009). Fitness costs of Bt
resistance are found in many species and select against resistance in environments where Bt
toxins are absent; this selection counterbalances selection that favors an increase in resistance in
fields of Bt crops (Gassmann et al., 2009). Fitness costs expressed in heterozygous individuals
are nonrecessive; costs expressed only in homozygous resistant individuals are recessive.
Nonrecessive fitness costs can delay the evolution of resistance more effectively than recessive
fitness costs because alleles that confer resistance to Bt crops are often rare (Gould et al., 1997;
Andow et al, 2000; Tabashnik et al, 2006; Mahon et al, 2007), so most resistance alleles in
pests targeted by Bt crops are carried by heterozygous individuals. With nonrecessive fitness
costs, the fitness of resistant heterozygous individuals is lower than the fitness of susceptible
individuals in refuges, and such costs can strongly select for a decline In resistance despite the
fact that selection favors resistant individuals on Bt crops (Gassmann et al, 2009). In other
words, recessive costs that influence only the rare homozygous resistant individuals are less
effective in delaying resistance than nonrecessive costs that influence the more abundant
resistant heterozygous individuals.
Incomplete resistance occurs when the fitness of resistant individuals is lower on Bt cultivars
than on corresponding non-Bt cultivars (Carriere and Tabashnik, 2001). It occurs because the
individuals that do survive on Bt crops are nevertheless affected adversely by Bt toxins (for
example, larvae take a long time to develop on the Bt crop, and the resulting moths are smaller
and less fecund). Incomplete resistance is found in many species and contributes to delaying the
evolution of resistance by reducing the selective differential between resistant and susceptible
individuals (Carriere and Tabashnik, 2001; Tabashnik et al., 2005; Crowder and Carriere, 2009).
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The Pyramid Strategy
The first IR crops produced a single Bt toxin. More recently, the “pyramid” strategy has used
GE crops that produce two distinct Bt toxins for delaying pest resistance. The pyramid strategy is
based on the principle that insects are killed on two-toxin plants as long as they have a
susceptibility allele at a resistance locus — a phenomenon called redundant killing (Gould, 1998;
Roush, 1998). As resistance alleles are generally rare, the only genotype that has high survival on
a cultivar that produces two or more Bt toxins is expected to be extremely rare. Accordingly, the
refuge strategy is considered more effective in reducing the heritability of resistance when crops
produce more than one Bt toxin than when they produce a single Bt toxin (Gould, 1998; Roush,
1998; Gould et al., 2006). Models suggest that the pyramid strategy is most effective when the
majority of susceptible pests are killed by the GE crop, resistance to each Bt toxin is recessive,
fitness costs and refuges are present, and selection with one Bt toxin does not cause cross-
resistance to another (Gould, 1998; Zhao et al., 2005; Gould et al., 2006). Cross-resistance to Bt
occurs when a genetically based decrease in susceptibility to one toxin decreases susceptibility to
other toxins.
Changes in Refuge Strategy in the United States
In a process that aims to use scientific knowledge to balance economic and environmental
considerations, refuge strategies for Bt com and cotton mandated by EPA have been improved
since the commercialization of these GE crops in 1996. EPA specifies the area, configuration,
and types of refuges to be used with specific Bt crops. Changes in refuge requirements have been
based on input from academe, farmers, and industry. Some of the changes have made refuge
requirements more stringent, while others have eliminated refuge requirements. For example,
refuge distance requirements for the use of Bt cotton against pink bollworm were unspecified
from 1996 to 2000, unless the percentage of Bt cotton in a county exceeded 75 percent in the
previous year (US-EPA, 1998; Carriere et al., 2001). However, on the basis of the principle that
refuges must be near Bt crops to promote the desired mating between susceptible and resistant
insects, new regulations enacted in 2001 limited the distance between refuges and Bt cotton
regardless of the percentage of Bt cotton in the previous year (Tabashnik et al, 1999; Carriere et
al, 2001; US-EPA, 2001; Y. Carriere et al, 2004). Since 2006, in response to a proposal from
cotton growers to eradicate pink bollworm in Arizona, EPA has allowed use of mass release of
sterile pink bollworm moths as an alternative to non-Bt cotton refuges (US-EPA, 2006a).
In another example, in response to a proposal from Monsanto, the refuge requirement of non-
Bt cotton cultivars w-as abolished from Texas to the Mid-Atlantic to manage resistance of
tobacco budworm {Heliothis virescens) and cotton bollworm {Helicoverpa zea) to Monsanto’s
pyramided Bt cotton cultivar that produces the toxins Cry 1 Ac and Cry2Ab (US-EPA, 2007) and
subsequently to a cultivar from Dow AgroSciences producing Cryl Ac and CrylF. The proposal
included new data and modeling results that indicated that weeds and non-Bt crops other than
cotton might provide sufficient refuges to delay Bt resistance in the two mobile, polyphagous
pests (US-EPA, 2006b). The 2007 change by EPA meant that refuges of non-Bt cotton are no
longer required for millions of acres of the Monsanto cotton cultivar grown in large areas of the
United States. Assuming that no other factors changed (e.g., the technology fee), that action
would improve the net benefits to farmers of growing the GE cotton and increase its adoption
(Luna V et al, 2001; Matus-Cadiz et al, 2004) at least in the short tenn. However, it is
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noteworthy that decreased susceptibility to both CrylAc and Cry2Ab in cotton bollworm {H.
zed) has indicated that this pest is evolving resistance to cotton producing those toxins in the
United States (Tabashnik et a!., 2008; Tabashnik et al., 2009b).
It appears likely that most Bt crops commercialized in the future by biotechnology
companies will produce tw’o or more Bt toxins for the control of individual insect pest species
(Bravo and Soberon, 2008; Matten et al,, 2008). That could improve the durability of Bt crops if
few other major insect pests targeted by Bt crops evolve resistance before the replacement of
one-toxin crops by pyramids, and if populations of pests that are resisUint to single-toxin Bt crops
remain rare. EPA promotes the replacement of one-toxin Bt cultivars with two-toxin Bt cultivars
on the basis of recognition that the evolution of resistance is more effectively delayed with a
pyramid strategy than with one-toxin crops (Matten et al, 2008). Another incentive to
eliminating the use of one-toxin Bt cultivars when two-toxin Bt cultivars are introduced is that
results from simulation models and small-scale laboratory experiments indicate that the
evolution of resistance to two-toxin cultivars is accelerated when plants that produce two Bt
toxins are grown near plants that produce Just one toxin (Roush, 1998; Gould, 2003; Zhao et al.,
2005).
So far, the complete replacement of one-toxin with two-toxin Bt cultivars has occurred only
in Australia (Baker et al, 2008). The Transgenic and Insecticide Management Strategy
committee, which comprises growers, consultants, researchers, seed companies, and chemical
industry, has overseen the development, implementation, and evaluation of resistance-
management strategies for Bt cotton in Australia (Fitt, 2003). Cotton that produces the Bt toxin
CrylAc for the control of cotton bollworm {Helicoverpa armigerd) was replaced by cotton
producing CrylAc and Cry2Ab in 2004. That allowed producers to reduce the area of refuges
from 70 percent with CrylAc cotton to as low as 5 percent with CrylAc and Cry2Ab cotton
(Baker et al, 2008). The exclusive use of a pyramid strategy for managing the evolution of Bt
resistance in insect pests might allow producers to use more Bt crops while maintaining efficient
resistance management (Mahon et al, 2007; Baker et al, 2008). However, an allele conferring
high levels of resistance to Cry2Ab has been found in relatively high frequency (0.0033) in field
populations of cotton bollworm {H. armigerd), and individuals homozygous for this allele can
survive on mature cotton producing the toxins CrylAc and Cry2Ab (Mahon et al, 2007; Mahon
and Olsen, 2009). This indicates that a key assumption of the pyramid strategy is not met (i.e.,
redundant killing), and thus that caution should be used to manage the evolution of cotton
bollworm resistance to CrylAc and Cry2Ab cotton in Australia.
Agricultural and Environmental Impacts of Insect Resistance to Bt Crops
The refuge strategy was mandated in the United States not only to slow the evolution of
resistance to Bt cultivars but also to protect the effectiveness of Bt sprays. Susceptibility to
sprays with many Bt toxins in pests that evolve resistance to single-toxin Bt crops will depend on
several factors, including the level of resistance, the variety and concentration of the toxins in the
sprays, and the extent of cross-resistance to different toxins. If a spray contains one or more
toxins to which the pest has evolved resistance or cross-resistance, susceptibility to the spray
could be decreased (Tabashnik et al, 1993; Moar et al, 1995). Nonetheless, sprays containing
one or more toxins that kill pests that are resistant to other toxins can be useful against such pests
(Tabashnik et al, 1993; Liu et al, 1996; Akhurst et al, 2003; Wang et al, 2007).
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Along with other insecticidal compounds with different modes of action, many sprayed Bt
insecticides commonly used in the United States contain at least two Cry toxins that differ
substantially from each other in amino acid sequence and that bind to different target sites in the
larval midgut (Schnepf et ai., 1998; Ferre and Van Rie, 2002; Crickmore et ai., 2009). The few
pests that have evolved resistance to Bt crops could remain susceptible to sprayed Bt insecticides
that contain many Bt toxins, as long as Uie evolution of resistance to the toxins in Bt crops does
not involve strong cross-resistance to all the toxins in Bt sprays. Cross-resistance between Bt
toxins that differ substantially in amino acid sequence is usually weak or nil, but exceptions
occur in important pests that are targeted by Bt crops, including cotton bollworm {H. zed)
(Hernandez-Martinez et al., 2009; Tabashnik et al., 2009b). However, the possibility of cross-
resistance in com stem borer and fall armyworm has not been investigated extensively. The
agricultural and environmental impacts of cross-resistance between single-toxin Bt crops and
multitoxin Bt sprays will also depend on the extent to which the two approaches are used to
control a given pest and on pest movement between Bt crops and areas where Bt sprays are used.
EPA requires remedial action plans to address cases of resistance, which can involve
cessation of use of a particular Bt cultivar in a specific area (US-EPA, 1998; Carriere et al.,
2001; US-EPA, 2001). Sales of com that produce the Bt toxin CrylF were suspended voluntarily
in Puerto Rico after the evolution of resistance to CrylF in fall armyworm (Matten et a!., 2008).
In the absence of published information on the distribution of resistance and on the presence of
cross-resistance and fitness costs, it is not possible to assess whether the evolution of resistance
to CrylF in fall annyworm threatens the sustainability of other Bt crops or sprayed Bt
insecticides in Puerto Rico. Furthermore, the economic and environmental consequences of Bt
resistance are difficult to assess because little information is available on the profitability of
CrylF com in Puerto Rico and on how withdrawal of CrylF com in Puerto Rico has affected
insecticide use.
In contrast, the evolution of resistance of cotton bollworm {H. zed) to CrylAc cotton In the
United States did not have serious agronomic, economic, or environmental consequences. That is
because resistance did not affect many bollworm populations, CrylAc cotton still provides some
control of Ciyl Ac-resistant insects, synthetic insecticides were used in conjunction with CrylAc
cotton from the onset to control bollworm, and the widespread use of cotton that produces both
CrylAc and Cry2Ab in the states where resistance occurred provided effective control of insects
that were resistant to CrylAc (Tabashnik et al., 2008). Data on increased bollworm survival on
cotton plants that produce CrylAc and Cry2Ab in the field or on the consequences of field-
evolved resistance to Cry2Ab are lacking (Tabashnik et ai., 2009b). Although there is strong
evidence of resistance to CrylAc in some populations of bollworm in the Southeast (Tabashnik
and Carriere, 2009; Tabashnik et al., 2009a), a subset of the data has been contested by some
scientists (Moar et ai., 2008), and EPA has not commented on the situation.
GENE FLOW AND GENETICALLY ENGINEERED CROPS
This section presents an overview of the potential of gene flow to weedy relatives for crops
for which GE varieties have been developed (though not all of these varieties have been
commercialized). The movement of herbicide resistance into weedy relatives present on farm
fields can influence farmers’ weed-management strategies. Gene flow between GE and non-GE
crops could accelerate the evolution of pest resistance to Bt crops, if many Bt plants are routinely
present in refuges of non-Bt crops (Heuberger et al., 2009; Krupke et al., 2009). The following
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section specifically considers factors that ^cct gene flow via cross-pollination within crops, on
which the coexistence of GE and non-GE crops depends. Chapter 3 addresses other sources of
gene flow, such as co-mingling of seed and germination of volunteer seeds left behind, and the
economic consequences of gene flow between GE and non-GE varieties.
Gene Flow Between Genetically Engineered and Non-Genetically Engineered Crops
The potential for cross-|X)!Hnation between GE and non-GE crops depends on the plant
species (Ellstrand, 2003a). In particular, the reproductive strategy of a crop determines the
degree of gene flow between GE and non-GE crops; open-pollinated crops (such as com) have
the greatest probability of cross-pollination between GE and non-GE cultivars. Even in self-
pollinated plants, out-crossing occurs occasionally, the rate depending on the particular species
and environment. In soybean, for example, out-crossing is occasional (Palmer et al., 2001 ; Abud
et al., 2004; Abud et al., 2007). In contrast, com is freely out-crossing, so the cross-pollination of
non-GE cultivars with pollen from GE varieties depends on the distance from the source and
other factors. Models of pollen dispersal in com and the consequent gene flow may have low
precision, particularly in light of the small amounts of pollen that move more than 800 ft and the
substantial impacts of climate (Ashton et al., 2000).
Among the factoid that control gene flow between populations of wind-pollinated plants are
distance from the pollen source and pollen shed density, time required for pollen movement,
wind speed and direction, air temperature, and relative humidity (Luna V et al., 2001; Westgate
et al., 2003). Pollen viability declines quickly with desiccation. Even if pollen is dispensed over
great distances, it may, if dried out, not be viable. Similarly, the occurrence of GE pollen in a
non-GE corn field does not necessarily mean that pollination will occur (Fell and Schmid, 2002).
Nonetheless, the distances needed to prevent any cross-pollination in com or other open-
pollinated crops are so great that they are not practical in current commercial agricultural
systems (Luna V et al., 2001 ; Matus-Cadiz et a!., 2004).
Insect-mediated cross-pollination between GE and non-GE crops occurs in those species for
which insects typically are the agents of transfer of pollen between individuals (Van Deynze et
al., 2005; Llewellyn et al., 2007). Canola and cotton are modally out-crossing as a result of
pollinator activity, whereas soybean is usually self-pollinated but is visited by insects seeking its
pollen (Ahrent and Caviness, 1994; Walklate et al., 2004; Heuberger and Carriere, 2009). In a
recent study that monitored cross-pollination of seed-production fields of non-Bt cotton (some
HR, some not) by Bt cotton, both the density of flower-foraging honey bees in seed production
fields and the area of Bt cotton at a distance of 2,460 ft from the non-Bt cotton fields affected
cross-pollination (Heuberger and Carriere, 2009). It had been documented that most cross-
pollination in cotton occurs over distances of less than 160 ft (McGregor, 1976; Free, 1993;
Xanthopoulos and Kechagia, 2000; Zhang et al., 2005). Nevertheless, foraging honey bees can
easily travel two miles or more (Beekman and Ratnieks, 2000); this suggests that the 2,460-ft
radius at which pollen from Bt cotton influenced out-crossing of non-Bt cotton resulted from
movement of foraging honey bees from Bt to non-Bt cotton fields. Accordingly, the results of
Heuberger and Carriere (2009) indicate that small-scale gene-flow studies may miss occasional
long-distance cross-pollination between GE and non-GE insect-pollinated crops.
As the adventitious presence of GE traits is widespread in the seed supply of non-GE crops,
gene flow between non-GE and GE crops may commonly involve cross-pollination by plants
from the same field (i.e., adventitious plants). Heuberger and Carriere (2009) found adventitious
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Bt cotton plants in 67 percent of seed-production fields of non-Bt cotton. They demonstrated that
adventitious Bt plants resulted both from human error (inadvertent planting of Bt cotton in non-
Bt cotton fields) and from contamination in seed bags. After accounting for the effect of the area
of Bt cotton surrounding a seed production field and the abundance of foraging honey bees, the
density of adventitious Bt plants was positively associated with out-crossing rates in seed-
production fields. Most models of pollen transfer between crop varieties have not considered the
adventitious presence of GE plants in non-GE fields and may therefore fall short of making
accurate predictions of the abundance of GE traits in supposedly non-GE plants.
Canola is not a major crop in the United States, but substantial acreage is planted in North
Dakota, which accounted for more than 87 percent of U.S. canola planted in 2009 (USDA-
NASS, 2009b). Gene flow l^tween GE and non-GE canola is well documented in the large
canola-growing region of western Canada; it can be facilitated by the transient populations of
canola established each year outside agricultural fields (Knispel et al., 2008). Genetically
engineered HR canola cultivars are the dominant type, and in 2006, glyphosate-resistant and
glufosinate-resistant canola cultivars accounted 65 percent and 32 percent, respectively, of U.S.
canola acres planted (Howatt, 2008, personal communication). Given that there are two GE
herbicide-resistance traits (glyphosate and glufosinate) and a non-GE imidazolinone-resistant
trait, introgression of these traits can result in multiple-herbicide resistance in a single plant
(Knispel et al., 2008). The occurrence of multiple-herbicide-resistant volunteer canola increases
the difficulties of management (Beckie et al., 2004; Beckie, 2006; Beckie et ai., 2006). In
addition to the problem of deploying special management techniques for HR weeds, adventitious
presence of a GE trait in a non-GE field of canola has economic consequences.
Alfalfa is an important crop in the United States and is widely cultivated over a broad
geographic range (USDA-NASS, 2008). GE glyphosate-resistant alfalfa was commercialized in
2005, and about 198,000 acres were planted in 2006 (Weise, 2007). However, in 2007, it once
again became a regulated item, a decision that was upheld by the Court of Appeals in 2008.
USDA Animal and Plant Health Inspection Service (APHIS) was ordered to conduct an
environmental impact statement (EIS) because of “the significant threat of gene flow and the
development of Roundup-resistant weeds that requires further study and analysis in an EIS”
(Geertson Farms Inc., 2009).^' APHIS released the draft EIS for public comment in December
2009.
Sugar beet {Beta vulgaris) cultivars with the GE trait that confer resistance to glyphosate
have been commercialized and were widely adopted by growers in the United States. However,
in September 2009, the Northern California District Court ruled that USDA violated the National
Environmental Protection Act when it deregulated HR sugar beets, and USDA is required by the
court to prepare an environmental impact statement to adequately consider the impacts of GE
sugar beets on other sugar beet growers as well as farmers growing table beets and swiss chard,
two crops with which sugar beets may cross pollinate {Center for Food Safety v. Thomas J
Vilsack, 2009).
’ ’Roundup is the trademarked name of glyphosate sold by Monsanto.
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Gene Flow between Genetically Engineered Crops and Related Weed Species
In locations where crop varieties occur with wild or weedy populations of the same or closely
related species, interbreeding between a crop and its relatives may lead to exchange of genes
between the cultivars or species involved Such hybridization is common in plants generally and
is a key process for the evolution of new plant species. When gene flow occurs between crops
and their wild relatives, an agronomic characteristic may move into the wild populations.
Environmental sustainability on farms might be affected by the consequences of such gene flow
between crops and wild relatives if the gene flow reduces genetic diversity available for crop
improvement. However, only a few crops (sunflower, pecan, blueberry, and some squashes)
were domesticated within the borders of the United States, so most crops planted on U.S. farms
do not pose a risk to the conservation of genetic diversity in related native species and landraces.
When crop species coexist with weedy relatives, gene flow might result in a weed-management
issue and any accompanying economic and environmental effects. At least 15 crop species have
been documented to hybridize with weedy relatives in the United States (Keeler et al., 1996). For
HR traits, hybridization is a mechanism by which herbicide resistance might evolve in related
weeds if HR crops are able to interbreed with related weedy species occurring in the same
location (see the canola example in “Developing Weed-Management Strategies in Herbicide-
Resistant Crops” earlier in this chapter).
In the United States for com and soybean, the most common GE crops grown, no genetically
compatible relatives or weedy strains exist; therefore, movement of GE traits into related weed
species is not an issue. Wild populations of cotton {Gossypium hirsutum) exist along the Gulf
Coast and a wild relative {Gossypium tomentosum) is in Hawaii. Gene flow is unlikely because
the United States prohibits the commercial sale of Bt cotton in those areas. In Hawaii, test
varieties and nursery stock can be produced, but with restrictions to minimize gene flow (e.g.,
US-EPA, 2005). In contrast, the use of HR crops in the same areas is apparently not more
restricted than in the rest of the United States (USDA-APHIS, 2008).
Hybridization between the allotctraploid canola (Brassica napus) and one of its diploid
weedy parents, turnip mustard (Brassica rapa) are extensive, and the hybrids are usually about
60 percent pollen fertile (Warwick et al., 2003; Leg^re, 2005; Simard et al., 2006), thus
facilitating the spread of a GE trait into the weeds. GE herbicide-resistant traits have been
reported to persist in populations of turnip mustard as they have in several other species of weeds
(Warwick et al., 2003; Owen and Zelaya, 2005; York et al., 2005; Warwick et al., 2008). In
addition, hybridization is possible between canola and species of a few related genera of
mustards, some of them weedy (Warwick et al., 2000; FitzJohn et al., 2007) and occurs
spontaneously when they are grown together in an experimental garden. For these reasons,
canola has been designated as a moderate-risk crop with regard to the potential for gene flow to
its weedy relatives (Stewart et al., 2003), and farm-level effects may occur in canola-growing
regions as discussed earlier. The extent to which they have economic impacts and affect
environmental sustainability will depend on how the weeds are managed.
Gene flow has been demonstrated from sugar beet to near-relative weeds, B. macrocarpa and
B. vulgaris subsp. maritime (Andersen et al., 2005). Thus, the introgression of HR traits from
GE sugar beets to weedy beets (B. vulgaris) and sea beets (B. vulgaris subsp. maritima) should
be considered a moderate risk (Stewart et al., 2003), but the consequences of gene flow would
occur on a very small spatial scale in the United States. Co-occurrence of those species with
sugar beet cultivation was limited to two California counties (Kem and Imperial) in 2006
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(Caiflora, 2009). Weedy beets are sporadic and local in the United States and not considered a
major problem, as they are in Europe, where the species is native.
Transgenic virus-resistant squash has been available commercially since 1995 and was
estimated to have been planted on an average of 12 percent of the 58,400 acres in squash
production in 2005 (Quemada et al., 2008). Wild populations of Cucurbita pepo occur in south
and central regions of the United States (Cowan and Smith, 1993) and cmi be an agricultural
weed (Oliver et al., 1983). Gene flow between conventional cultivars of domesticated C. pepo
and its wild populations is known to occur (Kirkpatrick and Wilson, 1988; Decker-Waiters et al,
2009). Data are not available yet on the extent to which transgenes may exist in wild populations.
As of 2005, the opportunity for gene flow across a large spatial scale appeared low because the
majority of transgenic squash cultivation occurs outside the range of the wild populations of C.
pepo (Quemada et al., 2008). The consequences of any gene flow to wild populations depend on
virus incidence, the expression of the transgene in the wild populations (Spencer and Snow,
2001; Fuchs et at., 2004a; Fuchs et al., 2004b; Laughlm etal., 2009; Sasu et al., 2009)
Concerns about the consequences of a transfer of GE traits to wild or weedy populations and
how to effectively mitigate those consequences have delayed the release of GE sunflower
{Helianthus annuus, a species that was domesticated in the United States), creeping bentgrass
{Agrostis stolonifera, a popular turf grass introduced from Europe), and rice (Oryza sativa, a
species native to Asia with related, intercompatible weeds introduced into some rice fields with
the crop). For sunflower, the potential for transgene movement to weedy relatives is quite high
and thus the consequences of gene flow on weed management presents an environmental
concern about the commercial development of transgenic sunflower (Snow and Palma, 1997;
Snow, 2002; Ellstrand, 2003b; Stewart et al., 2003). Wild sunflowers are weeds in row-crop
fields, including com, soybean, domesticated sunflower, wheat, and small grains (Bernards et al.,
2009). In a multiyear study conducted across the High Plains of the United States in a number of
commercial sunflower-production fields, it was observed that approximately 66 percent of the
fields existed near weedy sunflower (Burke et al., 2002). It is important that the cultivated and
weedy sunflowers flowered simultaneously (52-96 percent), and evidence of hybridization
ranged from 10 percent to 33 percent of the weedy sunflower (Burke et al., 2002). Evidence of
genes coding for herbicide resistance in cultivated sunflower moving to weedy sunflower
suggests that there is a substantial risk of the introgression of the trait into wild sunflower
populations, which might result in increased management problems for growers if the wild plants
are in cultivated fields (Marshall, 2001; Massinga and AI-Khatib, 2002; Massinga, 2003). These
management problems may emerge in association with sunflower varieties with resistance to the
herbicide imazamox that were developed using conventional breeding methods and not genetic
engineering. Hybrids of imazamox-resistant sunflowers and two interbreeding relatives appear to
be competitively equal to the HR domesticated sunflower, suggesting that the resistance gene
will persist when gene flow occurs (Massinga et al., 2005).
GE giyphosate-resistant creeping bentgrass was field-tested in Oregon in 2003, and
introgression of the transgene into weedy populations was detected at a considerable distance
from the test sites (Mallory-Smith et al., 2005; Reichman et al., 2006). The inability to mitigate
GE trait introgression into compatible weedy relatives of creeping bentgrass has delayed
commercialization of the GE creeping bentgrass product (Charles, 2007). The transfer of this
trait may be important if glyphosate is used to control weedy populations of the grass.
In the case of rice, GE glufosinate-resistant rice cultivars have been developed to improve
weed management of red rice {Oryza sativa L.), a common and important weed in commercial
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rice production. However, these GE cultivars have never been commercially available (Geaiy et
al, 2007) though they were first deregulated in 1998. The commercialization of rice with
resistance to the herbicide imazethapyr produced by a chemical-induced seed mutagenesis, not
genetic engineering) has resulted in the movement of this HR trait into red rice because total
control of red rice is not always possible (Burgos et al., 2008). Stewardship recommendations to
prevent and to control the spread of HR red rice exist and encourage crop diversity (BASF,
2009); data on the success of managing imazethapyr-resistant red rice may provide useful
information for the regulation of GE cultivars. In addition to concerns about introgression with
the weed red rice, GE rice has historically been unacceptable to consumers for the reasons
discussed in Chapter 1 (Geaiy and Dilday, 1997; Geaiy et al., 2003; Geaiy et al, 2007).
Wheat is a major grain crop in the United States, and there has been interest in
commercializing genetically engineered HR cultivars. The potential for introgression of a GE
trait into near-relative weed populations exists (EUstrand et al., 1999; Morrison et al., 2002;
Morrison et al., 2002; Stewart et al., 2003). Jointed goatgrass (Aegilops cylindrica) is reported to
be an important weed of small grains in Colorado, Kansas, New Mexico, Oklahoma, Oregon,
Utah, Washington, and Wyoming (NAPPO, 2003) and is a weed in the Great Plains
(Stubbendieck et al., 1994). Specifically, it causes serious problems in winter wheat in the
western United States due to its similarity to wheat in appearance, seed size, growth pattern, and
genetics (Schmaie et al., 2008; Schmale et a!., 2009; Yenish et al., 2009). Studies have
demonstrated hybridization with wheat varieties (Hanson et al., 2005; Rehman et al., 2006). It is
predicted that hybridization between HR wheat cultivars and Aegilops spp. will result in the
introgression of the HR trait and thus a more competitive weedy hybrid, complicating
management issues in wheat production (Hanson et al., 2005; Loureiro et al., 2008). Glyphosate-
resistant hard red spring wheat provided an opportunity for better weed management and resulted
in a 1 0-percent higher grain yield than conventional wheat cultivars treated with conventional
herbicides (Howatt et al, 2006). Despite the technical fit, the program to develop glyphosate-
resistant cultivars was postponed in 2004 because of regulatory and marketing issues, concern
for stewardship, and the inability to ensure the segregation of the GE wheat from non-GE wheat
grain at the time (Dill, 2005) (see Chapter 4 for further details). An Imazamox-resistant winter
wheat, which was bred using conventional techniques, has been commercially available since
2002, and the identical concerns about the development of HR jointed goatgrass biotypes exist
(Kniss et al, 2008).
The ecological and economic consequences of the introgression of GE traits into weedy or
native relatives will vary among types of GE traits (Owen, 2008). For HR crops, the
introgression of herbicide resistance from GE crops into weedy near-relatives is likely to have
consequences for weed management when weeds with the resistance trait occur in fields or other
ecosystems treated with the herbicide. Therefore, for future HR plants, understanding the extent
to which a herbicide controls weedy relatives will provide valuable information on the
consequences of gene flow for on-farm and off-farm weed management.
CONCLUSIONS
Environmental effects at the farm level have occurred as a result of the adoption of GE crops
and the agricultural practices that accompany their cultivation. The introduction of GE crops has
reduced pesticide use or the toxicity of pesticides used on fields where soybean, com, and cotton
are grown. Available evidence indicates that no-till practices and HR crops are complementary.
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and each has encouraged the other’s adoption. Conservation tillage, especially no-till, reduces
soil erosion and can improve soil quality. The pesticide shifts and increase in conservation tillage
with GE crops have generally benefited farmers who adopted them so far. Conservation tillage
practices can also improve water quality by reducing the volume of runoff from farms into
surface water, thereby reducing sedimentation and contamination from farm chemicals. Given
that agriculture is the largest cause of impaired quality of surface waters, that may constitute the
largest benefit of GE crops, but the infrastructure for tracking and understanding this does not
exist.
I'he effects of Bt crops on nontarget invertebrates, including predators, are favorable or
neutral, depending on the degree to which Bt crops replace insecticide treatment and on whether
additional insecticide treatments are applied to the Bt crop. Evidence indicates no effect of Bt
toxins on the honey bee, a widespread pollinator in agricultural systems. For HR crops, the
effects on the abundance of arthropods in the fields correlate with whether weeds are controlled
more effectively. Shifts in the weed communities have occurred in response to weed-
management tactics used for HR crops, in particular when weeds in glyphosate-resistant crops
are treated only with glyphosate. Similarly, glyphosate-resistant weeds have evolved where the
glyphosate application is repeated and constitutes the only weed-management tactic used. The
evolution of resistance to glyphosate in particular kinds of weeds and shifts in the weed
community may increase production costs for farmers, require more tillage for weed control, and
lead to at least a partial return to the use of different and often more toxic herbicides. The
development and establishment of more diversified control strategics for managing weeds in HR
crops is needed.
The first generation of IR crops commercialized in the United States produced a single Bt
toxin for the control of insect pests. Since the commercialization of those crops, EPA has
mandated the refuge strategy to delay the evolution of resistance in major insect pests that are
controlled by Bt com and cotton. After 1 4 years of use of Bt crops, two insect pests have evolved
resistance to Bt crops in the United States: cotton bollworm {Helicoverpa zed) evolved resistance
to CrylAc and Cry2Ab in Bt cotton, and fall armyworm evolved resistance to CrylF in Bt com.
The evolution in bollworm of resistance to Bt cotton did not have serious agronomic, economic,
or environmental consequences. Information for assessing the consequence of the evolution of
resistance to CrylF in Bt com in fall armyworm is lacking. The second generation of IR crops
produces two or more Bt toxins for the control of individual insect pest species. The complete
replacement of one-toxin with multitoxin Bt crops should help in delaying the evolution of
insect-pest resistance to IR crops.
The changes in weed and insect population densities resulting from the adoption of HR and
IR crops can affect farms beyond the boundaries of the operations that are using the GE crops.
That is, faraiing practices may have landscape as well as local level effects on pest populations.
For example, large-scale planting of IR crops has decreased populations of some insect pests
targeted by Bt crops not just at a farm-field level but on a regional scale. It can also affect local
and possibly landscape populations of non-target or beneficial organisms according to crop
species planted and management of pests, nutriente, water, and soil (Bjorklund et al., 1999;
Cattaneo et al., 2006; Dale and Polasky, 2007; Zhang et al., 2007; Carriere et al., 2009).
Beneficial organisms with high mobility move among habitats and crop fields, so effects within a
field that is planted to GE crops could influence beneficial organisms on other farms as well as
noncultivated habitats in the region.
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For com and soybean, gene flow tetween GE varieties and wild relatives is not an issue in
the United States because com and soybean have no wild relatives here. Limited overlap occurs
between cotton and wild relatives and l^tween sugar beet and introduced, weedy relatives. Gene
flow is unlikely for Bt cotton and wild relatives because of planting restrictions, but there are no
planting restrictions for HR cotton. Other crops in which gene flow with wild or weedy relatives
is possible include canola, alfalfa, sunflower, creeping bentgrass, wheat, and rice. Gene flow
between GE and non-GE crops occure via cross-pollination between GE and non-GE plants from
different fields, co-mingling of seed before or during the production year, and germination of
seeds that are left behind after die production year. Gene flow between GE and non-GE crops is
almost impossible to prevent completely with current technology. The complex interactions
among the multiple factors that influence gene flow between GE and non-GE crops and the
resulting levels of adventitious presences of GE traits in non-GE crops deserve more attention.
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Zelaya, I.A., and M.D.K. Owen. 2002. Amaranthus tuberculatus (Mq. ex DC) J. D. Sauer:
potential for selection of glyphosate resistance. In H. Spafford Jacob, J. Dodd, and J, H.
Moore ed., Vol. 13. Proceedings of the 13th Australian Weeds Conference, pp. 630-633.
at Perth, Australia. Council of Australian Weed Science Societies.
Zelaya, I.A., M.D.K. Owen, and M.J. VanGessel. 2004. Inheritance of evolved glyphosate
resistance in horseweed {Conyza canadensis (1.) Cronq.). Theoretical Applied Genetics
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(Asteraceae). American Journal of Botany 94(4):660-673.
Zhang, B.H., X.P. Pan, T.L. Guo, Q.L. Wang, and T.A. Anderson. 2005. Measuring gene flow in
the cultivation of transgenic cotton {Gossypium hirsutum L.). Molecular Biotechnology
3 1 ( 1 ): 11 - 20 .
Zhang, W., T.H. Ricketts, C. Kremen, K. Carney, and S.M. Swinton. 2007. Ecosystem services
and dis-services to agriculture. Ecological Economics 64(2):253-260.
Zhao, J.Z., J. Cao, H.L. Collins, S.L. Bates, R.T. Roush, E.D. Earle, and A.M. Shelton. 2005.
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Academy of Sciences of the United States of America 102(24):8426-8430.
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Zwahlen, C., W. Nentwig, F. Bigler, and A. Hilbeck. 2000. Tritrophic interactions of transgenic
Bacillus thuringiensis com, Anaphothrips obscurus (Thysanoptera: Thripidae), and the
predator Orim majusculus (Heteroptera: Anthocoridae). Environmental Entomology
29(4):846-850.
Zwahlen, C., A. Hilbeck, R. Howald, and W. Nentwig. 2003. Effects of transgenic Bt com litter
on the earthworm Lumhricus terrestris. Molecular Ecology 1 2(4): 1 077-1 086.
Zwahlen, C., A. Hilbeck, and W. Nentwig. 2007. Field decomposition of transgenic Bt maize
residue and the impact on non-target soil invertebrates. Plant and Soil 300(l-2):245-257.
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3
Farm-Level Economic Impacts
As shown in Chapter I, farmers growing soybean, cotton, and corn adopted genetically
engineered (GE) varieties over the last decade on the majority of acres planted to these crops in
the United States. Much smaller acreages were planted in 2009 to a few other GE crops, such as
canola, sugar beet, squash, and papaya. The decision to plant GE crops has affected the
economic circumstances not only of the adopting farmers but in some cases of farmers who
chose not to adopt them. The economic effects on farmers who adopt GE crops span their
production systems and marketing decisions. In this chapter, we discuss the potential yield
effects, changes in overhead expenses and management requirements, and shifts in market access
and value of sales. A wide array of studies conducted mostly during the first 5 years of adoption
has provided evidence for assessing the overall economic implications for farmers (see Box 3-1).
We also discuss here the economic effects of GE-crop use on livestock producers who use the
crops for feed and on farmers who do not elect to use the technology. The chapter concludes by
examining the economic implications of gene flow from GE crops to non-GE crops and weedy
relatives.
ECONOMIC IMPACTS ON ADOPTERS OF GENETICALLY ENGINEERED CROPS
GE crops have affected the economic status of adopters in several ways. The use of GE crops
has had an effect on yields and their risk-management decisions. Genetic-engineering technology
has also changed farmers’ production expenses and altered their decisions related to time
management. Furthermore, because of the widespread adoption of GE crops and their subsequent
impact on yields, genetic-engineering technology has influenced the prices received by U.S.
farmers.
Yield Effects
The first generation of GE varieties contains traits that control or facilitate the control of pest
damage. A starting point for analyzing the productivity effect of such control is the damage-
control framework (Lichtenberg and Zilberman, 1986) that was developed to estimate the
effectiveness of the use of chemical pesticides and other pest-control activities. The framework
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recognizes that damage-control agents, like pesticides and GE traits for pest management, have
an indirect effect on yield by reducing or facilitating the reduction of crop losses, in contrast with
such inputs as fertilizers, capital, and labor, which affect yields directly. In particular, the
framework assumes that
effective yield = (potential yieldXl - damage).
Potential yield is defined as the yield that would be realized in the absence of damage caused
by pests (i.e., weeds, insects).* It is a function of production inputs, such as water and fertilizer,
and of agroeco logical conditions and seed varieties. The yield actually observed is called
effective yield and is equal to potential yield minus damage. Damage is affected by the
pervasiveness of pests, which may be conttolled with pesticides, the adoption of GE varieties, or
other control activities. With that framework, the yield effects of GE varieties can be analyzed,
but spatial, temporal, and varietal factors must be taken into consideration.
' Damage may also be caused by weather conditions, such as wind, rain, drought, and frost, For
succinctness and convenience here, the definition of damage is restricted to pest problems.
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The indirect yield effects of the use of insect-resistant (IR) crops are most pronounced in
locations and years in which insect-pest pressures are high. For example, it is generally
recognized that the adoption of Bt com for European corn borer (Ostrinia mibilalis) control
resulted in annual average yield gains across the United Slates of 5-10 percent (Falck-Zepeda et
al., 2000b; Carpenter et a!., 2002; Femandez-Comejo and McBride, 2002; Naseem and Pray,
2004; Fernandez-Cornejo and Li, 2005). Empirical studies, however, have clearly indicated that
the indirect yield effects of Bt com hybrids for European com borer control vary temporally and
spatially. In years with high pressure — com borer damage of more than one tunnel per plant that
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exceeds 2 inches in length (Baute et al., 2002; Dillehay et a!., 2004)— the yield advantage for Bt
hybrids relative to near-isolines^ was 5.5 percent in Pennsylvania and Maryland (Dillehay et a!.,
2004), 6.6 percent in Wisconsin (Stanger and Lauer, 2006), 8 percent in New Jersey and
Delaware (Singer et ah, 2003), 9.4 percent in Iowa (Traore et al., 2000), and 9.5 percent in South
Dakota (Catangui and Berg, 2002). The yield advantage for Bt com was negligible in those
regions during years with low pest pressure (Traore et al, 2000; Catangui and Berg, 2002; Singer
et al, 2003; Dillehay et al, 2004; Stanger and Lauer, 2006). Likewise, in regions where
European com borer is an occasional pest, there was no indirect yield advantage from the use of
Bt hybrids in comparison to near-isolines (Cox and Chemey, 2001; Baute et al, 2002; Ma and
Subedi, 2005; Cox et al., 2009). Most of the early empirical studies, however, included some Bt
events^ that did not have season-long control of com borer, and this may have muted the yield
advantage of Bt hybrids (Traore et al, 2000; Catangui and Berg, 2002; Pilcher and Rice, 2003).
There have been fewer empirical studies of the yield effects of Bt corn for control of com
rootworm (Diabrotica spp.) than of the effects of Bt com for control of European com borer.
Rice (2004) estimated potential annual benefits if 10 million acres of Bt corn for com rootworm
control were planted. They included
• Intangible benefits to farmers (safety because of reduced exposure to insecticides, ease
and use of handling, and better pest control).
• Tangible economic benefits to farmers ($23 1 million from yield gains).
• Improved harvesting efficiency due to reduced stalk lodging.
• Increased yield protection (9 to 28 percent relative to that in the absence of insecticide
use and 1.5 to 4.5 percent relative to that with insecticide use).
• Reduction in insecticide use (a decrease of about 5.5 million pounds of active ingredient
per 10 million acres).
• Increased resource conservation (about 5.5 million gallons of water not used in
insecticide application).
• Conservation of aviation fuel (about 70,000 gallons not used in insecticide application).
• Reduced farm waste (about 1 million fewer insecticide containers used).
• Increased planting efficiency.
• improved safety of wildlife and other nontarget organisms.
A recent study by Ma et al (2009) indicated spatial and temporal variability in indirect yield
responses. Bt corn rootworm hybrids produced yields 11-66 percent larger than untreated near-
isoline hybrids. Bt yields were also larger than yields of the non-Bt hybrid variety planted on
clay soils and treated with insecticide in 1 of 3 years that had high infestations of western com
rootworm {Diabrotica virgifera virgifera). On sandy soils, where corn rootworm infestations are
typically much lower than on clay soils, yield differences also occurred between Bt com
rootworm hybrids and their near-isoJines with or without the standard soil-applied insecticide
*Near-isolines are cultivars that have the same or near genetic constitution (except for alleles at one or a
few loci) as the original cultivar from which they were developed. Near-transgenic isolines that have similar genetic
makeup except for the transgenic trait allow a comparison of the cultivar with or without the transgene for its
agronomic, quality, or nutritional aspects.
’Each seed company has different evente associated w'ith different insertion places of the Bt gene and
different promoter genes that allow a Bt toxin to be produced at different times of the season or in different plant
parts.
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treatment in 1 of 2 years. The study reported low levels of western com rootworm on droughty
sandy soil, however, and attributed yield increase to improved drought tolerance from the finer,
longer fibrous roots of the Bt hybrid com. Cox et al. (2009) found no yield advantage for com
hybrids with Bt rootworm control compared with near-isolines in a diy year when rootworm
damage did not occur.'*
Gray et al. (2007) expressed concern that one of the Bt com rootworm events was somewhat
susceptible to injury by a variant of western com rootworm in Illinois. Another Bt com
rootworm event, however, had superior control of western com rootworm larvae in Iowa,
Illinois, and Indiana (Harrington, 2006); this suggests that distinct Bt events from different seed
companies may differ somewhat in com rootworm control as they did initially in com borer
control. Cox et al. (2009) evaluated both Bt rootworm events on second-year com in field-scale
studies on four farms in New York and found that neither rootworm event provided a yield
advantage because rootwonn occuirence was low in all fields. As with Bt com for com borer, Bt
com for rootworm control did not provide an indirect yield benefit in the absence of pest
pressure.
Piggott and Marra (2007), relying on 1999-2005 university field-trial data from North
Carolina, found that Bt cotton with two endotoxins out-yielded conventional cotton by 128 more
lbs of lint per acre (14 percent of average yield In the region) and out-yielded Bt cotton with one
endotoxin by 80 Ib/acre (8 percent of average regional yield). A study of Bt cotton varieties with
two endotoxins in 13 southern locations that had mostly moderate to high infestations of cotton
bollworm (Helicoverpa zed), with or without foliar-applied insecticides, showed that indirect
yield effects had spatial variability. The Bt cotton cultivars without insecticide use provided
consistent control of the Heliothines (cotton bollworm and tobacco budworm, Heliothis
virescens), regardless of the magnitude of infestation (Siebert et al., 2008). Furthermore,
supplemental insecticide applications to the Bt cotton cultivars rarely improved control of
budworm and bollworm. In the low-infestation environments, however, the use of Bt cultivars
with or without insecticides provided no yield improvement relative to the control or the non-Bt
cultivar without insecticide application. In the moderate- to high-infestation environments, the Bt
cultivars provided the same 30-percent yield increase in lint yield with or without insecticides
compared with the control (Siebert et al., 2008). In a large-scale study of 81 commercial cotton
fields conducted in 2002 and 2003, average yield did not differ among Bt cotton, Bt cotton
resistant to glyphosate, and non-GE cotton (Cattaneo et al., 2006). However, after statistical
control for variation in two factors significantly associated with yield (number of applications of
synthetic insecticide and seeding rate), the yield of Bt cotton and Bt cotton with herbicide
resistance was significantly larger (by 8.6 percent) than the yield of non-GE cotton. A total of
eight GE cotton cultivars and 14 non-GE cultivars were included in the study. For those
‘‘As discussed in Chapter 1, all Bt rootworm com hybrids are treated with a low level of insecticide and
fungicide (typically a neonicotinoid). The low level (0.25 mg of active ingredient per seed) targets secondary pests
but does not affect com rootwonn. In fields planted continuously with com, the low level used with a soil-applied
insecticide resulted in lower com yields compared to a high level (1 .25 mg of active ingredient per seed) with a soil-
applied insecticide (Cox et al., 2007c). That is indirect evidence that the high level of seed-applied insecticide
increases control of com rootworm, but die low level does not. In addition, the low and high levels of seed-applied
insecticides had no positive effects on com grain (Cox et al., 2007b) or com silage yields (Cox et al., 2007a) when
following soybeans, which suggests there is no yield enhancement of these seed-applied insecticides in the absence
of pests.
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cultivars, it appears that Bt cotton (herbicide-resistant or not) would generally out-yield non-Bt
cotton given similar production inputs and agronomic conditions.
The indirect yield effects of herbicide-resistant (HR) crops generally may have less spatial
and temporal variability because weeds are ubiquitous and cause yield losses in most situations.
For example, the use of HR soybean with timely glyphosate application almost always achieves
yield gains relative to production without weed control (Tharp and Kells, 1999; Corrigan and
Harvey, 2000; Mulugeta and Boerboom, 2000; Wiesbrook et al., 2001 ; Knezevic et al., 2003a, b;
Dailey et al., 2004; Scursoni et al., 2006; Bradley et al., 2007; Bradley and Sweets, 2008).
Likewise, the use of HR com and cotton varieties with timely glyphosate application almost
always results in yield increases (Culpepper and York, 1999; Johnson et al., 2000; Gower et al.,
2002; Dailey et al,, 2004; Richardson et al., 2004; Sikkema et al., 2004; Thomas et al,, 2004;
Cox et al., 2005; Myers et al,, 2005; Sikkema et al., 2005; Cox et al., 2006; Thomas et al., 2007).
Yield Lag and Yield Drag
Despite properties that result in indirect yield benefits, some fanners observed a yield
reduction when they first adopted HR varieties (Raymer and Grey, 2003). Indeed, shortly after
the adoption of glyphosate-resistant soybean, university soybean trials reported lower yields of
HR varieties (Opiinger et al., 1 998; Nielsen, 2000). In a study that compared five HR varieties
with five non-HR varieties in four locations in Nebraska, evidence of “yield lag” and “yield
drag" was found (Elmore et al., 2001 a, b).^ A 5-percent yield lag was due to the difference in
productivity potential between the older germplasm used to develop the HR varieties and the
newer, higher yielding germplasm of the non-HR varieties.* A 5-percent yield drag resulted from
the reduced production capacity of the soybean plant following the presence or insertion process
of the HR gene (Elmore et al., 2001b). Although not as pronounced as in the Nebraska study,
Bertram and Petersen (2004) also presented data that indicated a potential yield lag at one
location in Wisconsin with the early HR soybean varieties.
Femandez-Comejo et al. (2002b) reported that a national farm-level survey indicated that HR
soybean showed a small advantage in yield over conventional soybean, probably because of
better weed control. A national survey of soybean producers in 2002 found that there was no
statistical difference in yield between conventional soybean and HR soybean (Marra et al.,
2004). A mail survey of Delaware farmers in 2001 found that HR soybean had a 3-bushel/acre
’Yield lag is a reduction in yield resulting from the development time of cultivars with novel traits (in this
case, glyphosate resistance and Bt). Because of the delay between the beginning of the development of a cultivar
with a novel trait and its commercialization, the germplasm that is used has lower yield potential than the newer
gemtpiasin used in cultivars and hybrids developed in the interim. Consequently, the cultivars with novel traits have
atendency to initially yield lower than new elite cultivars without the novel traits. Over time, the yield lag usually
disappeai^.
Yield drag is a reduction in yield potential owing to the insertion or positional effect of a gene (along with
cluster genes or promoters). This has been a common occurrence throughout the histoiy of plant breeding when
inserting different traits (e.g., quality, pest resistance, and quality characteristics). Frequently, the yield drag is
eliminated over time as further cultivar development with the trait occurs.
^During selection for a particular h^it in a plant-breeding program, many other traits may also change. Such
“correlated” changes may occur because a gene controls more than one trait (pleiotropy), bec^se genes controlling
two traits are in physical proximity on a chromosome (linkage), or because of random segregation (drift). The
distinctions among the three causes m-e important because the solutions to them differ. Solutions may be necessary
because some correlated changes are undesirable.
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yield advantage (Bernard et al., 2004). The survey data and results of empirical studies in
Wisconsin indicate that the use of more elite germplasm in variety development has probably
eliminated the yield lag or yield drag associated with the use of HR varieties (Lauer, 2006).
Similarly, early empirical studies of Bt com hybrids indicated a potential yield lag, as
indicated by the lower yield of Bt hybrids than of new elite hybrids (Lauer and Wedberg, 1999;
Cox and Chemey, 2001). However, Bt hybrids yielded as well as or better than near-isolines
(Lauer and Wedberg, 1999; Traore et a!., 2000; Cox and Chemey, 2001; Baute et al., 2002;
Dillehay et al., 2004), and this suggests that there was no yield drag or loss of yield because of
the insertion of the Bt gene with the early Bt com hybrids.
Furthermore, whether a yield loss or a yield increase materializes for a GE crop depends on
the particular farming situation. For example, in their comparison of HR com hybrids with non-
HR varieties, Thelan and Fenner (2007) reported that in low-yield environments HR hybrids
yielded 5 percent more than non-HR hybrids and in high-yield environments non-HR hybrids
yielded about 2 percent more than HR hybrids. An early study of cotton (May and Murdock,
2002) that compared first-generation glyphosate-resistant cuitivars with nonresistant cultivars
showed no yield lag in glyphosate-resistant cultivars and a yield advantage of using glyphosate
instead of the standard conventional soil-applied herbicides. The results of the study suggested
that the use of soil-applied herbicides resulted in some type of injury to cotton, whereas
glyphosate application before the fourth leaf stage did not. A study at nine locations across the
United States (May et al., 2004) showed that one of Monsanto’s later glyphosate-resistant cotton
lines provided even greater yield than the first-generation glyphosate-resistant cotton when
glyphosate was applied from the fourth to the 14th leaf stage; this resulted in an agronomic
advantage of the later technology.
A 2002 U.S. Department of Agriculture (USDA) survey found that increases in cotton yields
in the Southeast were associated with the adoption of HR cotton and. Bt cotton in 1997: a 10-
percent increase in HR-cotton acreage led to a 1.7-percent increase in yield and a 10-percent
increase in Bt cotton acreage led to a 2.1 -percent increase in yield if other productivity-
influencing factors were constant (Femandez-Comejo and Caswell, 2006).
It was noted above that most of the yield studies of GE versus non-GE crops conducted in the
United States used data from the late 1990s and early 2000s.’ Any yield differences between GE
and non-GE varieties found during the first 5 years of adoption could have diminished as seed
companies developed new IR and HR events. One reason for the lack of recent studies on yields
may be that it is increasingly difficult to find sufficient data on non-GE varieties owing to the
predominance of GE varieties in major crops (see Chapter 4).
Improved Crop Quality and Risk Management
Bt com has been found to decrease concentration of the toxic chemical aflatoxin (Wiatrak et
al., 2005; Williams et al, 2005) and some other mycotoxins produced by fungi (fumonisins in
particular) in the grain (Clements et al, 2003). In doing so, it decreases the risk of price dockage
to farmers because of poor crop quality and increases food safety for consumers. Bt crops also
have reduced stalk lodging at harvest (Rice, 2004; Wu et al, 2005; Stanger and Lauer, 2006;
’More recent data from field trials are available but have not been published in peer-reviewed literature.
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Wu, 2006);^ this improves crop quality and increases harvest efficiency, thus reducing the
farmers’ fuel and labor costs. Another benefit of the use of HR soybean is that the presence of
foreign matter (such as weed seeds) in the harvested crop has greatly decreased (from 5-25
percent to 1-2 percent in the southeastern states) (Shaw and Bray, 2003), reducing the need for
handlers to blend soybean with high foreign matter with soybean with lower foreign matter to
improve the overall quality of the crop.
The use of GE crops can also reduce agronomic risks for farmers, for example, in the case of
HR crops, glyphosate breaks down quickly in the soil, removing the potential for the residual
herbicide to injure a succeeding crop (Scursoni et al., 2006). Additionally, some Bt varieties may
improve drought tolerance (Wilson et al., 2005). Empirical studies have not documented that the
use of Bt com for com borer provides a yield benefit in the presence of drought (Traore et al.,
2000; Dillehay et al., 2004; Ma et al., 2005), but Ma et al. (2009) found in an empirical study on
Bt com for com rootworm that in a drought year on sandy soil, the Bt com rootworm hybrid
yielded 10 percent more than the near-isoline. The roots of the Bt com rootworm hybrids were
longer and more dense than those of the non-GE hybrid because the Bt trait kills the below-
ground larvae that feed on the roots of the com plant. Ma et al. (2009) speculated that Bt com
rootworm hybrids may have more drought tolerance than standard hybrids in drought years
because the root system is more intact and therefore capable of taking up more water. Such risk
reduction may explain in part farmers’ motivation to adopt these GE crops. A related risk posed
by adoption of Bt corn in northern latitudes, however, is the potential for higher grain moisture at
harvest because of improved plant health, which increases drying costs or delays harvest (Pilcher
and Rice, 2003; Dillehay et al., 2004; Ma and Subedi, 2005; Cox et al., 2009).
Because GE crops have the ability to reduce yield loss, adopting farmers also have different
insurance options for managing risk. In 2007, Monsanto developed a submission to the USDA
Federal Crop Insurance Corporation for a new crop-insurance endorsement for com that contains
three traits: a Bt toxin that controls com borer, one that controls corn rootworm, and herbicide
resistance.^ The submission proposed a premium-rate discount for those hybrids based on several
thousand on-farm field trials conducted over several years in the Com Belt states of Illinois,
Indiana, Iowa, and Minnesota. The trials demonstrated the yield and yield-risk reduction
advantages of the hybrids compared with conventional or single-trail HR hybrids and showed
that the current premium rates were no longer actuarially appropriate. A lower insurance
premium became available in the 2008 crop year to farmers who adopted the triple-stacked
hybrids. The rate discount was applied to the yield portion of the premium for actual production
history of the field and based policies on crop-insurance units in which at least 75 percent of the
acreage was planted to qualifying com hybrids. The average premium-rate discount was 13
percent in 2008, or about $3.00/acre.
Comparable triple-stacked hybrids from seed companies Dupont/Pioneer and Syngenta were
approved for inclusion in the program for the 2009 crop year, and the premium-rate discount
applies to all three companies’ and licensees’ seed brands that contain at least the above-
mentioned traits for dryland com in at least a subset of 13 Midwest states and irrigated com in
"Stalk lodging is the permanent displacement of the stems of crops from their upright position, resulting in
a crop that either leans or can be prostrate. A mildly lodged crop results in only a slight slowdown of harvest,
whereas a severely lodged crop ^eatly slows down harvest (in some instances the crop can only be harvested in one
direction further reducing harvesting efficiency).
^These products are marketed by Monsanto as YieldGard^Plus, Roundup Ready 2®, YieldGard ® VT
Triple hybrids.
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Kansas and Nebraska. This is the first approved crop-insurance innovation that has resulted in
reduced premium rates, and it provides a saving for farmers and reduces the need for premium
subsidies by the federal government, Cox et a!. (2009), however, found no consistent yield or
economic advantage for triple-stacked hybrids compared to double-stacked hybrids from both
companies in second-year com in New York, despite one of the years being dry and warm. In
both years, com rootworm damage was low, and corn borer damage was sporadic across
locations.
Production Expenses
The use of GE crops triggers changes in several production expenses, particularly those
related to seed technology, pesticide expenditures, labor and management requirements, and
machinery operations.
Seed Prices
U.S. farmers pay for the GE traits in the seeds that they plant in the form of a technology fee
because GE seeds are considered proprietary in the United States. The market price of seed,
which includes the technology fee, incorporates the costs associated with development,
production, marketing, and distribution (Femandez-Comejo and Gregory, 2004). The price must
be responsive to farmers’ willingness to purchase the technology while ensuring an attractive
return on capital to the seed development firms (technology provider and licensee seed
companies or distributors) and their investors. The price also depends on the competitiveness of
the particular seed market and on the pricing behavior of firms that hold large shares of the
market.
In recent decades, private-sector research and development costs have risen with the
application of new technologies. Much of the increase in seed prices paid by U.S. farmers has
been associated with that general trend (Krull et al., 1998). The seed-price index has exceeded
the average index of prices paid by U.S. farmers by nearly 30 percent since the introduction of
GE seeds in 1996 (Figure 3-1). The contrast is even starker for cotton and soybean. After
adjustment for inflation, the real average cotton seed price almost tripled between 1996 and 2007
(Figure 3-2), while the soybean seed price grew by more than 60 percent.
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— Seed All prices paid
FIGURE 3-1 Seed price index and overall index of prices paid by United States farmers.
SOURCE: Femandez-Comejo, 2004; USDA-NASS, 2000, 2005, 2009a.
— e— Corn ' ■ Cotton Soybean
FIGURE 3-2 Estimated average seed costs for United States farmers in real (inflation-adjusted)
terms.
SOURCE: Femandez-Comejo, 2004; USDA-NASS, 2000, 2005, 2009a.
The rise in real seed prices can be accounted for by improvements in germplasm, by the
increasing price premiums paid for GE seed, and by the growing share of GE seed purchased by
U.S. farmers (as the share of seed saved by farmers correspondingly decreased). The price
premium, which includes the technology fee, doubled in real terms for GE cotton seed between
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2001 and 2007 (adjusted for inflation) (Figure 3-3). U.S. farmers also experienced similar price-
premium increases for corn and soybean seed (Figure 3-4 and Figure 3-5). Some of the increase
reflects the larger number of services that the seed delivers to the buyers compared with
conventional seed. For example, faitnere who purchase Bt cotton receive the seed germplasm
and an insecticide combined in one product, whereas for non-GE crops they must buy each
separately and pay for costs related to applying the insecticide. The increase also reflects the
additional value to the farmer provided by later GE cultivars with more than one type of trait or
more than one mode of action for particular target pests. The rates of adoption noted in Chapter 1
indicate that the price premiums have not deterred many U.S. farmers from purchasing GE seeds
and that non-GE seed options were less attractive or were not available.
xTym Biotechnology. S/100 lb sKsa Ncwibiotechnology. S/100 b ——Seed premium, including technology fee, $/100 lb
FIGURE 3-3 Real (inflation-adjusted) cotton seed prices paid by United States farmers,
2001-2007.
SOURCE: USDA-NASS, 2000, 2005, 2009a.
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2ZZ3 Biotechnotogy, $/bag NorrfMotechnok^, $*ag —“Seed prenraum, including technology fee, S/bag
•fon
2001 2002 2003 2004 2006 2006 2007 2008
Year
FIGURE 3-4 Real (inflation-adjusted) com seed prices paid by United States farmers, 2001-
2008.
SOURCE: USDA-NASS. 2000, 2005, 2009a.
ezza Biotechnotogy, S/Bushetassyi Nonbiotechnotogy, $/Bush&l Seed premium inciuding technoiogy fee, $/Bushel
2001 2002 2003 2004 2005 2006 2007 2008
Year
FIGURE 3-5 Real (inflation-adjusted) soybean seed price paid by United States farmers, 2001-
2008.
SOURCE: USDA-NASS, 2000, 2005, 2009a.
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Other Input Costs
If U.S. farmers who have adopted GE crops pay higher prices for the seed, have they
experienced compensatory cost reduction for other inputs? With insect-resistance technology, a
plant contains its own insecticide, whereas most HR crops are engineered to be used with the
herbicide glyphosate. Have those conditions changed adopters’ farming practices and purchasing
habits?
Economic reasoning suggests that the influence of genetic engineering on pesticide use
depends on whether the GE cultivar and the pesticides are complementary or substitute inputs
(Just and Hueth, 1993). Where IR or stacked GE cultivars substitute for other pesticides,
chemical-pesticide use should decline. That is often the case with Bt crops (see Chapter 2,
Figures 2-7 and 2-8). For HR crops, it often means reducing the use of less effective, more
costly, and possibly more toxic herbicides although exceptions occur (Cattaneo et al., 2006).
That substitution effect can produce cost savings as well as reductions in environmental and
human health risks associated with chemical applications (Sydorovych and Marra, 2007).
Several studies have attempted to establish whether the adoption of GE crops affects pesticide
use. Some early investigations found evidence of a decline in pesticide use as adoption of GE
crops increases (Heimlich et al., 2000; Hubbell et al., 2000; Carpenter et al., 2001; Marra et al.,
2002). Some studies have found that most of the reduction in pesticide use resulting from
adoption of an IR cultivar was in highly toxic chemicals, and average toxicity declined with
adoption(Heimlich et al., 2000; Sydorovych and Marra, 2007). However, others have concluded
that pesticide use increases in tandem with GE-crop production (Benbrook, 2004). Such
contradictory findings have been attributed to the different approaches to measuring pesticide
use, specifically
• How pesticide use is recorded (pesticide active-ingredient volume, formulated volume,
relative toxicity, or number of applications) (Sydorovych and Marra, 2007).
• Which factors are controlled for (results would vary from region to region and from year
to year depending on the extent of pest infestation, weather, cropping patterns, and so
on).
• The method of aggregation (Frisvold and Marra, 2004).
A general overarching effect cannot be discerned because of the variability in specific
conditions on different farms and in different regions.
The observed change in pesticide use with IR crops depends on the crop and the pest.
Changes in insecticide use for treatment of European com borer were minimal because many
farmers accepted yield losses rather than incur the expense and uncertain results of chemical
control. A survey of com growers in Iowa and Minnesota determined that only 30 and 17
percent, respectively, had managed European com borer with insecticides during any season in
the early 1990s because chemical use was not always profitable and timely application was
difficult owing to the unpredictability of pest outbreaks (Rice and Ostlie, 1997).
In the case of Bt cotton, however, GE control greatly reduced expenditures on pesticides to
treat tobacco budworm, pink bollworm (Pectinophora gossypiella), and cotton bollworm
(Jackson et al., 2003; Cattaneo et al., 2006). Survey data indicated that the number of insecticide
sprays and insecticide costs generally decreased with the adoption of GE cotton across the
United States (Table 3-1). Where measurable, farm-level profit was also shown to have increased
with the adoption of Bt cotton in all states (Piggott and Marra, 2007). Although the studies
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reported in Table 3-1 seem to suggest that insecticide costs increased after commercialization of
Bt cotton in Arizona, detailed surveys of insecticide use and costs conducted since 1979 clearly
show that use and costs were drastically reduced after 1996 (Ellsworth et al., 2009). One major
factor in the reductions has been the efficient control of the pink bollworm by Bt cotton (Carriere
et al., 2003; Carriere et al., 2004). However, other critical factors in reducing insecticide use and
cost were the introduction of novel and highly efficient insecticides for the control of the
whitefly (Bemisia tabaci) in cotton (Carriere et aL, 2004) and the success of the boll weevil
eradication program (Femandez-Comejo et al., 2009). That illustrates an important point (see
Chapter 2): longitudinal data on pesticide use should not be taken at face value in assessing the
effects of GE crops without controlling for other influences, as many factors can contribute to
changes in patterns of insecticide use.
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Bt com is a preferred method for growere for controlling rootworm because of its simplicity
and safety in applying it compared witfi soil-applied insecticides or with higher levels of active
ingredient in seed treatments on non-Bt com seed*® (AI-Deeb and Wilde, 2005; Vaughn et al.,
2005; Ahmad et al., 2006). The adoption of Bt com for rootworm control has resulted in a
substantial reduction in insecticide use, by an estimated 5.5 million pounds of active ingredient
per 10 million acres (Rice, 2004).
In addition to the pesticide quantity effects, the adoption of HR and IR crops lowers the
demand of competing pesticides used on conventional varieties and may therefore lower the
prices of these pesticides. Huso and Wilson (2006) shows that this effect benefits farmers who
adopt the GE variety and those who plant the conventional variety.
Indirect cost differences between GE crops and conventional crops originate in the adoption
of practices that are linked to the adoption of some GE crops. For example, if a GE crop reduces
the need for tillage to control weeds, reductions in machinery, fuel, and labor for the avoided
cultivation practices amount to indirect cost savings. The indirect cost differences are
particularly important for HR crops because of the complementary relationship between their
adoption and conservation tillage. That is, GE-crop adoption increased the probability of
adoption of conservation tillage, and conservation tillage increased the probability of higher
adoption of GE crops (for a more detailed discussion of conservation tillage, see Chapter 2).
The increased use of conservation tillage has been facilitated by the commercialization of
more effective postemergence herbicides, such as glyphosate, that can be applied topically to
crops and weeds. Glyphosate can supplement or replace tillage as a tool for controlling most
weeds and in so doing can reduce the use of machinery and fuel and lower labor requirements
(Harman et a!., 1985; Chase and Duffy, 1991; Baker et al., 1996; Downs and Hansen, 1998;
Boyle, 2006; Baker et al., 2007). Mitchell et al. (2006) reported that a reduced-tillage system in
the planting of California cotton reduced the number of tractors in operation by 41 to 53 percent,
fuel use by 48 to 62 percent, and overall production costs by 14 to 18 percent Sanders (2000)
reviewed and summarized results of several studies and concluded that conservation tillage can
reduce fuel costs by as much as 50 percent and labor cost by up to 40 percent. Those conclusions
agree with USDA Natural Resources Conservation Service estimates that Iowa farmers would
save 30-50 percent in fuel costs by adopting conservation-tillage practices (Table 3-2). Using
Nebraska survey data for various row crops, Jasa (2000) showed that fuel use for no-till was 1 .43
gal/acre compared with 5.28 ga!/acre for moldboard-plow tillage and that labor requirements for
no-tili were 0.49 hours/acre, compared with 1 .22 hours/acre for moldboard-plow use.
'°As discussed in Chapter 1, Bt com hybrid seed for com rootworm control has 0.25 mg of active
ingredient of insecticide and fungicide applied per seed compared to 1 .25 mg of active ingredient applied to non-Bt
com hybrids.
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TABLE 3-2 Fuel Consumption by Tillage System (Gallons per Year)
Crop
Acres
Conventional
Tillage
Mulch Till
Ridge Till
No-Till
Com
1,000
4,980
3,710
3,330
2,770
Soybean
1,000
4,980
3,110
3,330
1,970
Total fuel use
9,960
6,820
6,660
4,740
Potential fuel savings over
conventional tillage
3,140
3,300
5,220
Saving
32%
33%
52%
SOURCE: USDA-NRCS, 2008.
The financial returns to GE crops should vary directly with fuel prices if they save costly
machinery passes over a field. HR crops do not necessarily save passes over a field, but they do
substitute herbicide applications for more expensive and more fuel intensive methods of weed
management, such as intensive tillage practices or the use of herbicides that require physical
incorporation into the soil. Also, with potentially fewer passes over the field, tractor and spraying
equipment lasts longer, and this results in savings in machinery and equipment costs over the
long term.
Management Requirements and Nonpccuniary Benefits
Many of the commercially available GE products have consistently been shown to be
profitable for U.S. farmers. For example, the profitability of Bt cotton in the Cotton Belt and Bt
com for controlling com rootworm is well documented (Marra, 2001; Alston et al., 2002).
However, the national evidence supporting the use of HR soybean is inconclusive (Bullock and
Nitsi, 2001; Gardner and Nelson, 2007). Femandez-Comejo et al. (2002b) and Fernandez-
Cornejo and McBride (2002) evaluated 1997 field-survey data and 1998 whole-farm survey data,
respectively, and found that the differences in net returns between adopters and nonadopters of
HR soybean were not significant. This lack of significance is consistent with findings from other
producer surveys (Couvillion et al., 2000; Duffy, 2001). In light of high overall adoption rates,
those findings suggest that other considerations have motivated farmers to use genetic-
engineering technology. The wide adoption of HR soybean despite the associated technology fee
stimulated research to identify possible nonpecuniary benefits to GE adopters that motivate such
a shift in technology use.
In addition to the substantially superior control of a broad spectrum of weeds (Scursoni et al,
2006), simplicity, flexibility, and increased worker safety have been suggested as root causes of
herbicide-resistance technology adoption, in that growers can use one herbicide instead of
several to control a wide array of broadleaf and grass weeds (Gianessi and Carpenter, 1999;
Bullock and Nitsi, 2001). The convenience of HR soybean use may mean that farmers can
reduce the time that they spend scouting fields for weeds and mixing and spraying different
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herbicides to address various weed problems (Bullock and Nitsi, 2001). Furthermore, the
window of application for glyphosate is wider than that for other postemergence herbicides. That
application flexibility can effectively control weeds but often the weeds have already caused a
loss in potential crop yield by the time glyphosate is applied.
However, quantifying the simplicity, flexibility, and safety of pest-control programs has been
difficult. The inability to include a measure of management time in the evaluation of benefits of
new technologies in agriculture is not unique to HR soybean. As Femandez-Comejo and Mishra
(2007) observed, assessments of technology adoption using traditional economic tools pioneered
by Griliches (1957) have proved insufficient to explain differing rates of adoption of many recent
agricultural innovations. The standard measures of farm profits, such as net returns to
management, give an incomplete picture of economic returns because they usually exclude the
value of management time itself (Smith, 2002). HR soybean was adopted rapidly despite
showing no statistically significant advantage in net returns over conventional soybean in most
studies, but adoption of such strategies as integrated pest management has been rather slow even
though it has explicit economic and environmental advantages (Femandez-Comejo and
McBride, 2002; Smith, 2002). That inconsistency led to the hypothesis that HR adoption is
driven by unquantifiable advantages — such as presumed simplicity, flexibility, and safety — that
translate into a reduction in managerial intensity, which frees time for other pursuits, and into
increased worker safety.
An obvious use of managers’ time is off-farm employment; alternatively, a farmer could
farm more acreage to increase farm income. Femandez-Comejo and collaborators examined the
interaction of off-farm income-earning activities and adoption of different agricultural
technologies of varied managerial intensity, including HR crops (Femandez-Comejo and
Hendricks, 2003; Femandez-Comejo et al., 2005) and Bt com (Femandez-Comejo and Gregory,
2004). They also estimated empirically the relationship between the adoption of those
innovations and farm household income from on-farm and off-farm sources. To do that, they
expanded the agricultural household model to include the technology-adoption decision and off-
farm work-participation decisions by the operator and spouse (Femandez-Comejo et al., 2005;
Femandez-Comejo and Mishra, 2007).
Those studies hypothesized that adoption of management-saving technologies frees
operators’ time for use elsewhere, most notably in off-farm employment, and that leads to higher
off-farm income. They found that the relationship between the adoption of HR soybean and off-
farm household income is positive and statistically significant: after controlling for other factors,
a 15.9-percent increase in off-farm household income is associated with a 10-percent increase in
the probability of adopting HR soybean. The adoption of HR soybean is also positively and
significantly associated with total household income from off-farm and on-farm sources. A 9.7-
percent increase in total household income is associated with a 10-percent increase in the
probability of adopting HR soybean. In contrast, and consistent with the lack of higher returns
from this technology, adoption of HR soybean did not have a significant relationship with
household income from farming. Those findings complement the findings of Gardner and Nelson
(2007), who used national survey data from 2001-2003 and found that adopting HR soybean
reduced household labor requirements by 23 percent.
Studies have also found that farmers value the convenience and reduced labor requirements
of Bt cotton above and beyond the pecuniary benefits. Because conventional cotton faces heavy
pest pressure, IR varieties decrease the time demands of spraying, and this leads to a 29-percent
reduction in household labor requirements (Gardner and Nelson, 2007). Survey data of Marra
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and Piggott (2006) support the finding that faimers place a monetary value on the convenience,
flexibility, and relative safety of GE crops. In a stated-preference approach, participants in four
surveys placed values on such characteristics as saved time, operator and worker safety, and total
convenience. In each survey that evaluated the total-convenience attribute of genetic-engineering
technology, it made up over 50 percent of the total value placed on nontraded aspects of the GE
crop (Table 3-3). The median total value of convenience ranged from $3. 33/acre per year for
soybean to $5. 00/acre per year for HR cotton. Survey respondents also placed a value on the
improved operator and worker safety characteristics of GE crops. Farmers valued the reduction
in handling and toxicity of the pesticides involved with those crops at $0.43— $2.36/acre per year.
Although initially they increase the demand for GE seeds, the perceived management benefits
may cause the demand for the seeds to become more inelastic (i.e., less responsive to price
increases) over time. As farmers get accustomed to the characteristics and continue to place a
value on them, increases in seed expenditures through either a price increase or an increase in
user cost will not reduce the use of GE seeds by as large an amount as when the nonpecuniary
attributes are not present (Piggott and Marra, 2008).
TABLE 3-3 Value and Relative Importance of Nonpecuniary Benefits to Farmers
Characteristic
Re-scaled^
Median Mean Std Dev
Share
(%)
Com Rootworm Survey: n
= 367
Time saving
0.588
0.997
1.390
23.86
Equipment saving
0.400
0.724
0.969
17.51
Operator and worker safety
0.429
0.991
1.623
17.12
Environmental safety
0.208
0.787
1.565
10.88
More consistent stand
0.800
1.773
2.862
30.63
Sum of the parts
3.000
5.272
6.222
National Soybean Survey: n = 113
Operator and worker safety
0.913
1.660
2.026
20.97
Environmental safely
1.304
1.961
2.201
24.89
Total convenience
3.333
4.158
3.690
54.14
Sum of parts
5.000
7.779
6.026
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North Carolina Herbicide-Resistant Crop Survey: n = 52
Operator and worker safety
2.361 2.923
2.783
23.91
Environmental safety
1.666 2.720
2.660
20.45
Total convenience
5.000 7.793
7,818
55.63
Sum of parts
10.000 13.437
10.612
Roundup Ready Flex Cotton Survey: n = 72
Operator and worker safety
1.875 3.056
4.061
23.90
Environmental safety
0.958 2.592
3.382
18.06
Total convenience
5.00011.180
15.441
58.04
Sum of parts
10.000 16.828
17.383
■^Rescaled to conform the magnitude of the overall value, which is asked as a separate question.
SOURCE: Marra and Piggott, 2006.
Management benefits do not appear to influence the adoption of GE com. Femandez-Comejo
and Gregory (2004) did not find a statistically significant relationship between adoption of Bt
com (to control com borer) and off-farm household income, and Gardner and Nelson (2007)
noted no effect of adoption of Bt or HR com on household labor. The lack of a significant
relationship supports the observation that most farmers accepted yield losses rather than incur the
expense and uncertainty of chemical control for European com borer before the introduction of
Bt corn (Femandez-Comejo et al., 2002a). For those farmers, the use of Bt com was reported to
result in yield gains rather than pesticide-related savings, and savings in managerial time were
small. However, one of the benefits of adoption of Bt com for rootworm control is that it makes
it unnecessary to handle toxic insecticides at planting or to deal with high rates of insecticide-
treated seeds.
Thus, the econometric results are consistent with anecdotal statements that many GE crops
save managerial time because of the associated simplicity and flexibility of pest control. In the
case of some GE crops, such as HR soybean, these nonpecuniary benefits provide incentives for
adoption that counteract the additional cost of GE seeds. Indeed, the benefits increase demand
for the GE seeds, and that in turn supports a higher price, in the case of other GE crops, such as
Bt cotton, nonpecuniary benefits are accrued above and beyond additional farm profits.
Lower management costs and increased yield and nonpecuniary benefits have figured in the
economic value of the natural refuge for cotton with two endotoxins for control of the bollworm-
budworm complex. As discussed in Chapter 2, the Environmental Protection Agency (EPA)
changed the refuge requirement for these IR cotton varieties from a 20 percent refuge treated
with insecticide (or a 5 percent refuge not treated with insecticides) to a natural refuge where
wild host plants constitute the refuges. The benefits of the refuge change were estimated for
North Carolina to be $26.90 per year per impacted acre when pecuniary and nonpecuniary
impacts were considered (Piggott and Marra, 2007).
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Value and Market-Access Effects
In addition to the input-cost effects, the use of GE crops can affect the revenue potential of
farmers. Tv^o such effects can occur: foreign yield effects on the prices of products sold and
market access to sell the GE crops.
Increase in grain and oilseed supplies should result in downward pressure on the prices
received by farmers, all else being equal. Genetic-engineering technology helped to boost yields
that had already been growing over the last 70 years through improved plant-breeding
techniques. As a result, supply exceeded demand; the real price of food (adjusted for inflation)
had fallen until 2006. However, over the period 2006-2008, com and soybean prices increased
rapidly because of various factors, including the rise in world incomes and the demand for
renewable fuels made from agricultural feedstock. The increase in the global supply of those
crops due to the adoption of GE crops and improvements in germplasm and plant breeding likely
moderated the upward pressures on prices during this time.
Assessing the impact of new agricultural technologies on commodity prices is difficult
because the effect on price cannot be measured directly. As Price et al. (2003) explain, once a
new technology is introduced and adopted, only the world price that results from increasing
global supply (supply shift) can be observed. It is not possible to observ'e the counterfactual
price — ^the price that would have existed, assuming the same supply and demand conditions, if
tlie new technology had not been introduced (see Box 3-1). Therefore, the counterfactual world
prices and demanded quantities of the commodities must be estimated from market equilibrium
conditions by using econometric models, which generally are reliable in the short term and when
systems are stable.
The approach to calculating the effect of genetic-engineering technology on commodity
prices followed by most studies (Falck-Zepeda et al., 2000a; Falck-Zepeda et al., 2000b;
Moschini et al., 2000; Price et al., 2003; Qaim and Traxler, 2005) is based on the theoretical
framework developed by Moschini and Lapan (1997) to assess the impacts of an innovation on
economic welfare when the innovator behaves as a monopolist under the protection of
intellectual-property rights in an input market by pricing the new technology above marginal cost
(the cost of producing one more unit of a good) (Price et al., 2003). Changes in the economic
welfare of producers and consumers in a competitive output market can also be measured
because some of the benefits generated by the innovation are passed on to them in the form of
higher production efficiency and lower commodity prices.”
Table 3-4 shows the estimates of the effect of GE-crop adoption (com, soybean, and cotton)
on crop prices. The price effects are different for each crop and technology and depend on the
market penetration (the extent of adoption) of the new technology and on the details of the
As Price et al. (2003) described it, the estimated total market benefit of adopting each of the GE crops
depends on the extent to which the global commodity supply curve shifts outward after the introduction of die
technology. In each case, the shift in supply reflects potential yield increases and/or decreases in costs. The
estimated market benefit also depends on the interaction of the supply and demand curves before and after the
introduction of the new technology. The empirical models calculate the preinnovation and postinnovation prices and
quMtities in an international market setting by using information on adoption rates, crop yields, costs, technology
fees, and seed premiums. The framework also takes into account the adoption of biotechnology outside the United
States. The counterfactual world price, the equilibrium world price without the innovation, is the sum of the
observed market price and the vertical supply shift resulting from ftie adoption of GE crops. The equilibrium world
price occurs at the intersection of the excess-supply and excess-demand curves.
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models used (particularly supply and demand parameters). For example, adoption of Bt cotton
was associated with a decline in cotton prices of 0.65 percent for the first year of adoption in the
United States only but with a price decline of 1.1 percent when adoption continued in the United
States and took place in other countries. The effect of adoption of HR soybean varieties on
soybean price ranged from a decline of 0.17 percent in 1997, when adoption had only occurred in
the United States, to about 2-percent decline following further adoption in the United States and
Argentina and a 2.6-percent decline for world adoption in 2001. Simultaneous adoption of Bt
com and HR soybean could lead to a decline in com prices of 2.5 percent and a decline in oilseed
prices of 3.9 percent, alt other things being equal.
Table 3-5 presents the estimated distribution of the tangible benefits among consumers,
farmers, technology providers (biotechnology firms), seed firms, and consumers and producers
in the United States and the rest of the world. The distribution of benefits varies by crop and
technology because the economic incentives to farmers (crop prices and production costs), the
payments to technology providers and seed firms, and the effect of the technology on world crop
prices are different for each crop and technology. For example, farmer adoption of HR cotton
benefits mainly consumers, whereas adoption of Bt cotton benefits farmers and technology
providers. Innovators (technology providers and seed firms) are often the largest beneficiaries in
the case of HR soybean, but producers and consumers also gain (Moschini et al., 2000). The
aggregate net benefits to crop farmers depend on the aggregate cost saving relative to the
estimated price decreases and increased production (sales). The lower output prices may deter
some farmers who have relatively lower yield gains or higher costs from adoption. But farmers
with sufficient yield gains and cost saving will adopt GE crops even when an increase in supply
puts downward pressure on prices. Livestock producers primarily receive benefits from lower
prices of feedstocks than would have occurred without GE-crop adoption. Analyses of the
benefits of GE crops and their distribution have many nuances.
The studies mentioned above analyzed the economic effects of GE varieties during the early
period of their adoption of these technologies (the latest study used data from 2001).*^ Results of
studies of adoption in agriculture (Feder et al., 1985) suggest that early adopters of new yield-
increasing technologies gain early in the life of the technologies, but that their gains dissipate as
prices go down. The United States was the dominant early adopter of GE varieties; James (2009)
has since found a high rate of adoption of GE varieties more recently, mostly in developing
countries. The agricultural products produced with genetic engineering are traded globally, and
adoption of GE varieties worldwide affects prices that U.S. farmers receive.
'^hesc studies were carried out before Brazil began producing large amounts of GE soybean. The entry of
Brazil into the GE soybean market and the continued expansion of GE soybean in Argentina may have pushed
considerable amounts of the benefits from prt^ucers to consumers.
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According to (James, 2009), 331 million acres of land were planted to GE cultivars
worldwide in 2009, of which nearly 95 percent was in six countries: the United States,
Argentina, Brazil, Canada, India, and China. The total global acreage planted to GE crops in
2009 amounted to 8 percent of the world’s tillable cropland. The GE cultivars were mostly of
four crops: soybean (52 percent), com (31 percent), cotton (12 percent), and canola (5 percent).
In 2009, 77 percent of the soybean area, 49 percent of the cotton, 26 percent of the corn, and 21
percent of the canola lands were grown with GE cultivars. Much of the adoption of GE com and
cotton has been in the United Slates, Argentina, and Brazil, but China and India are major
adopters of Bt cotton. The majority of acres planted to GE crops were HR varieties, at
approximately 62 percent, followed by stacked traits at 21 percent and IR varieties at 15 percent.
Stacked traits grew at a 23 percent rate from 2007 to 2008, the highest rate of the three trait
categories (James, 2009).
According to Sexton et al. (2009), the high increases in yield that resulted from adoption of
Bt cotton in developing countries have contributed to the increase in the world cotton supply and
to the relatively low prices of cotton from 1998-2008. They suggest that the decline in the price
of cotton relative to the price of other agricultural commodities has contributed to the transition
from cotton to other crops in California. The same shift away from cotton is taking place in other
cotton-producing regions. Total upland cotton-planted acreage In the United States has declined
by 36.8 percent since 2002 (USDA-NASS, 2009).
Soybean acreage began to increase in the United States in 1997 and stayed relatively high
until 2002, in part because the commodity support prices in the Federal Agricultural
Improvement and Reform Act of 1996 favored soybean over other program crops. Even though
Sexton et ai. (2009) found that average yield of soybean — the crop with the highest rate of
adoption of GE cultivars — grew more slowly than that of cotton after the introduction of GE
varieties, the introduction of GE soybean contributed to the expansion of harvested soybean area
worldwide, which grew by nearly 30 percent from 1997 to 2007 (FAO, 2008). In Argentina
alone, GE soybean enabled adoption of no-till practices, which facilitated double cropping of
wheat and soybean and contributed to a 9.9-milIion-acre increase in the soybean area from 1996
to 2003 (Trigo and Cap, 2003). The adoption of GE soybean in South America contributed to the
increase in soybean supply, which also occurred because of the expansion of soybean acreage in
Brazil. That supply shift caused downward pressure in soybean prices and had an adverse effect
on growers in the United States, although the price effect was overwhelmed by the effect of
increased global demand for soybean during the period 2006-2008.
Many of the analyses summarized in Table 3-4 and Table 3-5 are based on partial-
equilibrium models (in which the price of one good is examined and ail other prices are held
constant), but several studies have examined the effect of adoption of GE cultivars on producers
and consumers by using a computable general-equilibrium approach (the prices of good are
examined in relationship to one another). Some of the studies also attempted to assess the costs
of access barriers imposed on GE crops by the European Union (EU), which has had a
moratorium on the production and import of GE crops since 1999. Qaim (2009) has surveyed
those studies and found that they predict an annual global welfare gain to consumers and
producers from adoption of GE cultivars without restrictions, ranging from $1.4 billion from the
adoption of Bt cotton to $ 1 0 billion from the adoption of GE oilseed and com. The results of the
studies suggest that bans on imports of GE crops reduce the potential economic welfare of
several parties, including U.S. farmers, but that European consumers suffer much of the loss.
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TABLE 3-5 Adoption of Genetically Engineered Crops and Their Distribution
Study
Year
Total
Benefits
(S mtiiion)
U.S.
farmers
Share of Total Benefits (%)
Innovatoi^ U.S.
consumers
Net
Row
Bt cotton
Falck-Zepeda et al., 1999
1996
134
43
47
6
Falck-Zepeda et ai., 2000a
1996
240
59
26
9
6
Falck-Zepeda et al., 2000b
1997
190
43
44
7
6
Falck-Zepeda et al., 1999
1998
213
46
43
7
4
Frisvold et at., 2002
1996-1998
131-164
5-6
46
33
18
US-EPA, 200f
1996-1999
16-46
NA
NA
NA
NA
Price et a!., 2003
1997
210
29
35
14
22
Herbicide-resistant cotton
Price et al., 2003
1997
232
4
6
57
33
Herbicide-resistant soybean
Falck-Zepeda et al., 2000b
I997-LE‘’
1,100
77
10
4
9
1997-HE"
437
29
IS
17
28
Moschini et al., 2000
1999
804
20
45
10
26
Price et al, 2003
1997
310
20
68
5
6
Qaim and Traxler, 2005
1997
206
16"
49
35
NA'
Oaim and Traxler, 2005
2001
1230
13'*
34
53
NA'
Note: NA = not applicable; RoW = rest of the world (includes consumers and producers).
"Limited to United States farmers.
^LE - low elasticity; assumes a United States soybean supply elasticity of 0.22.
"HE = high elasticity; assumes a United States soybean supply elasticity of 0.92.
‘^Include all soybean producers.
"Included in consumers and producers.
SOURCE: Femandez-Comejo and Caswell, 2006, Qaim and Traxler, 2005.
Anderson and Jackson (2003) estimated that even under free trade — with global welfare gain
from the introduction of GE cultivars of cotton, com, and oilseed that will enhance supply-
farmers in the exporting countries will actually lose 0.07 percent of their income because of
lower prices, whereas low-income consumers in North America will stand to gain from the
introduction of GE cultivars because of lower food prices, all other things being equal. A
moratorium on the export of GE crops to the EU will quadruple the losses to U.S. farmers. Such
asynchronous conditions, when GE crops are approved at different times or not at all by different
countries, could influence farmers’ planting decisions because of those losses. Yet at the same
time that U.S. farmers suffer economically, U.S. consumers benefit. A more severe moratorium
on GE exports by the EU and other developed economies, such as that of Japan, is estimated to
reduce the income of North American farmers by 0.5 percent. Those bans will hurt European
consumers but benefit European farmers. Nielsen and Anderson (2001) showed that the welfare
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costs of less drastic barriers, such as labeling and segregation requirements, are important but
smaller than the cost of bans.
Lence and collaborators (Lence and Hayes, 2005a, b; Lence and Hayes, 2006; Lence et al.,
2005) show that, in addition to the cost saving and other benefits, the overall welfare impact of
genetic-engineering technology depends on the level of consumer concern with the technology
and the costs of identity preservation. In particular, they state that their results suggest “the
United States may have maximized welfare by not requiring labeling” of GE com and soybean,
but they claim that their results also suggest that “recently approved EU legislation enforcing
labeling of GE crops also makes sense because consumer concern in the EU appears to be greater
than that in the United States.”'^
The literature suggests that adoption of GE cultivars puts downward pressure on crop prices
and increases the earnings of adopting fanners in the early years of the adoption process and that
barriers to access reduce grower income. But there is a paucity of studies of the welfare effects of
genetic-engineering technology in recent years, when adoption has increased globally, and this is
an important subject for future research.
ECONOMIC IMPACTS ON OTHER PRODUCERS
Livestock Producers
Much of the soybean and com produced in the United States is fed to livestock (Figure 3-6
and 3-7), and byproducts are used in consumer products, so quality and nutritional characteristics
of soybean and com associated with GE crops have been closely examined. Most studies of
soybean have reported no differences in animal performance (Hammond et al., 1996); in
important nutritional qualities, such as isoflavones (Duke et al., 2003); or in other characteristics
at the macroscopic level of HR soybeans (Magana-Gomez and Calderon de la Barca, 2009).
Researchers (Cox and Chemey, 2001; Jung and Sheaffer, 2004) have reported that glyphosate-
resistant Bt com docs not affect feeding-quality characteristics of com silage. Lutz et ai. (2006)
reported that the Bt protein CrylAb is degraded during the ensiling process. In feeding studies,
there was no difference in milk production or milk composition between glyphosate-resistant
corn, with or without the stacked Bt gene, and nontransgenic hybrids (Barriere et al., 2001;
Phipps et al., 2005; Calsamiglla et al., 2007). There were no differences in body weight and feed
use between rats fed grain from a Bt com rootworm hybrid and rats fed grain from a
nontransgenic hybrid (He et al., 2008). Likewise, no differences were observed in mortality,
weight gain, feed efficiency, or carcass yield between broiler chickens fed grain from a Bt com
rootworm hybrid and chickens fed grain from a near-isoline (McNaughton et al., 2007). Thus,
empirical studies have clearly indicated that there is no adverse effect on quality of livestock
feed or on the output or quality of livestock products.
‘^The welfare implications of differojt regimes of protection of intellectual property rights in the seed
industry have also been studied (Lence et al., 2905).
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1980-1981 1989-1990 1998-1999 2007-2008 2016-2017
Year
FIGURE 3-6 United States com use.
NOTE; FSI = food, seed, and industrial.
SOURCE: USDA-ERS, 2009.
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FIGURE 3-7 United States soybean use.
Note: Crush is used primarily for livestock feed.
SOURCE: USDA-ERS, 2009.
Furthermore, nutritional characteristics of GE and conventional com hybrids — including
fatty acid profiles, mineral and vitamin contents, lutein, and total phenol and antioxidant
activity — were comparable (Venneria et al., 2008) although some slight differences in
triglycerides and urinary phosphorus and sodium extractions were noted in male rats (Magafla-
Gomez and Calderdn de la Barca, 2009). Cotton seed is used as a byproduct in animal feed, and
cottonseed oil is used for human consumption. Castillo et al. (2004) found that Bt cotton seeds
were deemed nutritionally equivalent with no difference in feed intake, milk yield, or
composition. Few studies have been conducted to assess the levels of the glyphosate metabolite
aminomethylphosphonic acid (AMPA) in glyphosate-treated, glyphosate-resistant com hybrids;
however, one study by Reddy et al. (2008) reported no detection of AMPA. Duke et al. (2003)
reported that AMPA was detected in glyphosate-treated, glyphosate-resistant soybean seeds;
however EPA has not established a tolerance for AMPA. Given that AMPA is not considered
significantly toxic (Giesy et al., 2000), the discovery of AMPA in glyphosate-treated,
glyphosate-resistant soybean is not considered to be an issue of importance at this time.
Feed costs constitute nearly half the variable costs of livestock production, so even moderate
price fluctuations can seriously affect the trajectory of the livestock market (USDA-NASS,
2008), As mentioned above, livestock operators are the buyers of feed, and they are the major
beneficiaries of reductions in the prices of com and soybean, to which the adoption of GE crops
has contributed. They also benefit from increased feed safety from the reduction of mycotoxins
(Wu, 2006). We are not aware of any quantitative estimation of savings to livestock operators
and final consumers due to the adoption of GE crops or of the resulting effect on the profitability
of livestock operations. This is another subject on which future research is desirable.
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Producers of Non-Genetically Engineered Crops
The adoption of GE crops affecte production costs for non-GE farmers in several key ways.
GE crops alter the demand for inputs, and this affects the cost of inputs to GE and non-GE crops
alike. For example, Bt crop varieties that reduce insecticide use also lower the input costs for
producers who use insecticides that substitute for Bt because the lower overall demand for them
puts downward pressure on their prices. In other cases, GE crops increase the demand for other
inputs. HR varieties increase demand for broad-s|^ctrum herbicides, like glyphosate, which can
have mixed effects on the price. On the one hand, the increase in demand puts upward pressure
on the prices of those herbicides and, everything else being equal, increases the profits of the
firms that manufacture GE seeds. On the other hand, the expanded market for broad-spectrum
herbicides compatible with HR crops may allow firms to reduce the price of the herbicide but
still increase profits through greater sales. HR varieties also affect the demand and prices for the
herbicides that were used before HR crop varieties became available, usually by lowering prices
because of reduced demand.
We have observed in Chapter 2 that GE crops can affect production of non-GE crops
favorably or unfavorably through externalities associated with pest-control activities. To the
extent that genetic-engineering technology successfully reduces pest pressure on a field, farmers
of adjacent or nearby fields planted with non-GE crops may benefit from reductions in costs for
pest control associated with reductions in regional pest populations (Sexton et al., 2007). Such
favorable externalities may exist for Bt crops, which control pests that target GE and non-GE
crops equally (Ando and Khanna, 2000). HR crops may provide some benefits to non-GE crops
on adjacent fields by reducing rates of pollination of weeds, but more certain benefits will accrue
to crops planted in rotation with GE crops. Specifically, because HR crops permit the
postemergent use of broad-spectrum herbicides, such as glyphosate, weed species that affect GE
and non-GE crops may be controlled more effectively. In particular, glyphosate has proved
effective in controlling perennial weeds that appear late in the principal crop season, persist, and
impose losses on subsequent crops (Padgette et al., 1996; Shaw and Arnold, 2002). The
reduction in pest pressure from the late-season use of effective chemicals on HR crops may
benefit the crop planted in the following season (Baylis, 2000; Tingle and Chandler, 2004)
although empirical evidence of this effect is scarce. A massive field trial of crop rotation and
herbicide application practices in Britain has provided evidence that the production systems used
for HR canola can improve weed control in cereal crops planted in rotation (Sweet et al., 2004).
'*As stated above, the introduction of GE crops will probably reduce pest damage and, in some ca.ses, will
reduce the commodity prices of com, soybean, and cotton. In the damage-control framework, the dem^d for inputs
other than the ones controlling pests (such as water and energy) is represented by (Lichtenberg and Zilberman,
1986)
Quantity demanded * (crop priceXl - damageXmarginal value of the input in
producing potential output).
This equation suggests that GE cultivare will contribute to increased demand for inputs — such as fertilizer, water,
and capital — if adoption of GE cultivars increases the earning per unit of potential output, which is equal to (crop
price)(I - damage), assuming no acreage constraints. Thus, when the introduction of GE cultivars does not affect
crop prices but reduces pest damage, adoption of GE crops increases the demand for other input use. That increases
the demands for fertilizer, water, capital, and so on, and corses upward pressure on their market prices. When the
introduction of GE cultivars reduces commodity prices substantially, it may lead to reduced demand for other inputs.
We are not familiar with empirical studies that have tried to estimate the impact of GE crops on the demand for or
prices of other inputs, and this is a subject for fiiture work.
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Farmers of non-GE crops may also experience adverse externalities associated with HR-crop
weed control. Growers experience an adverse effect when an economically important amount of
herbicide resistance builds up. As discussed in Chapter 2, resistance to broad-spectrum
herbicides is a concern associated with adoption of HR varieties because use of other chemicals
drastically declines in favor of the herbicide to which the crop is resistant (Shaner, 2000). When
resistance in weeds evolves, farmeis have resorted to managing those weeds with additional
forms of control; they have either increased their use of the herbicide to which the HR crops are
resistant, used additional and possibly more expensive forms of weed control (such as
cultivation), or both. Such actions not only reduce or reverse the environmental benefits of HR
crops reviewed in the previous chapter but also result in higher production costs for the grower
compared to using glyphosate alone. To date, costs have not risen to the level of costs incurred in
the conventional systems of weed control. If they had, a substantial reduction In the use of HR
crops would have occurred. Resistance-management strategies, such as the use of refuges, can be
expensive for individual farmers, though such strategies can provide long-run pest control
benefits in the area that will offset the sum of individual costs if implemented correctly.
Although Bt crops may be prone to resistance buildup because the toxins that target pests are
always present in the field, the refuge requirements for Bt crops have thus far provided adequate
protection from insect resistance buildup in the United States. The tradeoff is the requirement to
plant some percentage of a crop to non-Bt cultivars, which may result in net economic costs to
producers growing IR crops. Those costs, if they occur, are in the form of higher pesticide costs,
foregone yield, or both. A benefit is the lower cost of seed for the refuge acres. A case in point is
Bt cotton with the single trait for bollworm and budworm control, for which EPA requires a 20
percent insect-treated refuge or a 5 percent non-insect-treated refuge in the Southeast. Farmers
who choose the 20 percent refuge can incur higher insecticide costs to treat insect infestations —
more passes over the field and more labor to scout for insects — but have lower overall seed
costs. Those who choose the 5 percent, untreated refuge can experience substantial yield loss on
the refuge acres, though the cost of seed for those acres is lower. It is important to note that
before the introduction of the Bt crops substantial insect resistance to other classes of
insecticides, such as pyrethroids, had been observed.
SOCIOECONOMIC IMPACTS OF GENE FLOW
Inadvertent gene flow from GE to non-GE crops can also have a variety of social and
economic effects. Both the Ecological Society of America and the National Research Council
have recognized that some degree of gene flow between sexually compatible GE and non-GE
crops occurs regularly (NRC, 2004; Snow et al., 2005). Indeed, the presence of adventitious GE
traits in the intended non-GE seed supply of canola, cotton, com, and soybean and in the seed
supply of GE crops (e.g., a Bt trait in crop seed that is intended as HR only) is well documented
(Beckie et al., 2003; Friesen et al., 2003; Mellon and Rissler, 2004; Heuberger et al., 2008;
Heuberger and Carriere, 2009) The probability of gene flow is similar in both directions between
GE and non-GE varieties of a crop (Maliory-Smith and Zapiola, 2008); however, for farmers,
consumers, and food distributors, the actual and perceived consequences of gene flow from GE
to non-GE crops are greater than the consequences of gene flow from non-GE to GE crops.
Gene flow between GE and non-GE crops occurs via three routes: cross-pollination between
GE and non-GE plants from different fields (as discussed in “Gene Flow and Genetically
Engineered Crops” in Chapter 2), co-mingling of seed before the production year (in the
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presence of GE traits in seed bags of non-GE crops) or during the production year (mixing of
seed at planting, at harvest, or during storage), and germination of seeds left behind (i.e.,
volunteers) after the production year (Owen, 2005; McHughen, 2006). Generally, GE and non-
GE crops can coexist. However, given that some domestic and foreign consumers are willing to
pay a premium for non-GE product, there are strong market incentives as well as some
sociocultural reasons for farmers, seed distributors, and food processors to minimize the
adventitious presence of GE traits in non-GE crops and derived products (Lin et al., 2003;
Belcher et al., 2005; Furtan et a!., 2007; Devos et al, 2008).
Gene flow between HR and non-HR crops can increase production costs if gene flow
promotes weediness. For example, when volunteer seeds survive and germinate to the following
season, field management costs increase because the volunteers will not be eliminated by
glyphosate applications. Similarly, if HR traits cross into weedy relatives, weed-control expenses
will be higher for all fields on to which these weeds spread, whether the fanner grows GE crops
or not (Smyth et al, 2002).
Gene flow of GE traits could jeopardize the economic value of the entire harvest of non-GE-
crop farmers by rendering their output unsuitable for high-value markets (Bullock and
Desquilbet, 2002). They could also have unfavorable effects on the levels of trust that exist
between market participants. Two groups of farmers could be impacted by gene flow: those
fanning non-GE crops conventionally and organic farmers. The U.S. government does not have
thresholds for what level of purity is required to characterize a product as non-GE; the thresholds
are instead determined by the market. TTie U.S. National Organic Program excludes GE methods
from the organic process (OFPA, 2009). Because of adventitious gene flow, the organic process
does not necessarily result in a non-GE product when it goes to market; whether adventitious
presence is discovered depends on if testing for GE material is conducted. Therefore, if GE traits
are discovered in organic crops intended for a non-GE market, the organic or non-GE status of a
crop may be forfeited depending on the potential legal or market tolerances for the presence of
GE traits (Gealy et al, 2007). Other governments have set thresholds for organic and non-GE
crops; for example, Japan has a 5 percent threshold for com while the EU has zero tolerance for
non-approved GE material but a 0.9 percent permissible level for GE material that has been
approved by the EU (Bradford, 2006; Ronald and Fouche, 2006). Tests can be performed to
assess the presence of GE traits in grain to preserve the identity of non-GE grain; whether a
positive test results in rejection of a product depends on the individual policies of buyers.
Additional research is needed to determine the extent to which screening is used and its
relationship to variation in consumer desires for purity in the food supply. Although non-GE
products can lose market value because of the adventitious presence of GE material, the price of
GE products is not affected by the adventitious presence of non-GE material Accordingly, gene
flow between GE and non-GE crops imposes costs primarily on consumers and producers of GE-
free crops (Smyth et al, 2002; Belcher et al, 2005; Devos et al, 2008). Such a need to protect
the market value of non-GE products probably contributed to the creation of GE-free zones in
some regions of the United States and in the EU (Jank et al, 2006; Furtan et al, 2007).
Widespread use of GE crops in the United States may have forced some corporations that were
producing GE-free products to move their operations to countries w'here GE crops were less
prevalent (Mellon and Rissler, 2004). Nevertheless, a survey published in 2004 suggested that 92
percent of U.S. organic growers who responded to the survey had not incurred any direct costs or
suffered losses attributable to the adventitious presence of GE crops (Brookes and Barfoot,
2004). However, it must be noted that there have been considerable increases in the adoption of
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GE crops in the United States as well as growth in U.S. organic-crop production and the market
for non-GE products since this survey was conducted, that so far GE traits have been
incorporated into a small number of crops that have few near-relatives in U.S, agriculture, and
that few studies have analyzed trends in the socioeconomic impacts of gene flow.
A zero tolerance for the presence of GE traits in non-GE crops is generally impossible to
manage and is not technically or economically feasible. Pollen transfer between sexually-
compatible GE and non-GE crops is difficult, if not impossible, to prevent, and segregation
between GE and non-GE products may be accomplished more easily and economically when
nonzero thresholds for the adventitious presence of GE material in non-GE end-user products
and seed are established. The goal of the thresholds is to set acceptable limits for the presence of
GE traits that have been deemed safe and approved for human consumption. Accordingly,
programs aimed at establishing such thresholds are analogous to seed-certification and food-
labeling programs that have been used for decades to ensure the quality of seeds for agriculture
and of food for consumers. The difficulty of maintaining the coexistence of GE and non-GE
crops increases as the tolerance for the adventitious presence of GE traits in non-GE products
becomes lower and the adventitious presence of GE traits in non-GE products becomes easier to
detect even at very low levels due to technological advances.
The situation has a drastically greater impact when GE traits not approved for human
consumption contaminate non-GE products. Such contamination can have strong adverse effects
on market value, on the possibility of exporting crops, on the costs of remedial actions to remove
contaminated supplies, and therefore on the profit margins of food producers and distributors
(Lin et al., 2003; Vermij, 2006; Vogel, 2006). It can also undemiine public confidence in the
food system. The effects of the identification of a variety of Bt com marketed under the name
StarLink® in human food constitute an important example. StarLink® was approved only for use
in animal feed but was discovered in products destined for human consumption. The resulting
concerns about food safety led to the recall of more than 300 food products, and some major U.S.
export markets, such as Japan and South Korea, imposed trade restrictions (Lin et al., 2003). The
technology developer ultimately discontinued sale of StarLink® seed. Similarly, the accidental
release of glufosinate-resistant rice in the United States in 2006 and the contamination of
sulfonylurea-resistant flax in Canadian exports in 2009 imposed heavy costs on farmers,
commodity traders, and processors.
Those examples of accidental releases, or any other low-level presence of unapproved GE
material in the food supply, impose considerable costs on the food system that need to be
accounted for in cost-benefit analyses of GE crops (Salazar et al., 2006), They also affect
farmers’ planting decisions because of the risk of lost revenues and other economic and social
costs. As more exotic GE crops (e.g., pharmaceuticals) enter the commercialization phase,
possible supply disruptions will multiply with greater potential for conflict between sectors in the
food and non-food industries and substantial economic costs. Such potential market and political
repercussions indicate that a very low tolerance threshold set by U.S. regulatoiy authorities is
appropriate for the presence of unapproved GE traits in food intended for human consumption.
Certain groups of consumers prefer GE-ffee products, a preference that is likely to increase
the demand for products made with ingredients from organically grown crops. The NOP
regulations require the certified organic producers must produce and handle their organic
agricultural products without the use of GE methods (NOP, 1990). However, the unintentional
presence of GE material in organic products will not necessarily lead certifying agents to change
the status of an organic product or operation (Federal Register, 2000), As explained above,
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because some level of gene flow between GE and non-GE crops is difficult to prevent, the
adventitious presence of GE material has been detected in non-GE products, including certified
organic products. Therefore, the process-based NOP standard that excludes GE methods in
production and handling systems does not assure that organically grown crops with non-GE
methods will be free of GE material for marketing.
The presence of GE material can affect the ability of growers to sell non-GE and organic
crops in domestic and foreign maricets with requirements beyond the process-based standard of
the NOP. Accordingly, policies have been established to manage the potential for adventitious
presence while enabling coexistence of GE, GE-free, and organic production systems. However,
policy-established tolerance thresholds for the adventitious presences of traits from
commercialized GE crops in non-GE or organic products vary considerably among countries.
For example, in the United States, voluntary labeling of food as GE-free is allowed as long as a
product contains less than 5 percent adventitious presence of GE material{Demont and Devos,
2008; OFPA, 2009). In contrast, the EU allows up to 0.9 percent adventitious GE material in
non-GE food, animal feed, and products labeled as organic if the GE crop has been approved in
the EU; otherwise, the threshold is zero (Demont and Devos, 2008). Certified non-GE seed sold
to farmers in the United States is typically expected to contain less than 0.5-1 percent of seeds
(depending on crop type) with GE traits (Mellon and Rissler, 2004; CCIA, 2007). Thresholds for
commercial seed have been considered but have not yet been implemented uniformly in the EU
(Kalaitzandonakes and Magnier, 2004; Devos et al., 2008).
GE-free or organic products lose their premium market value when the adventitious presence
of GE material exceeds established government or market thresholds. Anecdotal stories suggest
that the crops of U.S. organic growers are being screened in the marketing chain for the presence
of GE material and are being rejected if levels exceed market-determined levels. We do not have
evidence to judge how widespread such testing is in the United States. This issue deserves more
investigation to determine the extent of such market-led behavior and the social and other factors
driving it. We do know that given the threshold criteria in the EU for GE material in organic
products, food produced in the United States and labeled as organic by U.S. certifiers could be
rejected in the EU as not organic because of adventitious presence of GE material even though
no GE seed or crops were used in production by U.S. producers. The coexistence of GE and non-
GE products is possible as long as measures are taken to ensure that the adventitious presence of
GE traits remains below the thresholds set in receiving markets, either by governments or buyers.
In general, threshold differences among regions contribute to creating barriers to the use of GE
crops and trade in non-GE products (Smyth et al., 2002; Demont and Devos, 2008; Devos et al.,
2008).
Separating GE and non-GE products at every step of the production process is expensive, and
costs increase as thresholds for the presence of GE traits in non-GE products decrease (Lin et al.,
2003; Kalaitzandonakes and Magnier, 2004). Growers must attend to details and apply
considerable effort to achieve effective segregation between GE and non-GE crops (CBI, 2007).
Grain segregation in normal production settings is difficult but can be accomplished and could
effectively minimize the co-mingling of GE and non-GE crops. Given that co-mingling of seeds
can be costly for growers, particularly for growers who have specific contracts that restrict GE
traits, tactics for isolating GE crops from non-GE crops must be established effectively (Owen,
2000). Controlling volunteer GE crops in non-GE crops may not be difficult, depending on crop
rotation, but requires considerable diligence on the part of growers (Owen, 2005). When
volunteer crops acquire a GE trait for herbicide resistance via unintended gene flow, weed-
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management costs for a grower may increase and potential crop yield may decline if the crop
planted the following season is also resistant to glyphosate (Owen and Zelaya, 2005).
Furthermore, the isolation distances required to maintain complete segregation for open-
pollinated crops are often too large to be economically feasible (Matus-Cadiz et al., 2004).
An economic assessment based on data from major seed firms in the United States indicated
that reducing the adventitious presence of GE traits in non-GE com seed from 1 percent to 0.3
percent would raise seed production costs by about 35 percent (Kalaitzandonakes and Magnier,
2004).'^ The increased costs would involve changes in field operations and in processing and
result from new expenses for extra purity testing, storage, and transportation, but most of the
increase in production costs would result from measures taken at the field level to minimize gene
flow. Thus, programs that set levels of tolerance for the adventitious presence of GE traits in
non-GE products probably have substantial impacts on growers directly and would increase the
cost of non-GE seed and the market value of GE-free and organic products (Smyth et al., 2002;
Kalaitzandonakes and Magnier, 2004; Belcher et al., 2005).
Barring the risk of contamination, GE crops can contribute to the creation of market
opportunities for non-GE farmers. The organic market is a primary example. By virtue of the ban
on the use of GE traits in the official USDA definition of organic production, the organic
movement can market itself to, and collect a price premium from, consumers who prefer not to
purchase food or fiber produced with genetic-engineering technology. Consumer preference for
non-GE foods may be related to other traits associated with organic production, but the stated
price premium for non-GE crops is substantial in some segments of the population (Huffman et
al., 2003).
CONCLUSIONS
The widespread adoption of GE crops has had agronomic and economic implications for
adopters and non-GE producers in the United States. For GE farmers, the general increase in
yield, reduction in some input costs, improvement in pest control, increase in personal safety,
and time-management benefits have generally outweighed the additional costs of GE seed. The
use of HR crops has not greatly increased yields, but it has generally improved weed control,
especially on farms where substantial weed resistance to the specific herbicide to which the HR
crop is resistant has not developed, and it has improved farmers’ incomes by saving time thus
facilitating more off-farm work or providing more management time on the farm. IR crops have
increased yields in areas where economically damaging insect-pest pressures occur and have
saved on expenditures for conventional pesticide. Thus, the use of HR and IR crops has mostly
increased adopters’ incomes compared with the use of non-GE varieties.
It should be noted that the economic benefits have changed over time and probably will
continue to change. Yield lag and yield drag were not uncommon when HR crop varieties were
first introduced, but GE traits have since been incorporated into high-yielding varieties, and
improved GE events have replaced the initial events. Although research has identified those
changes in farmers’ experience with GE crops, there has been little investigation of the economic
impact of GE crops more recently. More research would improve the information available to
' This study is a summary assessment over various GE crop technologies and therefore should not be
applied to specific situations. It is likely that the impacts would vary considerably over different GE cultivars and
their specific farming situations.
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farmers, plant breeders, and policy-makers as market, environmental, and social conditions
change.
The extent to which GE crops make it economical to expand production to lands not
previously cultivated or to intensify production on existing cropland with double cropping has
not been reported adequately in the literature. More research on the economic effects of GE-crop
adoption on non-^E-crop producer would also be beneficial. Examples include the costs and
benefits of shifts in pest management for non-GE producers due to the adoption of GE crops, the
value of market opportunities afforded to organic farmers by defining their products as non-GE
crops, the economic impacts of GE adoption on livestock producers, and the costs to farmers,
marketers, and processors of adventitious presence or contamination from approved or
unapproved GE traits and crops into restricted markets.
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4
Farm-System Dynamics and Social Impacts of Genetic Engineering
The dissemination of genetically-engineered (GE) crops, like the adoption process associated
with other farm-level technologies, is a dynamic process that both affects and is affected by the
social networks that farmers have with each other, with other actors in the commodity chain, and
with the broader community in which farm households reside. As noted in Chapter 1, farmer
decisions to adopt a technology are influenced not only by human-capital factors, such as the
educational level of the adopter, but by social-capital factors, such as access to information
provided by other farmers through social networks (Kaup, 2008). That necessarily implies that
farmers receive information from others — for example, on the risks and benefits of a particular
technology — and that they share their own knowledge and experience through the same
networks. Such findings confirm the relevance of social factors in influencing how genetic-
engineering technology is adopted, what the impacts of its adoption are, and the significance of
farmers’ active participation in both formal and informal social networks with other actors in
commodity chains and communities.
However, little research has been conducted on the social impacts of the adoption of genetic-
engineering technology by farmers, even though there is substantial evidence that technological
developments in agriculture affect social structures and relationships (Van Es et al., 1988; Buttel
et al., 1990). Because further innovations through genetic engineering are anticipated, such
research is needed to inform seed developers, policymakers, and farmers about potential
favorable benefits for adopters and nonadopters and unwanted or potentially unforeseen social
effects (Guehlstorf, 2008). With such information, the likelihood of maximizing social benefits
while minimizing socials costs is increased. To demonstrate the necessity for increasing
commitments to the conducts of research on the social effects of GE-crop adoption, this chapter
synthesizes what is known in the scientific literature about the social impacts of farm-technology
adoption and the interactions between farmers’ social networks. The chapter also identifies
future research needs.
SOCIAL IMPACTS OF ON-FARM TECHNOLOGY ADOPTION
The earliest academic research in the United States on the social impacts of technology
adoption at the farm and community levels was focused on mechanical technologies. More than
a century ago, the use of machines in U.S. agriculture not only displaced labor but widened
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socioeconomic discrepancies between skilled and unskilled laborers (Quaintance, 1984).
Academic interest in the socioeconomic consequences of agricultural mechanization was
particularly strong in the 1930s and 1940s in the southern United States (Buttel et al., 1990) and
again in the 1970s throughout the countiy'. Berardi (1981) summarized the findings of the
literature and found that mechanization was associated with decreases in the agricultural labor
force, particularly those among the least educated and least skilled workers and in minority
groups; with better working conditions and less “drudgery” for the remaining work force; with a
decrease in farm numbers and an increase in farm size; with increased capital costs for
agricultural producers; and with a decline in the socioeconomic viability of agriculture-
dependent rural communities. Data also suggested that the technological development of U.S.
agriculture had contributed to declines in farm labor. In community dependence on agriculture,
and in rural community viability although other on-farm and off-farm factors also contributed to
these changes (Van Es et a!., 1988).
In the 1980s, social scientists broadened their research on the impacts of technology adoption
on fanns and farm communities to include studies of the potential and actual impacts of
biological (pre-genetic engineering) technologies in agriculture. Many observers assumed that,
unlike the earlier wave of mechanical agricultural technologies, genetic-engineering technology
would not be biased towards large-scale farming operations. Such an assumption was supported
by analyses of the production capabilities of agricultural biotechnology. For example, it was
noted that no interaction effect was observed between genetic predisposition to produce milk and
the use of the growth hormone bovine somatotropin (BST) to increase milk production in dair>'
cows (Nytes et al., 1990). However, other studies that directly examined farm-level social
change revealed that, despite the presumption of scale-neutrality, it was difficult to isolate the
impacts of biological innovations from those of other technological innovations in agriculture
because biological innovations were often developed and disseminated in conjunction with other
technologies that may not have been scale-neutral (Kloppenburg, 1984).
Additional research conducted on the social impacts of biotechnology in animal agriculture,
specifically on the use of BST, noted that rates of adoption of BST were moderate and that,
although adoption did not require large herds, scale effects were observed because BST use was
more effective in high-producing cows, which were more likely to be found in large herds with
complementary feeding technologies (Barham et al., 2004). Beck and Gong (1994) also observed
the existence of a scale effect with adoption of BST, with adopters more likely to have larger
herds, as well as being younger and having more formal education. Additionally, it was
suggested that the quality of farm management had an impact on the benefits accruing to the
adoption of BST (Bauman, 1992). The use of BST also was thought to lead to lower prices and
thus to result in increased economic pressure on smaller producers (Marion and Wills, 1990). In
other words, the body of research on the socioeconomic consequences of the use of
biotechnologies, including Green Revolution technologies, indicated that “scale neutrality is not
inevitable, but a possibility that depends on institutional context” (DuPuis and Geisler, 1988;
410). To put it another way, the social context of the adoption process and the impacts on that
context are interconnected, from which it follows that the social impacts of genetic-engineering
technology on farms and communities differ among cultures, commodities, and historical
periods.
Thus, though seed varieties are generally conceptualized as being scale-neutral, the adoption
of any technology may be biased toward large firms that can spread the fixed costs of learning
over greater quantities of production (Caswell et al, 1994). In developing countries, the
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economics of genetic-engineering technology do not appear to vary with farm size (Thirtle et ai.,
2003). However, scale may affect accessibility to technology. Small farmers have less influence
in input supply and marketing chains with which to secure access to desired technologies. Thus,
there can be a scale bias in the development and dissemination processes associated with
herbicide-resistance technology that puts small farmers at a disadvantage. In contrast, as noted in
Chapter 3, insect-resistance technolo©' can replace insecticide applications that require fixed
capital investments, such as for tractors and sprayers. In this regard genetic-engineering
technology has the potential to favor small farmers, who would benefit more from a technology
that required less fixed capital investment. The scale effects of transgenic varieties may also
depend on the pricing (such as quantity discounts) set by seed companies, which typically assess
a technology-user fee. '
An early empirical study was carried out by Femandez-Cornejo et al. (2001) using 1998 U.S.
farm data. They found that, as expected, the adoption of HR soybean was invariant to size, but
adoption of HR corn was positively related to size. They explained this disparity as due to the
different adoption rates: 34 percent of the farms had adopted HR soybean at the time, implying
that adoption of HR soybean had progressed passed innovator and early-adopter stages into the
realm where adopting farmers are much like the majority of farmers. On the other hand, adoption
of HR com was quite low at the time (5 percent of farms), implying that adoption was largely
confined to innovators and other early adopters who in general tend to control substantial
resources and who are willing to take the risks associated with trying new ideas. Thus, they
claimed that the impact of farm size on adoption is highest at the very early stages of the
diffusion of an innovation (HR com), and becomes less important as diffusion increases. This
result confirms Rogers’s (2003) observations that adoption is more responsive to farm size at the
innovator stage, and the effect of farm size in adoption generally diminishes as diffusion
progresses. Early adopters, by virtue of early adoption, also are able to capture a greater
percentage of the economic benefits of the technology adoption process.
Clearly, one cannot extrapolate the social Impacts of the adoption of GE crops based solely
on an assumption that the productive capabilities of genetic-engineering technology, when
isolated from the interaction with other factors, should be scale-neutral. In other works, previous
research on the social impacts of agricultural technologies suggests the possibility that the early
dissemination of genetic-engineering technology would be associated with farm size, and that the
use of GE crops could have differential impacts across farm types, farm size, and region, despite
the fact that GE crops are presumed to be scale-neutral.
In an article that attempted to predict some of the environmental, economic, and social
effects of genetic engineering of crops, it was argued that the use of GE crops was “clearly
capable of causing major ecological, economic, and social changes” (Pimentel et al., 1989 p.
61 1). Nonetheless, over the last decade, there has been virtually no empirical research conducted
on the social impacts of the use of GE crops on farms and rural communities. The lack of
research may have to do in part with the scarcity of funds available for such research as well as a
relative lack of interest in social issues on the part of environmental groups (Chen and Buttel,
2000), and other groups and organizations that might be expected to support such research.
Nonetheless, the results of research referred to above on the social repercussions of agricultural
technologies, including non-genetic-engineering biotechnology in crops and biotechnology in
'Examples of empirical studies on the eifectof farm size on GE adoption are given in “An Early Porft-aitof
Farmers who Adopt Genetically Engineered Crops” in Chapter 1.
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animal agriculture, would suggest that there are impacts, that these impacts could be favorable or
adverse, and that adverse impacts could be alleviated through the adoption of appropriate
policies. For example, based on earlier research on the introduction of new technologies in
agriculture, it might be hypothesized that certain categories of farmers (those with less access to
credit, those with fewer social connections to university and private sector researchers, etc.)
might be less able to access or benefit from existing GE crops. There is also the possibility that
the types of genetic advances being mariceted do not meet the needs of certain classes of farmers,
and that the full spectrum of the potential of genetic-engineering technology is not being
achieved. Furthermore, the possibility exists that communities where farmers play an important
social, political, and economic role could be impacted as well. However, for the purpose of this
report, no conclusion on the social impacts of the adoption of GE crops can be drawn on the
basis of empirical evidence. Research on such impacts clearly should be accorded a high priority
as genetic-engineering technology evolves. Without such research, the potential for genetic-
engineering technology to contribute to the sustainable development of U.S. agriculture and rural
communities cannot be adequately assessed. ITius, we recommend that such research be
sponsored and pursued actively and immediately.
SOCIAL NETWORKS AND ADOPTION DECISIONS
The adoption of genetic-engineering technology and its performance on the farm are
functions of the knowledge of agricultural decision-makers, who include farmers, input
suppliers, commodity traders, farm-management consultants, and extension agents. In making
technology-adoption decisions, farmers rely principally on information about the relative
performance of competing technologies and on information about best practices for optimizing
yields and controlling costs, given the technologies that they use. The performances of firms and
technology, therefore, depend upon the information used by various commodity-system actors.
Just et al. (2002) have shown that the internal competences of decision-makers affect the degree
to which they rely on different types and sources of information.
Farmers rely on a variety of intermediaries — such as extension agents, commodity groups,
commercial vendors, agricultural media, and other farmers — for information. For example,
farmers often turn to commodity associations for information about regulations and regulatory
changes. Many of the intermediaries that farmers communicate with use public information,
especially data and research results provided by the U.S. Department of Agriculture (USDA)
Economic Research Service and the National Agricultural Statistics Service and by state
extension services, particularly for information about the economic outlook of agriculture and
specific industries. Intermediaries use formal channels of information more than fanners (Just et
al., 2002) and then make that information available to fanners.
Farmers obtain about half their information from informal sources (i.e., sources whose
professional duties do not include provision of information) (Just et al., 2002), including people
in the end-users’ civic, community, professional, and commercial networks, like neighbors,
colleagues, customers, and suppliers. Fanners’ reliance on informal sources may reflect low
availability of or access to information from formal channels, issues of affordability of private
information, and credibility (Just et al., 2002).
Those findings suggest that fanners’ attitudes toward GE crops are likely to be affected by a
number of information providers. USDA’s Cooperative Extension Service, commodity groups,
and agricultural media are particularly influential in informing farmers’ views on the technical
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aspects of genetic-engineering technology, its economic implications, and its prospects.
Although the influence of those sources has not been widely appreciated, they have played a key
role in the adoption of the technology. As Wolf et al. (2001) and Just et al. (2002) demonstrated,
informal sources of information are just as likely as formal sources to accelerate or to slow the
rate of GE-crop adoption. It would also be reasonable to hypothesize that patterns of information
use would be linked to the ability of farmers to use the technology effectively and maximize its
potential.
INTERACTION OF THE STRUCTURE OF THE SEED INDUSTRY AND FARMER
DECISIONS
The U.S. seed industry has experienced extensive structural change in the last few decades.
The changes have affected decisions at the farm level by shaping the choices available to com,
soybean, and cotton farmers.
As Femandez-Comejo and Just (2007) have summarized, plant-breeding research until the
1930s was conducted primarily by the public sector (for example, USDA and state agricultural
experiment stations), and most commercial seed suppliers were small, family-owned businesses
that multiplied seed varieties that had been developed in the public domain. Seeds embody the
scientific knowledge needed to produce a new plant variety with desirable attributes — such as
higher yield, disease or pesticide resistance, or improved quality — so seed innovators face both
the risk of imitation by competing seed firms and the risk of seed reproduction by farmers
themselves (Femandez-Comejo, 2004). The development of hybrid com in the first half of the
20th century provided breeders with greater protection of intellectual-property rights (IPR)
because seeds saved post-harvests produced substantially smaller yields than the hybrid plants
from which they were gathered. With that incentive, the number of private firms engaged in com
breeding grew rapidly.
The proliferation of firms was followed by consolidation in part because U.S. law evolved to
provide incentives to innovators for research and development by giving them exclusive control
of their innovations through patent laws and other forms of enforceable legal protection
(Femandez-Comejo, 2004). Two principal forms of legal protection for seed innovators are plant
variety protection (PVP) certificates issued by the Plant Variety Protection Office of USDA and
patents issued by the Patent and Trademaric Office (PTO) of the U.S. Department of Commerce.
Both grant private crop breeders exclusive rights to multiply and market their newly developed
varieties. Patents provide more control because PVP certificates have a research exemption that
allows othere to borrow a new variety for research purposes (Femandez-Comejo and
Schimmelpfennig, 2004). IPRs for seed innovators were strengthened by the U.S. Supreme
Court’s 1980 Diamond v Chakrabarty decision, which extended patent rights to GE
microorganisms, important tools and products of biotechnology. A series of rulings by PTO’s
Board of Appeals and Interferences widened the scope of patent protection for GE organisms by
including plants and nonhuman animals. Those rulings extended IPRs to a wide array of new
biotechnology products in the form of utility patents (also referred to as patents for invention).
Products protected under the rulings include seeds, plants, plant parts, genes, traits, and
biotechnology processes (Fuglie et al., 1996; Femandez-Comejo, 2004).
Enhanced IPR protection has brought rapid increases in private research and development
(R&D), and indirectly assisted t^hnology developers in setting prices above marginal costs
(Goldsmith, 2001). Private spending on R&D in crop varieties increased by a factor of 14 in real
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terms from 1 960 to 1 996 (Femandez-Comejo, 2004), whereas public (federal and state) spending
changed little (Figure 4-1); (Femandez-Comejo and Schimmelpfennig, 2004). At the same time,
IPR protection may have spurred market concentration in the seed industry. The potential profits
of seed firms made possible through IPR protection may strengthen the incentive to invest and
thus provide greater opportunities to large firms (Lesser, 1998). Many seed firms have been
acquired by corporations that have the resources needed to achieve large economies of scale in
R&D (Femandez-Comejo, 2004). For example. Lesser (1998) stated that more than 50 seed
firms were acquired by pharmaceutical, petrochemical, and food firms after the passage of the
Plant Variety Protection Act.^ In contrast, Lesser (1998) also noted that weakness of IPR
protection may lead to mergers and acquisitions. In any case, by 1997, the share of U.S. seed
sales controlled by the four largest firms reached 69 percent for com (up from 60 percent ! 973),
47 percent for soybean (up from 7 percent in 1980), and 92 percent for cotton (up from 74
percent in 1970) (Table 4-1; Femandez-Comejo, 2004). Though it is difficult to obtain recent
detailed published market share information, it appears from company reports and other sources
that the trend of increased concentration in the structure of the seed industry continued in recent
years. ^ Farm survey data for com and soybean indicated that by 2007 the share of the four
largest firms reached 72 percent for com and 55 percent for soybean (Figure 4-2; Shi and
Chavas, 2009).
Year
FIGURE 4-1 Public and private research expenditures on plant breeding. Biological efficiency
includes breeding and selection of improved plant varieties.
SOURCE: Femandez-Comejo, 2004.
■The Plant Variety Protection Act (PVPA) of 1970 granted plant breeders a certificate of protection that
gave them exclusive rights to market a new plant variety for 18 years from the date of issuance. Amendment of the
PVPA in 1994 brought it into conformity with international standards. Protection provided by certificates of
protection was extended from 1 8 to 20 years for most crops (Femandez-Comejo, 2004).
^In the case of com, Pioneer has lost its dominant position in the com seed market from about 40 percent to
30 percent while Monsanto’s share of the com seed market increased to about 30 percent as a result of the Landec
acquisition (Leonard, 2006).
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TABLE 4-1 Estimated Seed Sales and Shares of Major Field Crops, United States, 1997
Company
Total
($ billions,
current)
Com Maricet
Share
Soybean Market
Share
Cotton Market
Share
Percentage of Acres
Pioneer Hi-Bred
International
1.18
42.0
19.0
—
Monsanto/Stoneville
0.54
14.0
19.0
n.o
Novartis/Syngenta
0.26
9.0
5.0
—
Delta & Pine Land
0.08
—
—
73.0
Dow Agrosciences/Mycogen
0.14
4.0
4.0
—
Golden Harvest
0.09
4.0
—
—
AgrEvo/Cargill
0.09
4.0
—
—
Others
1.12
23.0
53.0
16.0
Total
3.50
100.0
100.0
100.0
SOURCES: Hayenga, 1998; Femandez-Comejo, 2004.
Concentration of R&D output can also be used to measure the concentration in innovation
activity in the seed industry (Fulton and Giannakas, 2001). In genetic-engineering technology, a
measure of R«feD output is the number of GE cultivars approved by USDA for release into the
environment for field testing. In particular, Femandez-Comejo (2004) adapted the four-firm
concentration-ratio measure, commonly used to quantify industry concentration in terms of sales,
to examine R&D concentration on the basis of regulatory approvals of GE crop varieties. Table
4-2 shows the percentage of field releases obtained by the leading four firms in 1990-2000. The
top four firms controlled well over 50 percent of the approvals; this suggests consolidation in
R&D and potential barriers to entry for competitors. As Fulton and Giannakas (2001) noted,
expenditures on R&D and expenditures made to obtain regulatory approvals are sunk costs —
costs that cannot be recouped. If such sunk costs are present, markets are not contestable, so
there are potential barriers to entry.'*
'’a contestable market behaves in a competitive manner despite having few companies because of the threat
of new entrants.
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TABLE 4-2 Four-Firm Concentration Ratio in Field-Release Approvals from USDA Animal
and Plant Health Inspection Service, by Crop, 1990-2000
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
Com
67
67
65
82
82
67
60
73
73
80
79
Soybeans
100
100
94
68
72
94
82
82
71
87
85
Cotton
100
100
100
89
79
85
91
64
98
98
96
SOURCE: Fernandez-Cornejo, 2004.
Year
FIGURE 4-2 Share of planted acres of com and soybean seeds by largest four firms (CR4).
SOURCE: Stiegert et al., 2009.
As Femandez-Comejo (2004) observed, on the basis of the four-firm concentration ratio of
approvals, the extent of com-seed R&D concentration has been relatively constant at around 72
percent, which is fairly consistent with the four-firm concentration ratio in com in terms of sales.
Cotton-seed R&D is the most centralized, and this is also consistent with market-concentration
measures.
Patent ownership shows a pattern of concentration similar to that evident in other R&D
measures (Femandez-Comejo, 2004), Most of the biotechnology patents awarded to private
firms are held by a small number of large companies. As of 199^1997, Pioneer (soon after
DuPont/Pioneer) held the largest number of patents for com and soybean, followed by Monsanto
(Brennan et al., 2000). The leading firms in the sector have received IPR protection not only by
virtue of their respective R&D investments but through mergers and acquisitions. For example,
Pioneer was one of the first four companies active in the emerging com-seed market in the early
1930s. As shown in Figure 4-3, Pioneer (Pioneer Hi-Bred International, Inc.) made a series of
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acquisitions in 1973-1980 that strengthened ite overall position in the seed market. The chemical
firm DuPont bought 20 percent of Pioneer in August 1997 and bought the remaining 80 percent
in 1999 for $7.7 billion. As a DuPont company. Pioneer continues to operate under the Pioneer
name and remains headquartered in Iowa (Femandez-Comejo, 2004).
Agri-Con of Idaho
1975
Green Meadows
Ltd.
Lankhart
1975
Lockett
1975
Peterson
1973
Arnold Thomas
Seed Co. 1975
Garst & Thomas
Hybrid 1980
Pioneer Hi-Bred
International, Inc.
1999
> [ PuPonT
FIGURE 4-3 Evolution of Pioneer Hi-Bred International, Inc. / E. I. du Pont de
Nemours and Company.
SOURCE: Femandez-Comejo, 2004.
Although the increase in seed-industry concentration has raised concerns about its potential
Impact on market power, and ultimately on the sustainability of farms, empirical results for U.S.
cotton and com seed industries over the period covering 1970-1998 (which includes only 2 yeare
of GE-crop adoption) suggest that increased concentration during that time period resulted in a
cost-reducing effect that prevailed over the effect of enhanced market power (Femandez-
Comejo, 2004). Goldsmith (2001) argued that even though GE-seed prices were above the
competitive price, the actions of biotechnology supply firms apparently were not adversely
affecting the welfare of U.S. farmers.
However, concerns have been raised that, in time, such market power could lead to decreased
variability in the types of seeds being produced for the market, as well as increased prices, which
could limit the ability of farmers to purchase those seeds most suited for local environmental
conditions. In addition, it is conceivable that the continued market power of biotechnology
supply firms could lead to increased input costs for farmers, which in ftim could have an
unfavorable effect on the socioeconomic sustainability of farms. A recent study by Shi and
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Chavas (2009) has found that vertical integration (ownership of control of different stages of
production) in the U.S. soybean se^ industry had a substantial effect on soybean prices. Shi et
al. (2008) analyzed the pricing of com seed with stacked traits for the years 2000-2007 and
found “significant departures from component pricing (where seeds are priced as the sum of their
component values). The evidence supports sub-additive pricing. It shows that the marginal
contribution of each component to the seed price declines with the number of components.” The
authors also have indicated that “such a finding is consistent with the presence of economies of
scope in seed production. Indeed, synergies in R&D investment (treated as fixed cost) across
seed types can contribute to reducing total cost.”
In response to these concerns and others, USDA and the U.S. Department of Justice launched
a series of workshops in 2010 to examine competition and regulatory issues in the agriculture
industry (USDA, 2010). This is a first step towards updating and continuing research on how
market structure in the seed industry may be impacting seed prices and availability to variability
in genetic resources. In addition, studies of how seed-industry concentration, as well as the
practice of cross-licensing, could interact with farmers’ planting options and decisions, overall
yield benefits, crop genetic diversity, and economic returns would be very valuable.
Although the private sector owns the majority of agricultural-biotechnology patents, the
public sector still owns a substantial share. In a study of assignment of U.S. plant-biotechnology
patents granted from 1982 to 2001, Graff et al. (2003) found that 41 percent of the patents were
owned by large biotechnology companies, 35 percent by startups, and 24 percent by the public
sector. The public-sector ownership is weaker in some categories, such as Bt and other insect-
resistant traits (10 percent) and plant enzymes (8 percent), but stronger in other categories (42
percent in flowering and 56 percent in pathogen resistance). The capacity of the public sector to
obtain freedom to operate in transgenic crops is often also constrained by the fragmentation of
technology ownership among numerous institutions. Improved access to information about IPRs
and reduced transaction costs to obtain rights to use patents could increase the public sector’s
contribution to the development of transgenic varieties. Concerns have also been raised that
technology use and stewardship agreements prevent scientists in the public sector from
conducting independent assessments of GE varieties marketed by the private sector. In February
2009, in response to a notice in the Federal Register on a meeting of the Federal Insecticide,
Fungicide, and Rodenticide Act Scientific Advisory Panel, 26 entomologists submitted a general
comment that, because of those restrictions, the data that the Environmental Protection Agency
received regarding GE crops were inherently limited {Federal Register, 2009). If such
restrictions exist, farmer welfare could be adversely affected by the lack of complete information
regarding GE traits or crops. However, the degree to which technology use agreements may
hamper public research is unclear and strongly disputed by private-sector seed companies
(Monsanto, 2010). This issue merits careful investigation by neutral researchers to understand
what, if any, effects such agreements have on public research.
SOCIAL AND INFORMATION NETWORKS BETWEEN FARMERS AND INDUSTRY
Agriculture is unique among American industries in that federal law allows farmers to
cooperate in some collective activities while competing in the output market. That has enabled
farmers to act collectively as a counterweight to the large firms on which they rely to sell their
output (Cochrane, 1993). Farmers have developed cooperatives to coordinate research and
marketing efforts to benefit from economies of scale in these activities (Sexton, 1986). That
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collective-action capacity is important for adoption of genetic-engineering technology in that it
gives farmers the ability to influence crop trate that are introduced.
Farmers may attempt to block seed technologies if they anticipate that those new
technologies will not enhance, or perhaps even endanger, farm profit. Innovation in any crop can
increase farm revenue if the elasticity of demand for the crop is sufficiently high that increases in
output compensate for decreases in prices. But if the elasticity of demand is low, increased
output may lead to a fall in revenue and a decrease in profit unless the technology delivers cost
savings. In the latter case, farmere may attempt to block the introduction of a technology.
Farmers may also block a technology if ite introduction would result in lower prices in national
or international markets.
A large body of literature on the political economy of research argues that farmers use
political pressure to shape public research funding. Ruttan (1982) argued that farmer pressure
may have led to underinvestment in public research in the United States, and deGorter and
Zilberman (1990) linked overall spending on research to the political power of such groups as
consumers and producers. Graff and Zilberman (2007) argued that farmers’ interests partly
motivated Europe’s effective ban on GE crops, which in turn affected the access of U.S. farmers
who were growing GE crops to European markets.
Another example of farmers’ collective action is how farmers’ concerns influenced
Monsanto’s decision to halt its efforts to introduce and market herbicide-resistant (HR) wheat.
Some farmer coalitions in the United States and in Canada played a role in that decision because
they feared losing access to European and Asian markets that would not accept HR wheat. It was
thought that the introduction of that GE crop might have closed markets to U.S. and Canadian
farmers who planted non-GE wheat because of the difficulty in segregating wheat on fields and
in grain elevators and trucks (e.g.. Chin, 2004; Pollack, 2004). Many international buyers,
including millers and bakers in important Asian and European markets, had made it clear that
they wanted to purchase identity preserved (IP), non-GE commodities (Vandenberg et al., 2000).
In the case of white wheat, Japan and South Korea, two countries that have GE-food labeling
laws, were importing more than one-fourth of U.S. white wheat exports (Squires, 2004).
Japanese millers and bakers were well aware that a large percentage of Japanese consumers were
expressing negative attitudes toward the use of genetic-engineering technology in foods and
believed that their government’s regulation of GE food was too lax (Toyama et al., 2001).
Indeed, Japan was the United States’s largest market for non-GE com and soybean: nearly 90
percent of the IP, non-GE com and soybean produced in the United States was being exported to
Japan (Wilson et al., 2003). Faced with such demands from the marketplace and with farmer
concern about how those demands might influence sales in those markets, Monsanto decided to
defer the introduction of HR wheat in 2004.
However, farm organizations are not monolithic; indeed, the issue of HR wheat divided the
farming community (Graham and Martin, 2004). Even after Monsanto chose to suspend its HR-
wheat program, wheat producers and support groups, such as the National Association of Wheat
Growers, exhibited a strong interest in glyphosate-resistant wheat (Jussaume et al, 2004).
Monsanto’s HR trait had been inserted into only one variety of wheat grown in a subset of U.S.
and Canadian regions. It was opposed primarily by farmers who did not plant the potential HR
variety and by some farmers who could have planted it but were afraid of losing access to
European and Asian markets. Furthermore, during its deliberations, the present committee heard
that North Dakota wheat farmers who were gainst the introduction of HR wheat because of
concern about losing market access in Europe may now believe that they are disadvantaged by
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not having HR varieties and would like to see government and industry action that would lead to
its development (Wilson, personal communication). Pest pressure is heterogeneous among
growing regions, so support for or opposition to damage control through GE traits will vary
according to farmers’ abilities to benefit from them. Thus, the potential for collective action to
restrain the power of the seed industry is a function of farmers’ common interests, which are
often variable.
Farmer cooperatives may also undertake efforts to bring about the introduction of .seed traits
that the private sector, for economic or other reasons, is not motivated to introduce. They may
pool resources to undertake their own research or to defer the regulatory and development costs
that private firms face when they introduce new seed technologies. Farmers have worked with
universities to introduce new technologies (Bradford et al., 2006), and similar collaborations
could be effective in the development of genetic-engineering technology. In California, grape
growers have suffered considerable losses from Pierce’s Disease, so they have contributed funds
to the Public Intellectual Property Resource for Agriculture to support research for a genetic-
engineering solution to the problem (PIPRA, 2006). More generally, pooled funds from farmers
can lead to the introduction of desired traits for specialty crops when private seed companies lack
the incentives to develop the traits alone (for more discussion of seed-access issues, see Chapter
3). As the price of wheat goes up, for instance, farmers in some regions may approach companies
or universities to develop seed varieties to address specific constraints on productivity (Wilson,
personal communication). They may also work with initiatives like the Specialty Crop
Regulatory Assistance program, a fledgling collaboration of the federal government, scientists in
public universities and the private sector, and farmers designed to assist technology developers in
negotiating GE specialty crops through the requirements and expense of the regulatory process.
Despite the ability of farmers to organize collectively to counterbalance seed companies and
processors, some farmers are concerned about the evolution of seed-technology innovation from
a public good to a private good that is controlled by firms that have market power derived from
patents on specific products. Innovation in most agricultural inputs is embodied in the
technology, as in tractors and fertilizers. The technology is developed and sold by the private
sector. But because it had historically been difficult to capture benefits from research efforts in
seed technology before the advent of hybrid com seed, the private sector underprovided seed-
technology innovation, and the public sector took the lead in providing improved seed varieties
in many crops (especially wheat, soybean, cotton, barley, and oat). Consequently, farmers who
grew those crops— particularly wheat, barley, and oat— became accustomed to free or low-cost
access to seed, and some farmers may consider open access to seeds a right.
In the case of GE seed, however, companies can make use of patent protection to enforce
contracts that disallow reuse of the seed grown in farmers’ fields. Farmers must instead purchase
seed from firms to reward their research investment and effort. The patents enable the private
sector to set prices for the protected technology and to restrict the flow of knowledge. The
private sector had already begun to invest more in seed technology for major crops such as corn
in the 1930s and soybean in the 1970s. Because of the difficulty and expense of removing lint
from the seed, cotton farmers had traditionally purchased their seed from ginners and seed
distributors. Consequently, the introduction of GE seeds by the private sector and the patented
nature of the technology in the case of commercially available com, soybean, and cotton may not
have appeared to be strikingly different from the established relationship between seed
companies and farmers of those commodities.
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However, the deveiopmenta! trajectory of GE-seed technology is leading to concern that
access to seeds without GE traits or to seeds that have only the specific GE traits of particular
interest to farmers may become increasingly limited. Additional concerns are being raised about
the lack of farmer input and knowledge regarding which seed traits might be developed. The
push to develop seed varieties with a series of stacked traits, some of which may not be of use to
some farmers with respect to short-term productivity (leaving aside the issue of improved
resistance management discussed in Chapter 2), raises the issue of access to seeds that have
equivalent yield potential but only the desired GE traits or no GE traits at all. Although the
committee was not able to find published research that documents the degree of U.S. farmers’
access to and the quality of non-GE seed, testimony provided to the committee suggested that
access to non-GE or nonstacked seed could become limited for some farmers and that available
non-GE or nonstacked seed may not have the same yield characteristics as GE cultivars (Hill,
personal communication). Research is needed to investigate the extent to which U.S. farmers are
having difficulty purchasing high-yielding, non-GE seed. Public-sector institutions could address
this concern by improving the design of licensing contracts with seed companies so that property
rights of privately developed traits or cultivars will revert to university research programs if
private companies do not use the technologies.
Boejije (1999) has suggested that U.S. agriculture is going through a structural change in
which activities that will enhance product differentiation and added value to farming are being
emphasized. As part of that evolution, many agricultural sectors (poultry, swine, and some fruits
and vegetables) have come to be dominated by contracting arrangements between major
agribusiness companies and farmers or by large vertically integrated agribusiness firms. Those
large companies have the resources and scale to finance research in the development of GE traits.
The emergence of alliances between biotechnology companies and large agribusiness firms, and
even large farmers’ cooperatives to produce proprietary GE varieties, appears possible, but future
research is needed to determine whether such relationships can lead to the development of
differentiated products (Boehlje, 1999)— including those with traits that enhance direct value to
consumers, such as improving health or convenience, or that respond to the environmental and
management needs of specific groups of farmers — and whether such relationships will limit
farmers’ access to the types of GE traits they value.
INTERACTIONS OF LEGAL AND SOCIAL ISSUES SURROUNDING GENETIC
ENGINEERING
Legal issues constitute an important sociopolitical dimension that influences the adoption of
genetic-engineering technology ^d its impacts on farmers and communities. The legal issues are
complex, and a complete treatment of them is beyond the expertise of any of the authors of this
report. We briefly touch here on the issues of seed saving, gene flow, and organic standards.
Seed Biotechnology
Courts in the United States and Canada have consistently upheld the rights of companies that
sell patented seeds and genes through technology-use agreements to prohibit seed-saving
practices that involve seed sold through those contracts (Kershen, 2004; Anonymous, 2008).
Although that property right has been established, some continue to express concern about the
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ethical issues surrounding the patenting of life forms and over the effects of technology-use
agreements on seed-saving practices. Research on whether those concerns are warranted and
what the impacts are on farm sustainability are needed. Concerns are also being raised about the
lack of farmer involvement in GE-trait development for traits that could address production
problems identified by farmers and over the implications of current patenting procedures on
power relationships between biotechnology firms and farmers (Phillipson, 2001). However, the
social and economic effects of the exercise of such property rights, especially actual or potential
litigation on both adopters and nonadopters of GE crops, have not been thoroughly investigated
by social scientists. The lack of academic analyses of those issues may be due in part to the fact
that companies, in any sector, that use the courts to enforce their property rights view legal
actions and any out-of-court settlements as proprietary information. One interesting response by
those who are concerned about the possible effects of the private control of genetic resources has
been the open-source breeding movement.^
Gene Flow
A second set of legal issues related to genetic-engineering technology has to do with gene
flow, particularly from fields of GE crops to those managed by people not using GE crops (for
more on the potential for gene flow between GE and non-GE crops and on the challenges of
coexistence of GE and non-GE crops, see Chapter 2). As in cases that involve restrictions on
farmers against seed saving, these issues can be viewed as property-rights issues. Does gene flow
impinge on the rights of producers and consumers who wish to grow and eat foods that do not
include GE material (Conner, 2003)? That is of particular concern to some farmers who wish to
produce organic or non-GE crops. Even though organic certification by the U.S. government is
determined by the process used to grow the crop some farmers are concerned that their products
may not be accepted by markets in other countries or by food distributors and consumers who
establish their own standards, irrespective of process.
Several lawsuits have been filed by farmers against agricultural-biotechnology companies in
part because of damage alleged to have occurred as a result of drift of genetic material to the
fields of farmers who do not wish to grow crops with GE traits (Kershen, 2004). Consumer
groups have also brought legal action against the federal government for approving the
commercialization of GE crops that have the potential to cross with non-GE crops in the same
vicinity. As was discussed in previous chapters, GE alfalfa was pulled from the market after a
U.S. federal judge sided with arguments brought forward by numerous plaintiffs and found that
USDA should have prepared an environmental impact statement before it deregulated the crop
that facilitates commercialization {Geertson Farms Inc., 2009). In another case filed by the
Center for Food Safety and other plaintiffs, a federal judge decided in September 2009 that
similar steps should have been taken before GE sugar beet was commercialized (Pollack, 2009).
Issues raised by the possibility of gene flow are not only legal in nature. As noted in Chapters
2 and 3, the adventitious presence of GE material In non-GE crops raises complex environmental
and economic challenges. Similarly, social problems could arise as a consequence of gene flow,
This movement, which has been inspired in part by open-source project movements in computer software
and elsewhere, is in essence an attempt to develop publicly available genetic resources. As in the case of
“shareware,” researchers working on open-source biotechnology can access and improve on publicly available
genetic resources and technologies but must agree to make the improved materials available for others to use
(Delmer, 2005; Lemer and Tirole, 2005).
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particularly if GE and non-GE producer of the same commodity live in the same community.
Gene-flow disputes could move beyond the merely legal and affect the overall functioning of
communities where such disputes exist. TTiis might include conflicts between farmers as well as
stress related to the economic and social costs associated with lawsuits and the potential threat of
lawsuits. Studies of the social effects of such disputes are needed to gauge the full impact on
community well-being. The ability of GE production and non-GE production to coexist in
society may depend on the health of communities. Proposals for establishing “landscape clubs”
(Furtan et a!., 2007) and voluntary “GMO-free zones’’^ (Jank et al., 2006) clearly depend on the
existence of high levels of community cooperation, which could be undermined by disputes
related to gene flow.
Organic Laws and Resistance to Genetic Engineering
One of the intriguing public debates that has emerged around genetic engineering in
agriculture has been that regarding whether GE crops should be allowable in legal standards for
organic agriculture. As discussed in Chapter 1, many organic growers have vehemently resisted
the notion that GE crops should be allowable in organic agricultural production systems.
However, scientific arguments can be made for the use of genetic-engineering technology for
making organic agricultural production more sustainable. Ronald and Adamchak (2008) note that
what is or is not an appropriate use of genetic-engineering technology for “organic” producers is
problematic given that genetic-engineering techniques can be used to transfer genes within plant
species as easily as between them. Genetic-engineering techniques also include the use of
marker-assisted breeding wherein the genetic “fingerprint” of plants can be used to aid
conventional plant breeding. These authors also note the potential for genetic-engineering
technology to develop new varieties of crops that could be grown under conditions that reduce
some of the adverse environmental Impacts of growing food and that contribute to local food
production. The rationale parallels the arguments used in discussing the potential of genetic-
engineering technology for improving the productive capability of orphan crops in developing
countries (Naylor et al., 2004).
The ideological divisions between those who favor and those who oppose the use of GE
plants in organic production systems are complex, and in many cases concerns about safety and
naturalness are connected to and mask socioeconomic concerns. An example of the complexity
was the successftil vote In Mendocino County, California, in 2004 to ban the local use of GE
organisms in agriculture. The legal focus of the vote was on GE organisms, but it was clear,
because of how genetic-engineering technology was linked to issues related to corporate versus
local control of agriculture, that the technology was viewed by many of those supporting the
measure as a social problem (Walsh-Dilley, 2009). Similarly, some genetic-engineering
proponents argue for including GE products in organic standards and labels at the same time that
they argue against the labeling of foods with GE content because they consider GE and non-GE
foods to be substantially equivalent products (Klintman, 2002). That position can be understood,
in part, as a desire to obtain the economic benefit of some labels while avoiding the cost of being
associated with other labels. Those examples underscore the important socioeconomic and
group of growers concerned about the organic purity of an open-pollinated field crop may come together
to fonn a “landscape club”, a fee-based organization designed to increase their economic welfare by providing
protection against contamination through gene flow from related GE crops. A a)ne free from genetically modified
organism (GMO-free) would provide similar protection (Jank et al., 2006)
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sociopolitical dimensions in public debates about genetic-engineering technology. To reconcile
those debates over the potential use of genetic engineering in sustainable and developing-country
agriculture, it may be wise to heed the suggestion of Ronald and Adamchak (2008) and use
various social, environmental, and economic criteria in making decisions on when to use and not
to use genetic-engineering technology in agriculture.
CONCLUSIONS
Social dynamics and networks between farmers and within local communities play a
substantial role in the decisions that fanners make with respect to the use of GE crops and likely
are impacted by the use of and conflicte over those crops. Research on the adoption of other
agricultural technologies has demonstrated substantial social impacts on a farm level and a
community level. Those impacts include, but are not limited to: decreases to and change of
composition in the agricultural labor force; better on-farm working conditions; changes in farm
and agricultural-industry structure; increases in capitol requirements for farmers; and a decline in
the socioeconomic viability of some rural communities. Comparable research on the effects of
GE crops is lacking, and although it is reasonable to hypothesize that the social impacts of the
spread of GE crops have been low due to the assumed scale neutrality of this technology, it is
equally reasonable to assume that the social impacts have been numerous and profound. Those
questions cannot be answered without short- and long-term empirical research on the social
processes surrounding, and the social impacts associated with, the adoption of genetic-
engineering technologies at the farm level. Such research must take into account the various
contextual factors that are influencing social changes on U.S. farms and rural communities.
Research has demonstrated that farmers’ interest in genetic-engineering technology and
patterns of adoption are influenced by farmers’ social networks and by farmers’ associations,
private firms, and public actors, including universities. Research also has identified the
continuing consolidation of the seed industry and its integration with the chemical industry. The
market power of firms that supply seed has not adversely affected farmers’ economic welfare so
far, but research is needed on how market structure may affect ongoing access to non-GE or
single-trait seeds and future seed prices. Furthermore, there has been comparatively little
research on how changes in farmer social networks and seed-industry concentration might be
affecting farmers’ planting decisions and options, overall yield benefits, crop genetic diversity,
and economic returns.
A final set of social issues has to do with complex legal issues, including the adoption of and
the use of genetic-engineering technology. U.S. and Canadian courts have also upheld the legal
rights of seed companies to prohibit seed-saving practices through the use of contracts. The issue
of gene flow is complicated. One important question being raised is whether adventitious
presence of genetic material from GE crops into non-GE crops impinges on the rights of
producers, including organic producers, who do not wish to use specific GE traits. The legal
debates may mask deeper social and ideological divisions over the use of GE plants and how to
define and implement sustainable agricultural practices.
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Key Findings, Remaining Challenges, and Future Opportunities
The first generation of genetically engineered (GE) crops has mostly delivered effective pest
control for a few major crops because farmers producing these crops spend a lot of time and
money on the task, because the firms developing the new seed technologies saw considerable
profit potential in doing so, and because adding the traits was relatively straightforward,
requiring transformation of a genome at only a single location. The first generation of GE crops
continues a reliance on pesticide technology — in-plant toxins or resistance to herbicides — ^to
mitigate pest problems primarily in com, cotton, and soybean. Thus, the application of genetic-
engineering technology to crops has not developed novel means of pest control, such as
developing plant mechanisms to resist pest damage, nor has it reached most minor crops.
The next set of challenges for the application of GE-crop technology is to expand to
additional crops and to address additional desirable traits, such as drought tolerance, enhanced
fertilizer utilization to reduce nutrient runoff, nutritional benefits, renewable energy production,
and carbon sequestration. A number of those applications are under development by the private
sector, some by the public sector. Clearly, the future agenda for genetic-engineering technology
is extensive and of great importance for improvements in agricultural productivity and
sustainability in a rapidly-changing world.
This chapter opens by summarizing the major findings of our assessment of the farm-level
environmental, economic, and social impacts of GE crops. We then identify key remaining
challenges that will frame future development and commercialization of genetic-engineering
technology in crops. The discussion turns next to the future agenda of GE-crop applications,
including general patterns of crop-trait development, implications for future weed-resistance
management, and the potential role of GE crops for biofuels. The penultimate section highlights
two subjects of research that the committee believes deserve more resources and effort: water
quality and social impacts of GE crops. In closing, we discuss options for strengthening public
and private research and development to exploit the potential of genetic-engineering technology
to contribute more fully to environmental, economic, and social objectives.
KEY FINDINGS
The evidence shows that the planting of GE crops has largely resulted in less adverse or
equivalent effects on the farm environment compared with the conventional non-GE systems that
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GE crops replaced, A key improvement has been the change to pesticide regimens that apply less
pesticide or that use pesticides with lower toxicity to the environment but that have more
consistent efficacy than conventional pesticide regimens used on non-GE versions of the crops.
In the first phase of use, herbicide-resistant (HR) crops have been associated with an increased
use of conservation tillage, in particular no-till methods, that can improve water quality and
enhance some soil-quality characteristics. That farmers who practice conservation tillage are
more likely to adopt GE crops suggests the two technologies are complementary.
At least one potential environmental risk associated with the first phase of GE crops has
surfaced: some adopters of GE crops rely heavily on a single pesticide to control targeted pests,
and this leads to a buildup of pest resistance regardless of whether GE crops or non-GE crops are
involved. The governmental regulation of GE Bt crops through refuge requirements seems to
have proved effective in delaying buildup of insect resistance with two reported exceptions,
which have not had major consequences in the United States. Grower decisions to use repeated
applications of particular herbicides to some HR crops have led, in some documented cases, to
evolved herbicide-resistance problems and shifts in the weed community. In contrast with Bt-
crop refuge requirements, no public or private mechanisms for delaying weed resistance have
been extensively implemented. If the herbicide-resistance problem is not addressed soon, farmers
may increasingly return to herbicides that were used before the adoption of HR crops. Tillage
could increase as a pest-management tactic as well. Such actions could limit some of the
environmental and personal safety gains associated with the use of HR crops. The newest HR
varieties likely will have tolerance to more than one herbicide, and this would allow easier
herbicide rotation or mixing, and, in theory, help to improve the durability of herbicide
effectiveness. These new stacked varieties will be one more tool to help manage the evolution of
weed as well as insect resistance.
The potential for gene flow via cross-pollination between current major GE crops and wild or
weedy relatives is limited to cotton in small spatial scales in the United States because the other
major GE crops have no native relatives. How this changes in the future will depend on what GE
crops are commercialized, whether related species with which they are capable of interbreeding
are present, and the consequences of such interbreeding for weed management. Gene flow (i.e.,
the adventitious presence) of legal GE traits in non-GE crops and derived products remains a
serious concern for farmers whose market access depends on adhering to strict non-GE
standards. It would appear that the resolution of the issue may require the establishment of
enforceable thresholds for the presence of GE material in non-GE crops that do not impose
excessive costs on growers and the marketing system.
The literature reviewed in this report indicates that a majority of U.S. farmers who grow
soybean, com, or cotton have generally found GE varieties with herbicide-resistance and insect-
resistance traits advantageous because of their superior efficacy in pest control; their concomitant
economic, environmental, and presumed personal health advantages; or their convenience. The
extent of the benefits varies among locations, crops, and specific genetic-engineering
technologies.
After some early evidence of yield disadvantages for some GE varieties in the United States,
studies have now shown either a moderate boost in yields of some crops or a neutral yield effect.
Some emerging evidence suggests that the attractiveness of the genetic-engineering technology
for soybean, cotton, and com has increased the global acreage planted to these crops over what
would have been planted otherwise and thereby increased global commodity supplies (World
Bank, 2007; Brookes and Barfoot, 2009). Consequently, the adoption of some of the GE crops
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around the world has put downward pressure on the prices received by U.S. farmers who are
growing these crops, holding other factors constant. At the same time, livestock producers and
consumers who purchase GE feed and food products may have benefited from the downward
price pressure. However, the U.S. and world agricultural economies have been influenced by
other factors that tend to increase conmiodity prices, making empirical verification of the effects
difficult.
The economic effects of GE-crop adoption on nonadopters are mixed. To the extent that the
use of genetic-engineering technology changes the types and amounts of inputs used, adopters of
GE crops can influence the pesticide market. Changes in the price and availability of pesticides
affect nonadopters as well. Farmers of non-GE crops in the vicinity of GE-crop farms may
experience landscape-level effects from reduced pressure from pests targeted by GE traits.
Marketing of non-GE crops may also be affected by GE crops, favorably or unfavorably. For
example, products derived GE and non-GE crops can mix through gene flow or supply
contamination. On the other hand, GE crops may create a market premium for non-GE products.
The historic social repercussions of introducing new technologies in agriculture, such as
mechanization and the widespread planting of hybrid com, have been studied extensively, and
the results of the studies provide a basis for understanding the general effects of introducing GE
varieties of crops. Despite the salience of those effects, however, there has been little
investigation of farm-level and community-level social impacts of GE crops. The new seed
technologies raise important potential social issues about farm stmcture, the input and seed
choices available to farmers, and the genetic diversity of seeds. Among the known social facts
associated with the dissemination of GE crops are the continued consolidation of the seed
industry and its integration with the chemical industry. Another is the change in relationships
between farmers and their seed suppliers. Testimony to the committee suggested that farmers of
major crops have fewer opportunities to purchase non-GE seed of the best-yielding cultivars
even when a GE trait is not perceived to be required in a particular cropping situation. As
genetic-engineering technology matures and moves into its next phase, it is imperative that the
full array of social issues involved be identified and investigated in depth.
REMAINING CHALLENGES FACING GENETICALLY ENGINEERED CROPS
Potential crop-biotechnology developments stir discussion around five issues. The treatment
and resolution of those issues hold implications for long-term sustainability for farmers,
including both adopters and nonadopters of GE crops.
First, the success of genetic-engineering technology in the United States has altered the seed
industry by spurring consolidation of finns and integration with the chemical industry. Those
developments continue to alter seed and pest-control options in the market, expanding pest-
control options for some farmers and possibly limiting them for others, including those who do
not grow GE crops. The resulting concentrated and legally enforceable private control of plant
genetic material contrasts sharply with public plant-breeding programs that traditionally have
fostered public access to discoveries, especially if GE varieties are developed for crops from
which farmers have traditionally saved seed for the next year’s crop (such as wheat, barley, and
oat). Although corporate consolidation may offer greater economies of scale, it also is
accompanied by the possibility of less competition and higher seed expenses, which may lower
farmer returns, reduce pest-control options, and limit the benefits of commercialization of
genetic-engineering technology to a few widely grown crops. There is not yet clear evidence of a
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these
trends should be monitored, and their effects ameliorated to remedy social losses that result.
Second, how the intensive use of cuirent and prospective GE organisms will directly affect
the natural environment differently from other agricultural production systems is incompletely
understood (Ervin el ah, 2003). Relatively few studies have provided integrated assessments of
the indirect effects of GE crops on pest damage to non-GE crops and on the full suite of
ecosystem services on the landscape scale. For example, the concurrent effects on regional water
quality of shifting tillage and pesticide regimens with the introduction of GE crops on regional
water quality conditions remain poorly documented and understood. Knowledge of the spatial
and temporal effects on ecological health — favorable or unfavorable — assumes greater
importance as the evolution of herbicide resistance in weeds alters patterns of herbicide use to
make up for the loss of glyphosate’s efficacy on some species, and as novel GE plants, such as
those for energy and nonfood uses, approach commercialization. Evaluation and monitoring of
the ecological health of soils, water quality and quantity, and air quality will provide the
information needed for developing the most productive yet sustainable agricultural systems for
the future (Ervin et ah, 2003).
Third, progress in developing GE varieties for most “minor” crops (e.g., fruits and
vegetables) and for other “public goods” purposes not served well by private markets has been
slow. Minor crops play important roles in the agricultural sectors of many states. Some minor
crops, such as sunflowers and grain sorghum, have been considered to be poor candidates for the
HR traits because of the existence of near-relative weeds (grain sorghum) or native ancestral
populations (sunflowers). However, that risk does not explain the relative dearth of research and
development (R&D) on GE varieties of minor crops as a whole, especially fruits and vegetables.
The high fixed investment, patent protection involving GE traits, and the regulatory expense of
commercializing GE seeds have lessened the ability of small companies and public-sector crop-
breeding programs to develop commercially viable GE varieties of most minor crops. It seems
clear that more effort should be devoted to the enhancement of minor crops with the best
available genetic-engineering techniques even though the commercial rewards per crop may be
small. Private and public R&D programs for GE crops have not yet led to the commercialization
of many additional plant traits, such as improved tolerance to drought and increased fertilizer-use
efficiency that decreases nutrient runoff, a contributor to nonpoint-source water pollution. This is
not to suggest that GE seeds represent a “silver bullet” technology to solve all of these problems.
Such GE trait developments may or may not turn out to be the most cost-effective approach to
solving these issues, but exploration is necessary to evaluate their relative efficacy. Even though
the basic technology is over 20 years old, agricultural biotechnology in some regards is still in its
infancy. The rate of progress of genetic-engineering technology for some purposes suggests that
more time and resources and new institutional relationships, such as public-private R&D
collaborations, are desirable for the technology to reach its potential. Traits that have not yet
received much attention, such as improved nutrient absorption and enhanced food value of crops,
should be emphasized in the future so that wc can gain the knowledge needed for weighing how
the advances of genetic-engineering technology could present options for addressing all aspects
of food supply, energy security, and environmental challenges.
Fourth, the presence of transgenic material in non-GE products should be addressed. The
current definition of organic food in the United States excludes the use of GE materials in
production and handling processes, so organic farmers must take steps to ensure that their
production methods do not expose their crops to GE traits. To avail themselves of market
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premiums for certified organic crops, they must incur costs for keeping their products separate
from GE crops. Food producers who market products as non-GE face similar challenges to
prevent co-mingling of GE and non-GE crops during storage and distribution. In those ways, the
introduction of GE crops influences the decisions and operations of farmers and food producers
who do not use the technology.
Fifth, U.S. farmers who grow GE crops may face market restrictions from some countries or
retail firms on the importation or sale of the crops or products made from the crops. Under some
international agreements, some countries impose these restrictions because of perceived food
safety or environmental risks or for other reasons. Assuming that those actions satisfy
international treaty rules, such market-access restrictions to some extent slow the development of
a global market for GE crops. One effect of the trade restrictions has been to limit the market
demand for GE crops.
The potential of GE crop varieties to address the world’s emerging food-supply, energy, and
environmental problems hinges on how those challenges are resolved. Success in resolving them
may allow genetic-engineering technology to become even more transformational in fostering
sustainable agricultural systems for farmers. This important agenda frames the discussion of
future GE-crop applications.
FUTURE APPLICATIONS OF GENETICALLY ENGINEERED CROPS
In addition to expanding existing GE traits into other crops, the reach of genetic-engineering
technology could be extended through the development and commercialization of new traits.
Traits beyond those designed to control pests could have substantial benefits in fields other than
agriculture, such as food and energy security. This section summarizes the present pattern of
R&D of novel GE traits in the private and public sectors and highlights areas in which new traits
could be especially useful to improving agricultural sustainability.
Patterns of Genetically Engineered Products in Development
The GE crops now being planted by U.S. farmers were developed over long gestation
periods. Given that fact, the current portfolio of GE crops does not wholly capture the range of
new crops being readied for commercialization that could cover the U.S. farm and global
landscape in the future. For instance, companies are developing crops with more intricate pest
control mechanisms (see Box 5-1), but they are also engineering traits that improve crop
tolerance to stress or that provide benefits directly to consumers. Recent research also indicates
that novel forms of pest control may be part of the next generation of GE crops. As an example,
Baum et al. (2007) report positive laboratory findings that ribonucleic-acid (RNA) interference
technology, a plant-based method for pest management, results in larval stunting and mortality in
several coleopteran species controlled by Bt crops. Predicting future crop biotechnologies is
somewhat difficult because companies, for reasons of competitiveness and patent protection,
may not fully share the specifics of planned releases. However, three recent global surveys of
product-quality innovations in the development phase of genetic-engineering technology help in
discerning general trends in GE-crop development and, in particular, why quality-improving
innovations from genetic-engineering technology have not yet been more numerous (Graff et al.,
2009).
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N<Vf TmiN Reduce Refu{}e
of H«
^or coTimefcialization’ erf
and Introdot s
(EPA) announced fina! aupts'v
hybnds produce multiple o.-ote "
for the control of Jepidopte^ pekft' of com rootworm (tvt-o of t”
pfoteins must be used to^eS^r Jp mortality) The hyb-'ds a’;/i
have transgenes conferring rsetsian^ td^^^^E^^^^i^'gfeifostnate. Because of U'.e mu'tipie-''
toxins affecting single pests, this approved by EPA with a roTuqe
roquirsment of 5 nercent in tt«& Com the, Cotton BeH {U?-ppa POOP*
Those refuge requirements fedufOd tf^;<M^iharrequwements of 20 percent ip tne
Corn Belt and 50 percent 'n the Cott0n;.'B^ fpVl^reviOpS fa-ansgenic Bt cc.p >*' J,
Resistance to the different t«t)ad-sp4:irum h%r^te!^^q 1 asrhelp in delaying the evoluhcr' of
resistance thvveeds in ateasvrtiefeg^rphosa^-fe^taBii^ujations have not been icc’ ‘ S'l
However giowers must assume appropriate sts^VdSh^ ^ these herbicides n ivm-
manage tne future evolution of herbicfbe-resistaDlw^ popufeifio^is
The combined findings of the surveys show that jess tiian 5 percent of the innovations reach
the regulatory and commercialization phases. As might be expected, R&D activity has been
uneven among different trait categories because of variation in the difficulty of achieving
selected transformations and in the economic value of the traits. For example, traits governing
content and composition of macronutrients — proteins, oils, and carbohydrates — and traits that
control fruit ripening have more readily reached later stages of R&D, and few products with
enhanced micronutrients, functional food components, or novel esthetics have approached
commercialization (Graff et al., 2009). The analysts concluded that product-quality innovation
appears more responsive to demand in intermediate markets for processing and feed attributes
than to demand in retail markets for improved or novel products. They also noted that many of
the observed traits offer potential efficiency gains in agriculture and improvements in natural-
resource systems and a potential to reduce environmental impacts both because they will
decrease input requirements and because they will reduce adverse externalities of crop
production, processing, or consumption. For example, new traits may increase the efficiency of
livestock-feed digestibility and by so doing increase the value of the feed to farmers. Traits that
improve nitrogen-use efficiency that are on the horizon will bring value to farmers and could
contribute to reducing agriculture’s effects on water quality. The potential for environmental
improvement from such traits depends on the degree to which they Improve input-use efficiency
and the extent to which farmers expand production because of lower unit costs.
The rate of product-quality innovations in genetic-engineering technology identified in the
surveys decreased considerably after 1998. The authors noted that the cause of the decline
remains conjectural. It coincided with the decrease in the number of transgenic field trials
conducted in the United States and Europe, with the exit from the market of a number of small
biotechnology companies that were not deeply involved in the first generation of GE pest-control
crops, and with changes in the regulatory environment in Europe that restricted the introduction
of GE varieties there.
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Data on field tests of crop-biotechnology innovations corroborate the slowdown. A critical
part of new variety development is field testing to ensure that the desired traits will perform
under commercial production conditions and that no important environmental risks are
associated with release of a GE organism. The release of new GE varieties or organisms into the
environment is regulated, in part, through field-release permits monitored by the U.S.
Department of Agriculture (USDA) Animal and Plant Health Inspection Service (APHIS)
(Fernandez-Comejo and Caswell, 2006).* The overall number of field releases of plant varieties
for testing purposes is a useful indicator of R&D efforts in GE crops. By the end of 2008, about
15,000 applications had been received by APHIS since 1987, and nearly 14,000 (93 percent) had
been approved (I SB and DSDA-APHIS, 2009). Annual applications peaked in 1998 with 1,206,
and annual approvals peaked in 2002 with 1,141 (Figure 5-1). Most applications approved for
field testing in 1987-2008 involved major crops, particularly com with 6,648 applications
approved, followed by soybeans (1,554), cotton (912), potato (817), tomato (637), wheat (413),
alfalfa (385), and tobacco (363). Applications approved during this time included GE varieties
with herbicide resistance (25.1 percent), insect resistance (20.1 percent), improved product
quality (flavor, appearance, or nutrition) (18.2 percent), and agronomic properties, such as
drought resistance (13.4 percent) (Figure 5-2).
After sufficient field testing, an applicant may petition APHIS for a determination of
“nonregulated” status to facilitate commercialization of a product. If, after extensive review,
APHIS determines that unconfined release does not pose a substantial risk to agriculture or the
environment, the organism is “deregulated” and can be moved and planted without APHIS
authorization (Fernandez-Comejo and Caswell, 2006). Petitions for deregulated varieties peaked
in 1995-1997 with 14-15 petitions per year and have been below 10 petitions every year
thereafter (ISB and USDA-APHIS, 2009). As of June 5, 2009, APHIS had received 119
petitions for deregulation and had approved 76. The deregulated varieties had HR traits (38
percent), IR traits (28 percent), product-quality traits (15 percent), virus-resistance traits (11
percent), and agronomic traits (6 percent) (ISB and USDA-APHIS, 2009).
'if a plant Is engineered to produce a substance that “prevents, destroys, repels, or mitigates a pest”, it is
considered to be a pesticide and is subject to regulation by the Environmental Protection Agency (Fernandez-
Comejo and Caswell, 2006). Thus, all Bt oops are included.
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1200
1987 1989 1991 1993 1995 1997 1999 2001 2003 2005 2007
FIGURE 5-1 Number of permits for release of genetically engineered varieties approved by
APHIS.
SOURCE: ISB and USDA-APHIS, 2009.
□ Herbicide Resistance
B Insect Resistance
Q Product Quality
a Agronomic Properties
□ Virus Resistance
3 Marker Gene
□ Bacterial Resistance
a Fungal Resistance
B Nematode Resistance
□ Other
FIGURE 5-2 Approved field releases of plant varieties for testing purposes by trait (percent).
SOURCE: ISB and USDA-APHIS, 2009.
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Another study of the APHIS GE-crop release data investigated the private or commerciai and
public-goods aspects of traits being tested (Welsh and Glenna, 2006). The authors analyzed
releases in 1 993-2002 to answer two research questions (p. 936);
• “I'o what extent have universities mimicked the for-profit sector in agricultural
biotechnology by focusing their transgenic research on a relatively few proven genotypes
(traits)?”
• “To what extent have univereities mimicked the for-profit sector in agricultural
biotechnology by focusing their transgenic research on the relatively few major
(commercially dominant) agronomic crops?” (Welsh and Glenna, 2006, p. 936)
They categorized the crop releases into major traits — herbicide resistance, insect resistance,
and product quality — and “oAer” GE traits. Product quality includes the alteration of a particular
crop’s characteristics to make it more valuable to food, feed, or energy manufacturing firms,
such as a higher lysine concentration in com Uiat would be useful to livestock producers. Other
GE traits were nematode resistance, fungus resistance, bacterium resistance, virus resistance, and
agronomic properties (such as yield). They also categorized the releases by whether they were
major crops (soybean, com, wheat, alfalfa, and cotton) or minor crops (such as other field crops,
vegetables, and fmits planted on smaller acreages).
The results Indicated that the research profiles of universities in 1993-2002 were less
dominated by the major traits than were the profiles of for-profit firms. A similar pattern
emerged for major crops: about 71 percent of notices filed with APHIS by for-profit firms
entailed research on major crops compared with 32.6 percent filed by universities. Moreover,
work on minor crops differed among universities depending on their region (for example, apples
in the Northeast and citrus in the Southeast). The authors examined whether the relationships
changed during three periods: 1993-1995, 1996-1998, and 1999--2002. The research profiles of
the for-profit firms remained fairly uniform, but universities looked more like for-profit firms in
the later periods. That trend was especially pronounced for major traits; almost 73 percent of
notices filed by universities entailed at least one major trait in 1999-2002 compared with around
35 percent in earlier periods. The proportion of research on major crops by universities also
increased.
To probe those relationships in more depth, Welsh and Glenna constructed a commercial
index for each release. The index was computed by assigning scores of 1 for research on a major
crop and 1 for research on a major trait. Research on a minor crop was scored as -1 and research
on a minor trait was scored as -1. Possible index values were therefore 2, 1, 0, -1, and -2. A
higher index value indicated greater research emphasis on more commercially relevant crops and
traits, and a lower value indicated more emphasis on crops and traits with smaller markets.
Plotting the value of the index for universities and private-sector firms over time revealed that
universities and private-sector firms showed increasingly similar research trajectories, which
emphasized major crops and major traits in genetic-engineering technology. The time-series
relationship was also found to be statistically significant (Welsh and Glenna, 2006).
Results of those three studies of GE-trait developments indicated that some GE products in
various phases of development serve purposes other than pest-control traits dominant today, but
they have not been commercialized. The reasons for this vary with the crop and the trait, but
include a small anticipated market, lack of access to technology, uncertainty about consumer
acceptance, potential spillover to weedy relatives or gene transfer to non-GE cultivars, and high
regulatory costs. During the process of innovation, commercialization, and adoption, all
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organizations weigh the costs and benefits of their decisions (Bradford et a!., 2006). It is not
surprising that the GE crops that were commercialized first provided substantial net benefits to
the innovators, the seed companies, and adopting fanners.
Implications of Genetically Engineered Crops for Weed Management
An unmet challenge for GE crops documented in Chapter 2 revolves around sustaining the
efficacy of particular herbicides. Maintaining dieir efficacy holds important implications for
future farm economics and environmental sustainability. A key concept in understanding
herbicide-resistance effects in weeds is the open, unregulated access of all farmers to the
common pool of pest susceptibility. The presence of this condition leads to individual decisions
that may impose user costs on the whole population of farmers, to suboptimal overall
management, and to increasing total social costs (Hardin, 1968).
The data show that GE-crop cultivars resistant to glyphosate dominate in the com, soybean,
and cotton production regions across the United States. Results of a six-state sur\'ey to assess
crop rotations by growers of GE crops showed that rotation of a GE crop with a non-GE crop
was most commonly followed by rotation of a GE crop with a GE crop (Shaw et al., 2009).
Rotation of a GE with a non-GE crop was more common in the Midwest than in the South. With
the high acreage of glyphosate-resistant crops being planted, substantial changes in herbicide use
occurred; notably, fewer herbicides were used (Young, 2006); the most common current
herbicide tactic reported is one to three applications of glyphosate (Givens et al., 2009). A related
change in production practice attributable to the adoption of HR crops that has implications for
weed management was the increased adoption of conservation tillage (Givens et al., 2009). The
overall grower assessment of the effect of HR crops on weed population densities was that there
were fewer weeds because of the use of glyphosate on HR crops (Kruger et aL, 2009). Few
growers felt that weed populations would shift to species that had evolved resistance to
glyphosate, understood the importance of alternative tactics to control weeds, or perceived the
role of selection pressure caused by the use of glyphosate on HR crops (Johnson et al., 2009).
Given that changes in weed communities in response to production practices have been a
consistent problem in agriculture, future weed challenges are likely to increase quickly (Baker,
1991; Owen, 2001; Heard et al., 2003b; Heard et ah, 2003a). To summarize, growers valued the
immediate benefits of weed control without appreciating the long-term risks attributable to the
tactics they used. That behavioral response might be expected given many farmers’ desire to
meet short-run financial needs and the fact that other growers may not take similar control
actions.
Recent survey data show that growers emphasize the convenience and simplicity of the
glyphosate-based cropping systems while discounting the importance of diversification of weed-
management practices (Owen, 2008b). That prevailing attitude has several likely results: given
growers’ apparent unfamiliarity with or lack of concern about the implications of selection
pressure for weed communities, weed shifts are inevitable; and growers’ short-term interest in
killing weeds rather than managing them will result in the loss of crop yield and farm profits in
the long run unless innovation in weed-control technology occurs. The efficacy of glyphosate on
a broad spectrum of weeds, its ability to kill larger weeds, and the fact that glyphosate can be
applied to HR crops almost regardless of crop stage of grovrth all reinforce growers’ perception
of the simplicity and convenience of glyphosate-based programs.
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Weed management implies that there is a critical period of weed control (CPWC) when weed
interference must be eliminated to protect crop-yield potential (Nieto et al., 1968; Kasasian and
Seeyave, 1969; Swanton and Weise, 1991; Knezevic et al., 2002; Knezevic et al, 2003). The
CPWC is the same whether the crop is GE or non-GE. There is considerable information about
the proper timing of glyphosate applications that will provide protection of yield potential and
the related economic loss of crop yield in response to untimely glyphosate application (Gower et
al, 2003; Dailey et al, 2004; Cox et al, 2005; Cox et al, 2006; Stahl, 2007). Many growers may
recognize the relationship between early weed interference with HR crops and the resulting
economic loss to profitability or may face high individual cost or risk in changing their behavior.
The perception of success with glyphosate results in the repeated use of this herbicide without
consideration of alternative strategies. Recurrent application of any herbicide will cause shifts in
the weed community that support the evolving dominance of weeds that are not susceptible.
Growers must use diversified weed-management practices, recognize the importance of
understanding the biology of the cropping system, and give appropriate consideration to more
sustainable weed-management programs (Knezevic et al, 2003; Owen and Zelaya, 2005; Owen,
2008a). Furthermore, unless growers collectively adopt more diverse weed-management
practices, individual farmer’s actions will fail to delay herbicide resistance to glyphosate because
the resistant genes in weeds easily cross farm boundaries. Some form of private or public
collective action may avert this classic management of the commons problem in which
individual actions to apply glyphosate have adverse spillover effects on the entire community of
farmers (Hardin, 1968). Further research that results in new HR traits and other efficient means
of weed control likely will lessen this problem.
Potential for Biofuels
Amid diminishing reserves of fossil fuels, heightened concern about climate change, and
growing demand for domestic energy production, biofuels have emerged as an important
supplementary fuel that may have considerable potential in supplying future energy needs. First-
generation biofuels are serving as fuel extenders, displacing only a small percentage of gasoline
consumption in the United Slates (Energy Information Administration, 2007). Nevertheless,
because some existing biofuel crops can be produced in a manner that reduces greenhouse-gas
emissions relative to fossil fuels and because they reduce dependence on volatile oil import
markets, governments around the world have supported production of biofuel crops with
subsidies and mandates (Kopiow, 2007). However, although, as noted, some biofuel technologies
can reduce greenhouse-gas emissions (Farrell et al, 2006), that might not always be the case,
depending on production practices (Fargione et al, 2008; Searchinger et al, 2008). Furthermore,
when they increase the demand for food crops, biofuel production can contribute to higher
prices and shortages of food like those witnessed in 2008 (Tyner and Taheripour, 2008; Sexton
et al, 2009).
In the United States, ethanol is produced principally from com, approximately 80 percent of
which is grown with GE varieties. Simil^ly, biodiesel in the United States is produced almost
entirely from soybean; about 92 percent U.S. acres in soybean produce GE varieties. If those GE
crops have increased yields, they may reduce biofuel costs.
If developed appropriately, new GE-crop technologies could play an important role in
ameliorating further the adverse economic and environmental impacts of biofuels (Sexton et al,
2009). Indeed, some governments, like that of the United States, have tailored their biofuels
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policy to include, among other instruments, some support for next-generation technologies to
overcome existing limitations (e.g., Rajagopal et al., 2007; Rajagopal and D.Zilberman, 2008).
For example, genetic-engineering technology may help to improve the agronomic characteristics
of plants used for cellulosic ethanol, which are not yet widely commercialized. Whereas ethanol
is produced today only from the starch in plants, developments in microbiology allow the
cellulosic material to be converted to biofuel. Genetic-engineering technology holds the potential
to generate higher yields of these crops and to improve the amount of liquid fuel obtainable per
plant by altering plants’ genetic code in beneficial ways. It may provide these benefits without
environmental damage. Because many of the plants that may provide fuel in the future have not
been commercially farmed, it may be possible to improve plant genetics to maximize their
energy-yield potential, minimize the costs of converting cellulosic plant material to liquid fuel,
and devise best-management practices or mitigation for the environment.
RESEARCH PRIORITIES RELATED TO GENETIC.\LLY ENGINEERED CROPS
Water-Quality Monitoring and Evaluation
Nonpoint pollution is the leading cause of water-quality impairments across the United
States, extending into ocean estuaries, bays, and gulfs (US-EPA, 2007). Agriculture remains the
largest source of these nonpoint pollution flows by volume, and much of the pollution stems
from cropland operations. The predominant contaminants include sediment from land erosion
and nutrient and pesticide residues not used or retained for growing crops. For example, a recent
analysis estimated that agriculture contributes 70 percent of the nitrogen and phosphorus that
enters the Gulf of Mexico and that com production accounts for the majority of the nitrogen and
com and soybean production account for one-fourth of the phosphorus (Alexander et al., 2008).
Particularly in view of the huge dead zone that has formed in the Gulf of Mexico, lessening such
pollution has high national priority.
As explained in Chapter 2, evidence has begun to emerge that GE crops are often associated
with changes in cropping practices that should lead to an improvement in the nation’s water
quality. The changes include shifts to conservation tillage or no-tlll techniques that leave more
residues on the cropland surface and thereby reduce water runoff that contains sediment,
nutrient, and pesticide contaminants. They also include the use of pesticides, such as glyphosate,
that are less toxic and more quickly degrading than conventional crop herbicides and
Insecticides. The latter effects could also reduce contamination of groundwater and wells on
farms from spills and mixing operations.
Because monitoring and research resources have been inadequate, those potential water-
quality impacts of GE crops have not been documented. The committee received testimony from
the U.S. Geological Survey that explained the lack of comprehensive data and analysis that could
identify and estimate the magnitude of the potential improvements in water quality (Gilliom and
Meyer, personal communication). TTtose effects are among the largest environmental effects of
agriculture, and we recommend that more resources be devoted to the important tasks of spatial
and temporal monitoring of how agricultural practices influence water quality. Monitoring
changes associated with the adoption of GE cultivars is important given that the rapid,
widespread adoption of those cultivars may have large impacts on water quality by changing
agricultural practices. The resulting information could influence the design of future
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environmental policies and agricultiire programs. Such critical intelligence would help to
improve the efficacy and cost-effectiveness of achieving regional and national water-quality
standards, and thereby improve farm sustainability.
Social Issues in the Use of Genetically Engineered Crops
Accumulated research in the social sciences has verified that the processes of technological
development and diffusion do not take place in a social vacuum. Choices made by those who
create new technologies and decisions made by others regarding whether to use the technologies
are influenced by political, economic, and sociocultural factors. The social impacts of the use of
the technologies are influenced by the same factors. A particular technology can have dissimilar
social impacts depending on the context within which it is adopted. It is reasonable to
hypothesize, on the basis of the existing body of knowledge, that the adoption of particular
genetic-engineering technologies has a variety of social, economic, and political impacts, and
that these impacts would not be the same at all times and in all regions and cultures.
As noted in Chapter 4, the amount of research on the social processes and effects associated
with the development and use of GE crops has been inadequate and has not matched what took
place previously in the cases of agricultural mechanization or even the use of bovine
somatotropin in dairy production. Thus, there is little empirical evidence to which the present
committee can point to that delineates the full array of social impacts of the adoption of GE-crop
technology. That includes a lack of research on the social impact on farmers of companies
legally enforcing their intellectual property rights in GE seeds. Research that has been conducted
on the role of industry-farmer social networks in influencing the development of new seed
technologies, legal issues related to GE-crop technology, resistance to the use of the technology
in organic production systems, and the development of the open-source breeding movement does
suggest, however, that genetic-engineering technology is socially contested by some
groups. Those findings and trends reinforce the need for research on the social processes
associated with genetic-engineering technology, including its social impacts, to inform the
decision-making processes of technology developers, farmers, and policymakers. The committee
recommends the development of this research agenda, which should lead to findings important
for addressing the sociocultural issues that will arise in connection with broader adoption of GE
crops in the future.
ADVANCING POTENTIAL BENEFITS OF GENETICALLY ENGINEERING CROPS
BY STRENGTHENING COOPERATION BETWEEN PUBLIC AND PRIVATE
RESEARCH AND DEVELOPMENT
The rapid adoption by U.S. farmers of the first generation of GE soybean, cotton, and com
varieties illustrates the speed and scope with which agricultural systems can be improved if
appropriate products and systems are available. This report documents how GE varieties
contribute to the sustainability of agriculture related to the production of those major crops.
Expanding the effects to additional crops and further improving the technology will require an
expansive program of R&D. Private companies are already working to develop additional traits
that will improve the productivity and sustainability of agriculture in the United States and
worldwide. However, both the private and public sectors must play vigorous, if often times
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different, roles if the full potential of genetic-engineering technology to foster a more sustainable
agriculture is to be realized. In developing analogous traits for other crops, such as GE varieties
of “minor'” crops and additional GE traits to meet broader public environmental and social
objectives (e.g., improved water quality and carbon sequestration), the active involvement of
universities and nongovernment institutions will be crucial given the flexibility of such
institutions in selecting research objectives when funding is available. Developing the most
appropriate agenda for such research will require extensive stakeholder involvement, including
input from adopters and nonadopters of GE crops, environmental and social interest groups, and
industry representatives.
Public investment and innovation in genetic-engineering technology includes several phases,
such as discovery, scaling-up of innovations, regulatory research, commercialization, production,
and marketing. Life-science innovations increasingly take place within the educational-industrial
complex, where research universities and public research institutions are engaged mainly in the
early stages of innovation, and startup and major corporations are engaged more in product
development (Graff et al., 2009). Much of the academic research addresses basic problems with
uncertain outcomes that may result in new commercial innovations or in knowledge that has
either pure public-good properties in the economic sense, such as basic-research discoveries that
are nonrival and nonexclusive (Just et al., 2008), or properties that are not easy to appropriate, so
revenues cannot be collected. Thus, such academic research will receive underinvestment by the
private sector and warrants public-sector support (Dasgupta and David, 1994; Dasgupta, 1999).
Not all discoveries from academic research in genetic-engineering technology result in
nonrival and nonexcludable products. For example, some scientists patent their innovations;
these are then excludable products that can be licensed to other scientists, nonprofit
organizations, or industry. A national survey in 2004 revealed that about 25 percent of
responding scientists had filed for a patent since 2000. About 15 percent of the scientists had
been issued a patent, and just under 8 percent had licensed their invention for use by private or
public parties (Buccola et al., 2009). The responding scientists expressed slight support for
patenting compared to the belief that publicly supported scientists should focus on knowledge
with nonexcludable benefits (a mean of 2 versus a mean of 5 on a 6-point scale) (Buccola et al,
2009). Some scientists may be inclined to patent their discoveries in case they contribute to
future, commercially developed technology.
In those cases where university discoveries and innovations are basic proofs of concepts, the
private sector often undertakes the development effort, upscaling manufacturing capacity and
commercializing the technology. Companies that invest in development of university innovations
frequently buy rights to university patents to secure intellectual property protection and
monopoly power once the products are developed. Without that protection, the finns may be
unwilling to invest the capital necessary to move the technology to the commercialization stage.
There is likely to be underinvestment in commercialization of biotechnolog>' innovation by
the private sector because companies with implicit monopoly rights associated with patents aim
to maximize their own profit widiout taking full account of consumers’ welfare gains that result
from the lower prices associated with an innovation. Firms cannot capture the potential benefits
external to farmers and consumers, such as reduction in downstream pollution. The
underinvestment in research makes a case for public-sector development of GE varieties as long
as social benefits exceed social costs or social-equity objectives defined by elected
representatives are achieved (de Gorter and Zilberman, 1990; Just et al, 2008). The situation
suggests that public-sector research should emphasize the development of genetic-engineering
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technologies in specialty crops and innovation of other kinds, such as traits that may lead to a
reduction in greenhouse-gas emissions from crop or livestock production or novel varieties that
conserve water resources, ihe ability of the public and private sectors to develop new gene
technologies depends on the costs of innovation, which may include access to intellectual-
property rights and regulatory requirements. A tailored and targeted regulatory approach to GE-
crop trait development and commercialization that meets human and environmental safety
standards while minimizing unnecessary expenses could enhance progress on this front (Ervin
and Welsh, 2006).
In reinforcement of those conceptual points, recent studies of genetic-engineering R&D have
concluded that publicly funded research programs can complement private-sector R&D efforts in
developing the full potential of agricultural biotechnology (Graff and Zilberraan, 2001; Glenna et
ah, 2007; Buccola et ah, 2009). There are several reasons for that conclusion. First, federal and
state support encourages more basic research, whereas industry and foundations support more
applied research in U.S. universities (Buccola et al., 2009). Downstream (i.e., more applied)
research tends to be legally and economically more excludable than upstream (i.e., more basic)
research. Publicly funded research offers the highest potential for achieving public goods, such
as the basic science of genetic mechanisms, broadly accessible platform technologies, and
nonmarket environmental services (Buccola et al., 2009). Second, industry collaborations with
academic scientists have affirmed the necessity of a strong independent university research
sector in helping to provide credible evaluations of new technology (Glenna et al., 2007). Third,
both publicly and privately supported research assist in the transfer of basic discoveries in
genetic-engineering technology, such as plant-genome characterizations, into useful crop-plant
applications (Graff and Zilberman, 2001). For example, publicly supported basic research on
Arabidopsis thaliam has provided an enormous store of information on basic plant biology,
which in turn has enhanced our ability to produce commercially important advances in crops of
all kinds. New institutional mechanisms are needed to provide an uninterrupted “pipeline” from
basic research to field application (Graff et al., 2003). Fourth, commercialization of orphan and
minor crops requires a special role for public R&D because the improvement of such crops often
will not lead to sufficient profit to attract private-sector investment, even though the crops are
important to many farmers and consumers. Fifth, public funding of academic research and
government research fosters investigation that is too risky, or not sufficiently profitable, to be
attractive to the private sector.
The evidence assembled in this report makes clear that the first generation of GE soybean,
cotton, and com varieties has generally been economically and environmentally advantageous
for U.S. farmers who have adopted the technologies. The next generation of genetic-engineering
technologies being reported by industry suggests that it is intent on enhancing those benefits and
going beyond to new traits, such as drought and heat tolerance and enhanced fertilizer utilization
that may indirectly reduce nutrient runoff, and new applicability to minor crops, renewable
energy, climate change, and nutritional qualities. The public sector must complement industry by
developing genetic-engineering technologies for crops that have insufficient markets to justify
R&D and regulatory expense and to develop socially valuable public-goods applications. We
envision the research and technology agenda to include individual private and public activities as
well as private-public collaborations and to encompass work on the three essential components
of sustainable development: environmental, social, and economic. Furthermore, we recommend
that this agenda be undertaken in a program of research, technology development, and education
that maximizes the potential synergies between the two sectors and their strengths and that limits
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redundancies and tradeoffs. Such an integrated approach would have universities, government,
and nonprofit organizations leading in the development of traits that deliver public goods,
including basic discoveries and such environmental issues as improved regional water quality.
The private sector would continue to lead in the commercialization of GE crops for which there
are adequate market incentives.
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Appendix B
Tillage Systems
Below is an outline of general tillage and weed management practices for com, soybean,
and cotton. Tillage and weed control practices, however, vary greatly across regions of the
United States and within a region based upon grower preference, soil texture, structure, and
erosion potential for each individual farm.
Conventional or Conservation Tillage
Pre-tillage - may include shredding of cornstalks, usually in the fall, shortly after harvest.
Primary Tillage - types of equipment include moldboard plow, chisel plow, field cultivator,
and tandem disk depending upon preference by the grower and soil erosion potential. For
example, moldboard plow would be avoided if the fields are designated as Highly Erodible
Land. Consequently, the chisel plow, field cultivator, or tandem disk are primary tillage
implements in conservation tillage systems. Primary tillage can occur in the fall or the spring,
depending on soil conditions and erosion potential of the soil. Furthermore, primary tillage
may be done as a zone over the row where crops will ultimately be planted (strip tillage).
Secondary Tillage - types of equipment include tandem disk, field cultivator, chisel disk,
disk harrow, harrow, and other implements. The type of equipment used depends on grower
preferences, machinery complement, the region of the country, soil structure and texture, soil
erosion potential, and environmental conditions during the season. Secondary tillage
operations typically occur in the spring. Secondary tillage can involve multiple passes but
quite often a series of implements are pulled in tandem, making it a one-pass operation. If
growers are practicing conservation tillage, more than 30 percent of residue is present on the
soil surface after planting.
Weed management - may or may not include a half rate or full rate of soil-applied
herbicides with residual activity before or after planting (pre-emergence or early
postemergence to the crop). Modem sprayers are typically 90 feet in width or more, and this
step requires very little time and fuel use. Some growers, however, have tanks mounted on
their planters and spray the residua! herbicides at planting, thus saving an operation.
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Herbicide-resistant crops are ^ically treated with glyphosate postemergence to the crop and
weeds and may include other herbicides with different mechanisms of action. A second (and
possibly a third) application of glyphosate is typically applied, especially in cotton and
soybean where additional applications may be made. If one or more weeds have become
resistant to glyphosate or the farmer’s herbicide of choice, then the grower may apply a
substitute herbicide or use a till^^e operation to control the weed.
Organic growers substitute tillage (cultivation) operations, typically three or more, for
herbicides for weed control. The first operation is usually performed just after com or
soybean has emerged, using a rotary hoe. This step is usually followed by two cultivations,
the first occurring when com or soybean is quite small.
No Tillage
Pre-tillage - some growers may shred cornstalks.
Weed management - some growers will use a non-selective ”burn-down” herbicide, such as
glyphosate, to kill existing weeds if they are present before planting. Farmers may also wait
until after planting for the initial herbicide application. This treatment may include a
combination of herbicides that provide residual control of weeds that emerge later in the
season. Postemergence applications of herbicides may be used later in the season depending
on the weed infestation.
Planting - involves more sophisticated versions of the planters used for conventional tillage.
Typically, the planters have heavy coulters and other attachments to clear the residue from
the previous crop in the planting row. Not all soils are suitable for no-till, especially wet and
heavy soils in northern latitudes, and no-till may lead to increased pest occurrence because
conventional tillage may reduce insect, pathogen, and weed occurrence. On the other hand,
no-till is well adapted to well-drained soils in warm regions because no-till improves soil-
water infiltration and reduces soil evaporation, thereby providing more soil water to the crop.
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Appendix C
Biographical Sketches of Committee Members
David E. Ervin {Chair) is professor of environmental management, professor of economics, and
fellow at the Center for Sustainable Processes and Practices at Portland State University. Dr.
Ervin also serves on the board of the United States Society for Ecological Economics. He teaches
economics of sustainability, business environmental management, and global environmental
issues. His research and writing work includes university-industry research relationships in
agricultural biotechnology, risk management of transgenic crops, voluntary business
environmental management, and green technology. He recently directed a multi-university and
multidisciplinary research project on public goods and university-industry relationships in
agricultural biotechnology funded by the U.S. Department of Agriculture (USDA). He holds a
B.S. and an M.S. from the Ohio State University and a Ph.D. in agricultural and resource
economics from Oregon State University.
Yves Carriere is a professor of insect ecology in the Department of Entomology at the
University of Arizona. He is an expert on the interactions between insects and transgenic plants,
environmental impacts of transgenic crops, and integrated pest management. He is an associate
editor of the Journal of Insect Science. Dr. Carriere received a B.Sc. and an M. Sc. in biology
from Laval University and holds a Ph.D. in entomology and behavioral ecology from Simon
Fraser University.
William J. Cox is a professor of crop science, joined the Cornell University faculty on an
extension-research appointment in 1984. He has served in several capacities, including
department associate chairman and extension leader. He recently evaluated the effects of
transgenic seed on the yield and economics of com production. His research also focuses on the
environmental, biotic, and management interactions that influence the growth, development,
yield, and quality of corn, soybeans, and wheat. He collaborates closely with soil scientists,
animal scientists, plant pathologists, entomologists, and plant breeders in an effort to quantify
whole-plant physiological responses of the crop to the environmental, biotic, and crop
management interactions. He is a senior associate editor of the Agronomy Journal and the
electronic publication Crop Management. Dr, Cox holds a Ph.D. in crop science from Oregon
State University. He received an M.S. in agronomy from California State University-Fresno and
a B.S. in history from the College of the Holy Cross.
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Jorge Fernandez-Cornejo is an agricultural economist in the Resource and Rural Economics
Division of U.S. Department of Agriculture Economic Research Service (ERS). He currently
works on the adoption and diffusion of agricultural technologies, agricultural biotechnology, and
economics of biofuel production. Since joining ERS in 1990, Dr. Femandez-Comejo has
researched U.S. farmers’ experience with biotechnology in the first decade of its adoption and
the effects of the technology on farmers’ decision-making process. He has also studied the seed
industry. He has a Ph.D. in operations research and agricultural economics and a master’s in
chemical engineering from the University of Delaware, an M.A. in energy and resources from
the University of Califomia, Berkeley, and a B.S. in industrial engineering. Dr. Femandez-
Comejo has expertise In agricultural economics, farm management, integrated pest management,
and farm-level impacts of transgenic seed.
Raymond A. Jussaume, Jr., is professor and chair of the Department of Community and Rural
Sociology at Washington State University. His academic appointment includes teaching,
extension-outreach and research. The main thrust of his research has been to contribute to a
growing international research agenda on the globalization of agri-food systems and various
strategies for improving agricultural sustainability. Most recently, much of his research has been
focused on how agricultural sustainability can be enhanced by increasing the extent to which
agri-food systems are “localized”. He recently published several journal articles evaluating
Washington State farmers’ attitudes toward biotechnology. Dr. Jussaume was a participant at the
National Research Council’s Conference on Incorporating Science, Economics and Sociology in
Developing Sanitary and Phytosanitary Standards in International Trade. He received his Ph.D.
in development sociology from Cornell University.
Michele Marra is a professor of agricultural economics at North Carolina State University and
an extension specialist. A production economist, she has concentrated on economic issues
surrounding integrated pest management and the characteristics of agricultural innovations that
affect farmer choice. She works on the farm-level impacts of crop biotechnologies and the
economics of precision farming. Her recent publications have analyzed the benefits of and risks
posed by adopting new agricultural technologies and the effects of agricultural biotechnology on
farmer welfare. Dr. Marra Is a member of the American Agricultural Economics Association and
served as the associate editor of the American Journal of Agricultural Economics from 2004 to
2007. She has a Ph.D. in economics and an M.S. and a B.S. in agricultural economics from North
Carolina State University.
Micheal Owen has a Ph.D. in agronomy and weed science from the University of Illinois. He is
associate chair in the Department of Agronomy of Iowa State University. He has extensive
expertise in weed dynamics, integrated pest management, and crop risk management. His
objective in extension programming is to develop information about weed biology, ecology, and
herbicides that can be used by growere to manage weeds with cost efficiency and environmental
sensitivity. His work is focused on supporting management systems that emphasize a
combination of alternative strategies and conventional technology. Dr. Owen has published
extensively on farm-level attitudes toward transgenic crops and their impacts; selection pressure,
herbicide resistance, and other weed life-history traits; and tillage practices.
Peter H. Raven is the president of the Missouri Botanical Garden; a George Engelmann
Professor of Botany, Washington Univereity, St. Louis; adjunct professor of biology, University
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of Missouri, St. Louis and St. Louis Univereity; and a member of NAS. He earned his Ph.D. at
the University of California, Los Angeles. Dr. Raven was a member of President Clinton’ s
Council of Advisors on Science and Technology. He served for 12 years as home secretary of
NAS and is a member of the academies of science of Argentina, Brazil, China, Denmark, India,
Italy, Mexico, Russia, Sweden, and the U.K. Dr. Raven's primary research interests are in the
systematics, evolution, and biogeography of the plant family Onagraceae; plant biogeography,
particularly in the tropics and SouAera Hemisphere; and tropical Boristics and conservation. The
author of numerous books and reports, both popular and scientific. Dr. Raven was a coauthor of
Biology of Plants and Environment.
L. LaReesa Wolfenbarger conducts research on ecological effects of transgenic crops and
agricultural practices, and on land management for grassland bird conservation at the University
of Nebraska, Omaha. Other research interests include: the effects of agriculture on grassland
ecosystems and the ecology of grassland ecosystems in agricultural landscapes. She has
published several articles on the relationship between genetically engineered organisms and the
environment and on the ecological risks and benefits related to genetically engineered plants. Her
research also seeks to understand the responses of avian communities and reproduction to habitat
variation and to management practices on restored grasslands, remnant prairies, and marginal
agricultural habitats. Her other work includes synthesizing science on agricultural biotechnology,
chairing a committee for a departmental graduate student program, organizing public symposia
on environmental issues, and managing a 160-acre prairie preserve. Dr. Wolfenbarger earned her
Ph.D. in ecology from Cornel! University.
David Zilberman has been a professor in the Department of Agricultural and Resource
Economics of the University of California, Berkeley, since 1979. His research interests are in
agricultural and nutritional policy, economics of technological change, economics of natural
resources, and microeconomic theory. He is a fellow of the American Agricultural Economics
Association and the Association of Environmental and Resource Economists, which have
recognized many of his publications on the adoption and regulation of agricultural biotechnology
for their quality and value to the field. He received his B.A. in economics and statistics from Tel
Aviv University in Israel and his Ph.D. in agricultural and resource economics from the
University of California, Berkeley. Dr. Zilberman has expertise in the intersection of
biotechnology and politics and economics and agricultural marketing. He has recently published
on biofuels and biotechnology marketing.
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567
Journal of Agricultural and Applied Economics, 38,3(December 2CK)6):629-643
© 2CK)6 Southern Agricultural Economics Association
Simultaneous Adoption of
Herbicide-Resistant and
Conservation-Tillage Cotton Technologies
Roland K. Roberts, Burton C. English, Qi Gao, and
James A. Larson
If adoption of herbicide-resistant seed and adoption of conservation-dliage practices are
dctennined simultaneously, adoption of herbicide-resistant seed could indirectly reduce soil
erosion and adoption of conservation-tillage practices could indirectly reduce residual her-
bicide use and increase farm profits. Our objective was to evaluate the relationship between
these two technologies for Tbnnessee cotton production. Evidence from Bayes’ theorem
and a two-equation logit model suggested a simultaneous relationship. Mean elasticities
for acres in herbicide-resistant seed with respect to the probability of adopting conserva-
tion-tillage practices and acres in conservation-tillage practices with respect to the proba-
bility of adopting herbicide-resistant seed were 1.74 and 0.24, respectively.
Key Words: Bayes’ theorem, conservation tillage, cotton, genetically modified crops, her-
bicide-resistant crops, simultaneous logit model, technology adoption
JEL ClassfficaUotis: Q12, Q16, Q24, 033
Herbicide-resistant BXN (Buctril-resistant)
cotton seed was first introduced in 1995 by the
Stoneville Pedigreed Seed Company (Ward et
al. 1995) and Ronndup-Ready cotton seed be-
came commercially available in 1996 (John-
son 1996). The adoption of herbicide-resistant
seed by farmers has dramatically changed cot-
ton production practices with potential con-
sequences for the environment. Monsanto
Roland K. Roberts and Burton C. English ate profes-
sors, fames A, Larson is associate professor, and Qi
Gao is former graduate research assistant. Department
of Agricultural Economics, University of Tennessee,
Knoxville, TN.
'The authors thank Bruno Alesii of Monsanto and
John Bradley of Beltwide Cotton Genetics for their
useful suggestions, Donald Tyler and Delton Gerloff
for their insights into the research issues, and the anon-
ymous reviewers for their helpful comments. Funding
was provided by the Tennessee Agricultural Experi-
ment Station.
claims that adoption of herbicide-resistant
seed facilitates adoption of conservation till-
age, which “sustains the environment.” Soule,
Tegene, and Wiebe used data from the 1996
USDA Agricultural Resource Management
Survey (ARMS) and with logit analysis eval-
uated the effects of land tenure on adoption of
conservation-tillage practices. Although data
from the 1996 ARMS were available for adop-
tion of herbicide-resistant crops (Femandez-
Comejo and McBride 2002), adoption was
low, and Soule, Tegene, and Wiebe were not
intent on evaluating the synergy between
adoption of herbide-resistant seed and conser-
vation-tillage practices. Femandez-Cornejo
and McBride (2002) used 1997 ARMS data
and a two-equation simultaneous probit model
to evaluate this potential synergistic relation-
ship. Contrary to Monsanto’s claim, they
found no evidence that soybean farmers who
568
630
Journal cf Agricultural and Applied Economics, December 2006
had adopted herbicide-resistant seed had a
higher probability of adopting no-tillage prac-
tices than fanners who had not adopted her-
bicide-resistant seed. They found evidence
supporting the converse, however; farmers
who had adopted no-dllage practices had a
higher probability of adopting herbicide-resis-
tant soybean seed than fanners who had not
adopted no-tillage practices. Lack of simulta-
neity most likely resulted from using cross-
sectional data for the year after herbicide-re-
sistant soybean seed was first introduced,
leaving little time for adjustment in tillage
practices. Using data from a 1999 survey of
cotton farmers conducted in South Georgia,
Ward et al. (2002) found evidence based on
efficiency measures that farmers may have in-
centive to simultaneously adopt herbicide-re-
sistant seed and conservation-tillage practices.
Mana, Piggott, and Sydorovych found that
76% of North Carolina com, soybean, and cot-
ton acreage in herbicide-resistant seed was
produced with conservation-tillage practices
in 2001, while only 64% of com, soybean, and
cotton acreage in conventional seed was pro-
duced with conservation-tillage practices.
Their specific results for cotton were different,
with these two percentages being about the
same at close to 73%.
Findings from the aforementioned cross-
sectional analyses suggest a simultaneous re-
lationship may exist between adoption of her-
bicide-resistant seed and adoption of
conservation-tillage practices, but the evi-
dence is inconclusive, especially for cotton.
Sufficient atmual time-series' data are now
available to investigate the relationship of the
adoption of these two technologies over time.
The Conservation Tillage Information Center
(Fawcett and Towery) used a limited time-se-
ries sample of percentages of acres in gly-
phosate-resistant crops by tillage method for
1998 through 2000 and a 2001 survey by the
American Soybean Association to suggest a
simultaneous relationship between adoption of
glyphosate-resistant crops and conservation-
tillage practices in the United States. The in-
formation for Tennessee cottrai acreage in Fig-
ure 1 (Doane Marketing Research, Inc.;
Monsanto; Tennessee Department of Agricul-
Ytm
CwtryirtwTBuin
Figure 1. Total Tennessee cotton acreage
with percentages in herbicide-resistant seed
and conservation-tillage practices
ture, 1996-2003, 2(X)4) also suggests a rela-
tionship between adoption of herbicide-resis-
tant seed and conservation-tillage practices.
From 1992 through 1998, the share of Ten-
nessee cotton acreage in conservation-tillage
practices averaged 38% with no discemable
trend. In 1999 when adoption of herbicide-re-
sistant cotton seed started in earnest, the share
of conservation-tillage acreage began a slight
upturn to 40% with a dramatic increase there-
after, averaging 76% between 2000 and 2004
and reaching almost 100% in 2003 and 2004.
During the 1992 through 2004 period, cotton
acreage in Tennessee showed no perceptible
trend, except during the mid-to-late 1990s
when the Boll 'Weevil Eradication Program
was active in middle and southwestern Tfen-
nessee (Suarez, Larson, and English 2(K)0).
Because of eradication jHogram costs, farmers
had an incentive to switch to other crops dur-
ing the active phase of Uie program. Cotton
acreage was relatively stable after 1998, when
herbicide-resistant seed and conservation-till-
age practices were being rapidly adopted.
In our research, annual time-series data
along with Bayes’ theorem and simultaneous
estimation of two binomial logit models were
used to examine the relationship between
adoption of herbicide-resistant seed and adop-
tion of conservation-tillage practices in Ten-
nessee cotton production. If adoption of her-
bicide-resistant seed influenced adoption of
conservation-tillage practices, adoption of her-
bicide-resistant seed may have indirectly led
569
Roberts et al.: Herbicide-Resistant and Conservation-Tillage Cotton 631
to greater soil conservation and, if adoption of
conservation-tillage practices influenced adop-
tion of herbicide-resistant seed, adoption of
conservation-tillage practices may have indi-
rectly led to reduced residual herbicide use
and increased farm profits as adoption of her-
bicide-resistant seed increased (Marra, Pardy,
and Alston).
The choice of tillage method is a major de-
cision for farmers because of its potential im-
pacts on soil erosion and farm profit. Erosion
of agricultural topsoils has been recognized as
a problem for decades. Federal mandates have
encouraged production practices to curb ero-
sion. Anderson and Magleby and Heimlich
provide a comprehensive overview of U.S.
government policies designed to encourage
conservation of our nation's topsoils. For ex-
ample, Conservation Compliance, established
in the 1985 Farm Bill, resulted in farms with
highly erodible lands being requited to alter
cropping patterns and tillage practices to re-
duce erosion as a requirement for receiving
government payments: in 1991, the Crop Res-
idue Management Action Plan was developed
to assist producers in implementing conser-
vation systems. Tennessee has the most erod-
ible cultivated cropland in the United States
(Denton), with cotton being produced on some
of those erodible soils. Adoption of conser-
vation-tillage practices in cotton production
has lagged behind adoption in other row crops
(Tetmessee Department of Agriculture 2004).
Exploring the relationship between adoption
of herbicide-resistant seed and adoption of
conservation-tillage practices in Tennessee
cotton production could lead to improved pol-
icies for reducing soil erosion.
Farmers who adopt conservation-tillage
practices may benefit if adopting herbicide-re-
sistant cotton seed allows them to use more
effective herbicide treatment systems (Shoe-
maker et al.). Weed control is a vital compo-
nent of conservation tillage. Failure to control
weeds with conservation tillage can result in
decreased quantity and quality of output. Be-
sides preventing yield loss from weed com-
petition, weed control is particularly important
in cotton production because weeds can stain
lint during harvest and processing, resulting in
price discounts (Moore). Herbicide-resistant
seed provides farmers with effective weed
control programs that eliminate some prob-
lems associated with conservation programs
(Fawcett and Towery). Investigating the rela-
tionship between adoption of conservation-
tillage practices and herbicide-resistant seed
could increase our understanding of ways to
increase farm profit and reduce residual her-
bicide use (Marra, Pardey, and Alston) while
conserving soil.
The objectives of this research were: (1) to
evaluate the relationship between adoption of
herbicide-resistant cotton seed and conserva-
tion-tillage cotton production practices over
time and (2) to quantify the effects of econom-
ic phenomena on the adoption of herbicide-
resistant seed and conservation-tillage practic-
es for cotton production in Tennessee.
Methods and Data
The problem at hand is one of simultaneous
adoption of synergistic technologies and man-
agement practices. Wu and Babcock used a
polychotomous-choice selectivity model to
evaluate choices among crop management
plans, including tillage, rotation, and fertility
management alternatives. Dorfman used a
multinomial probit model, estimated in a
Bayesian framework using Qibbs sampling
(Geman and Geman), to evaluate adoption of
improved irrigation methods and integrated
pest management practices in apple produc-
tion. Fernandez-Cornejo, Hendricks, and
Mishra estimated a trivariate-choice selectivity
model to evaluate the relationships among off-
farm operator employment, off-farm spouse
employment, and adoption of herbicide-resis-
tant soybean seed. In an analysis more related
to this article, Femandez-Comejo and Mc-
Bride simultaneously estimated two binomial
probit models for adoption of herbicide-resis-
tant seed and no-tillage practices in soybean
production.
Two methods were used to evaluate the re-
lationship between adoption of herbicide-re-
sistant cotton seed and conservation-tillage
cotton production practices in Tennessee. The
first method was a comparison of conditional
570
632
Journal qf Agricultural and Applied Economics, December 2006
probabilities using Bayes’ theorem (Render,
Stair, and Hanna). The second was the simul-
taneous estimation of two binomial logit mod-
els, where the two equations represent the
choices between adopting herbicide-resistant
versus conventional seed and adopting con-
servation-tillage versus conventional tillage
practices. Both methods assume the probabil-
ity that a farmer will choose to produce an
acre of cotton using a particular technology is
equal to the share of cotton acreage produced
with that technology.
Bayes’ Theorem
Consider two events: (1) Event H occurs when
an acre of Tennessee cotton is produced with
herbicide-resistant seed and (2) Event C oc-
curs when an acre of Tennessee cotton is pro-
duced with conservation-tillage practices. The
complement of event H (ft) occurs when an
acre is produced with conventional cotton seed
and the complement of C (C) occurs when an
acre is produced with conventional tillage
practices. Let the probability of an event oc-
curring be represented by the share of total
Tennessee cotton acreage in that event. When
events H and C are not independent, Bayes’
theorem states that the conditional probability
of event H occurring given that event C has
occurred, I Q. i* equal to the joint prob-
ability of events H and C occurring, P(HC),
divided by the marginal probability of event
C occurring, P{C), or mathematically (Render;
Stair, and Hanna):
( 1 )
F(H|C)
PIHC)
PIC) •
Two other probabilities of interest are the
conditional probability of one event occurring
given that the complement of the other event
has occurred
(3)
P(.H\C) =
P{hC)
P(.C)
Pm - p(HC)
1 - P(C)
, and
P(C|H) =
P(HC)
P(ii)
PIC) - P(HO
1 - pm
When events H and C are independent,
/’(H|C) = P(m and i>(C|H) = P(C). Inde-
pendence implies that the conditional proba-
bilities in Equations (1) and (3) arc equal, the
conditional probabilities in Equations (2) and
(4) are equal, and these conditional probabil-
ities equal their respective marginal probabil-
ities. Alternatively, if P(fl|C) > P{H\C), the
adoption of conservation-tillage practices has
increased the probability of adopting herbi-
cide-resistant cotton seed, and if ElCl/f) >
P(C|H), the adoption of herbicide-resistant
seed has increased the probability of adopting
conservation-tillage practices.
We calculated and compared the condition-
al probabilities in Equations (1) through (4)
using data for 1998 through 2004 (Doane
Marketing Research, Inc.) on the percentages
of Tennessee cotton acres in herbicide-resis-
tant seed, conservation-tillage practices, and in
both technologies. This data set contained the
only consistent time-series data found that in-
cluded P(C), P(H), and P{HC). Data were not
available from Doane Marketing Research,
Inc. for 1995 through 1997 and were excluded
from the conditional probability analysis.
Logit Analysis
If events H and C are independent, P(.H\C) -
P{H) (Render; Staii; and Hanna). Bayes’ the-
orem can be stated conversely as
(2) 2’(C|«) = ^,
where P{C\H) is the conditional probability
of event C occurring given that event H has
occurred. If events H and C are independent,
E(C|ff) = P{C).
Following Gairod and Roberts, assume cotton
production can be accomplished during a par-
ticular year using herbicide-resistant or con-
ventional seed technologies and cotton acreage
is constrained to a fixed level by exogenous
or predetermined events (e.g., naive price ex-
pectations and lagged cotton acreage). Let p„
and pg represent average profit functions for
herbicide-resistant and conventional seed tech-
nologies, respectively, where p-, is conditional
upon the number of acres in technology i (qj.
571
Roberts et al.: Herbicide-Resistant and Conservation-Tillage Cotton
i — H and H), prices of outputs, and prices of
inputs. Thus, we assume the farmer’s problem
is to allocate cotton acreage between herbi-
cide-resistant and conventional seed technol-
ogies to achieve maximum profit. Our hypoth-
esis is that adoption of herbicide-resistant seed
is not independent of adoption of conserva-
tion-tillage practices. If they are not indepen-
dent, p, also includes conservation-tillage cot-
ton acreage as an argument.
Assuming q„ and qg are dependent on the
conditional profits of both technologies, their
quantities and shares can be defined as
(5) = /i(Ph, Ph< Q) i = H and H, and
*1 = /i/S /,-• i = H and H.
where k„ = q„IQ and kg = qg/Q are acreage
shares of the respective technologies, which
sum to one and are interpreted as probabilities
of adopting the respective technologies. If we
further assume
(6) ft = exp[s,(p„, pg, 0], I = // and ft
then kj is defined as a universal logit function
(Amemiya). A convenient expression is then
derived by taking the natural logarithm of the
probability ratio, or odds ratio:
(7) In(Vis) = ln(?„/qa) = r« = - gg.
Equation (7) can be estimated using standard
econometric methods if it is stochastic and lin-
ear in its arguments, and an estimate of the
probability of adopting herbicide-resistant cot-
ton seed can be obtained.
Conditional elasticities for q„ and qg with
respect to an explanatory variable can be cal-
culated as in Roberts and Gatrod. These elastic-
ities, for variables other than Q, approach zero
as t, (i = H ot ft) approaches unity, suggesting
that as the choice becomes limited to one alter-
native, that alternative caimot change in the
short mn because q, = Q is fixed. Also, the
weighted sum of these two elasticities equals
zero, where the weights are the acreage shares
in each seed technology, thus, in the short run,
cotton acreage in herincide-tolcrant seed cannot
633
increase (or decrease) without decreasing (or in-
creasing) acreage in conventional seed. For Q,
the weighted sum of the elasticities is urtity. If
acreage in conservation-tillage practices is an ar-
gument of Zg, the influence of conservation-till-
age adoption on the adoption of herbicide-tol-
erant seed, and its complement can be evaluated
through their respective elasticities.
A similar model can be hypothesized for
the choice between the use of conservation-
tillage (C) and conventional tillage (C) prac-
tices:
(8) ln(i:c/*e) = ln(9c/9c) = Zc = «c “ St-
where kj = qj/Q (j = C and C); qj is acreage
in technology J (j = C and C); and Q — qc +
qc- We hypothesize that adoption of conser-
vation-tillage practices is not independent of
herbicide-resistant cotton seed adoption, sug-
gesting that acreage in herbicide-resistant seed
is an argument of Zc- If indeed acreage in con-
servation-tillage practices is an argument in
Equation (7) and acreage in herbicide-resistant
seed is an argument in Equation (8). these two
equations form a system of simultaneous
equations that must be estimated with appro-
priate econometric methods that account for
simultaneity.
For empirical estimation. Equations (7) and
(8) were specified as
<»
=^^0 + ^iCAC + ^ ^RUPRiCOPR
+ ^^RSPRICSPR +
+ PjCTXC + fi/#,
and
= 7„ + 7,/MC 4- y^RUPR/FVPR
+ t^RAIN + y, DRAIN -I- y,NRAlN
+ y^CTAC 4 ec,
where variable defittitions and means are giv-
en in Table 1 the Ps and ys are parameters to
be estimated; and eg and Cc are random errors.
572
634 Journal of Agricultural and Applied Economics, December 2006
Table 1. Logit Model Variables, Definitions, and Means
Variable
Deiimtion
Mean*
. , NAC ,
^ 100 - HAC?
Natural logarithm of the ratio of the perceatage of Tennessee
cotton acres in herbicitle-resistant (Roundup Ready,
BXN, and liberty Link, including stacked genes) to the per-
1.80(1.11)
. , CAC ,
^ Soo - CAC?
centage in conventional seed
Natural logarithm of the ratio of the percentage of Tennessee
cotton acKS in conservation tillage <no-tiil, ridge-tiU, strip-
till, and mulch-till) to the percentage in conventional tillage
0.61 (0.20)
HAC
Percentage of Tennessee cotton acres in herbicide-resistant
^d
69.31 (42.65)
CAC
Percentage of Tennessee cotton acres in conservation tillage
61.31 (52.58)
RUPR
Roundup price ($/pint)
5.83 (6.08)
COPR
Cotoran price ($/pint)
4.57 (4.93)
RUPRICOPR
Ratio of RUPR to COPR
1.28(1.28)
RSPR
Roundup-Ready cotton seed price ($/lb)
1.88 (1.16)
CSPR
Conventional cotton seed price ($/lb)
1.01 (0.90)
RSPR/CSPR
Ratio of RSPR to CSPR
1.87(1.15)
D
Dummy equals 1 for 1999 through 2004; 0 otherwise
0.75 (0.46)
CTAC
Total Tennessee cotton acres (100,000s)
5.52 (5.77)
FUPR
U.S. index of prices paid by farmers for fuel, 2002 = 1.00
1,07(0.98)
RUPR/FUPR
Ratio of RUPR to FUPR lagged one period
6.35 (6.88)
RAIN
County average cumulative rainfall for April and May for
the five highest cotton-producing counties in Tennessee
(inches)
10.62 (9.96)
DRAIN
Dummy equals RAIN if RAIN is greater than one-half stan-
dard deviation above its mean (>11.16 inches); 0 otherwise
5.00 (3.08)
NRAIN
Dummy equals 1 if November rainfall in the previous year
was greater than one-half standard deviation from its mean
(>4.97 inches); 0 otherwise
0.38 (0.5)
* Means of annual data for 1997 through 2004, with means for 1992 through 2004 in parentheses.
Equations (9) and (10) were estimated with
three-stage least squares using Tennessee an-
nual time-series data for the 1992-2004 peri-
od. The Roundup price {RUPR) was taken
from Economic Research Service (1997) and
National Agricultural Statistics Service (2005,
2003, 2000, 1996a, 1996b). Cotoran iCOPK),
Roundup-Ready seed (RSPR), and conven-
tional seed (CSPR) prices were taken from an-
nual Tennessee field crop and cotton budgets
(Johnson 1992-1993; Gerloff 1994-1999;
Gerloff 20(K)-2004). The U.S. index of prices
paid by farmers for fuel (FUPR) was taken
from the Council of Economic Advisors. Data
for the rainfall variables (RAIN, DRAIN, and
FRAIN) were received Irom the National Cli-
matic Data Center. The percentages of Ten-
nessee cotton acreage in conservation-tillage
(CAC) and conventional tillage (100-CAC),
and total cotton acreage (CTAC) were found
in Tennessee Department of Agriculture
(1996-2003, 2004). Data used in the condi-
tional probability analysis for the share of Ibn-
nessee cotton acreage in conservation-tillage
practices provided by Doane Marketing Re-
search, Inc. were not used for OIC because
those tillage data only covered the 1998-2004
period. Tillage data from Tennessee Depart-
ment of Agriculture allowed estimation of
Equations (9) and (10) with time-series data
for 1992 through 2004.
The HAC data for 1995 through 1997 were
573
Robens et al: Herbicide-Resistant and Conservation-TiUage Cotton 635
not available fixim Doane. HAC was zero for
1992 through 1994 because herbicide-resistant
cotton seed was not available to fanners in
those years, and it was assumed zero for 1995
and 1996 because herbicide-resistant cotton
seed adoption in Tennessee was sufficiently
small (Alesii and Bradley, personal commu-
nication) for HAC to be considered zero with-
out appreciably affecting the analysis. Data for
HAC for 1998 through 2004 were received
from Doane Marketing Research, Inc. Mon-
santo (Alesii and Bradley, personal commu-
nication) provided their best estimate for HAC
in 1997 of about half the Doane 1998 level,
which was used in the logit analysis. Acreage
elasticities were calculated at the means of the
data for 1997-2004 (instead of 1992-2004) to
provide a more consistent view of acreage re-
sponsiveness during the period when herbi-
cide-resistant seed was available and being
adopted by fanners.
The price variables in Equations (9) and
(10) were used as proxies for prices of inputs
hypothesized to make the most difference in
relative profitability for the respective tech-
nology choices. Other prices were not consid-
ered because of general colinearity among
prices and to preserve degrees of freedom.
Price ratios were used for similar reasons.
Prices of cotton lint produced with herbi-
cide-resistant and conventional seed and with
conservation and conventional tillage practic-
es were not included in Equations (9) and (10)
for two reasons. First, prices for cotton lint
produced with the different technologies are
not different unless these technologies produce
lint of different qualities. Concern has been
expressed about a potential loss in lint quaUty
from herbicide-resistant seed (e.g., Bourland
and Johnson; Coley; Ethridge and Hequet;
Kerby et al.; Lewis; Verhalen, Oreenhagen,
and Thacker), although York et al. found no
difference in lint quality compared with con-
ventional cultivars in official North Carolina
cultivar trails. Daniel et al. and Bauer and
Busscher found no differences in lint quality
among tillage systems. Even if differences in
price discounts for lint quality existed, they
would likely have little effect on the results
because their magnitudes would be small rel-
ative to the magnitudes of the prices of lint
produced with these technologies. Second,
separate time-series data do not exist for prices
of lint produced with the technologies evalu-
ated in this analysis.
The expected lint price might still be in-
cluded in Equations (9) and (10) if changes in
the lint price changed the relative profitabili-
ties for each technology choice because of dif-
ferences in yields and/or production costs.
Nevertheless, the expected lint price was ex-
cluded for five reasons. First, research sug-
gests that lint yields are about the same for
conservation and conventional tillage practic-
es (e.g„ Bradley, 1991, 1997; Bronson et al.;
Buman et al.; Daniel et al.; Hudson; Keeling,
Segarra, and Abernathy; York et al.). Second,
differences in budgeted costs between no-till-
age and conventional-tillage cotton in Tennes-
see were from 4% to 6% of total cost regard-
less of seed technology (Gerloff 2003),
suggesting little potential for changes in rela-
tive profitabilities as the lint price changes.
Third, although some evidence suggests lower
lint yields from herbicide-resistant seed (Ver-
halen, Oreenhagen, and Thacker), modeling
by Femandez-Comejo and McBride (2000) in-
dicated increased lint yields with adoption of
herbicide-resistant seed, and Marra, Pardey,
and Alston reported research that indicated
herbicide-resistant lint yields between 120 lb/
acre higher and 164 Ib/acre lower than con-
ventional seed yields. Other researchers who
conducted field trials found similar yields be-
tween the two seed technologies (e.g., Gold-
man et al.; Keeling et al.; Vencill; York et al.).
Fourth, differences in budgeted costs between
Roundup Ready and conventional seed cotton
were only about 1% of total cost regardless of
tillage practice (Gerloff 2003), leaving little
room for changes in relative profitabilities as
the lint price changes. Fifth, even if the ex-
pected lint price affected the acreage alloca-
tion decisions in Equations (9) and (10), much
of its influence would be transmitted to the
decisions through CTAC. The expected lint
price (among other things) determines CTAC,
which in turn influences acreage-allocation de-
cisions for the technology choices portrayed
in Equations (9) and (10). Thu.s, the expected
574
636 Journal of Agricultural and Applied Economics, December 2006
lint price (e.g., lagged price) and CTAC would
capture similar effects and be highly correlat-
ed, producing extreme mnlticollinearity.
Economic theory and other attributes of the
variables in Equations (9) and (JO) allowed
formation of a priori hypotheses about the
signs of the parameters. The motivating hy-
pothesis for this research was that adoption of
conservation-tillage practices positively influ-
ences adoption of herbicide-resistant cotton
seed and that adoption of herbicide-resistant
seed positively influences adoption of conser-
vation-tillage practices; thus. Pi and y, were
both expected to be positive, indicating that a
change in the probability of adopting conser-
vation-tillage cotton (C4C) positively influ-
ences the probability of adopting herbicide-re-
sistant cotton seed and that a change in the
probability of adopting herbicide-resistant cot-
ton seed {HAC) positively influences the prob-
ability of adopting conservation-tillage prac-
tices.
Herbicide-resistant and conventional seed
cotton use two distinct herbicide systems. As
the cost of one system changes relative to the
other, the relative profitability of herbicide-re-
sistant and conventional seed cotton changes
and the probability of a profit-maximitung
farmer choosing one technology over the other
changes. Roundup (RUPR) and Cotoran
(COPR) prices were included in Equation (9)
as proxies for the prices of herbicides used to
produce herbicide-resistant and conventional
seed cotton, respectively. The price of Round-
up was chosen because herbicide-resistant cot-
ton is produced almost entirely with Roundup-
Ready seed and Roundup cannot be used over
top of conventional seed cotton. The price of
Cotoran was used because non-Roundup her-
bicides (e.g., Cotoran and others) are a small
part of the cost of producing herbicide-resis-
tant cotton, and Cotoran was a herbicide con-
sistently recommended for conventional seed
cotton in the University of Tfennessee cotton
budgets (Johnson 1992-1993; Gerloff 1994-
1999; Gerloff 2000-2004). With Roundup be-
ing an input in the production of herbicide-
resistant cotton, a change in RUPR was
expected to negatively influence the probabil-
ity of adopting herbicide-resistant cotton seed
and positively influence the use of conven-
tional cotton seed. Conversely, a change in
COPR was expected to negatively influence
the use of conventional rmtton seed and posi-
tively influence the probability of adopting
herbicide-resistant cotton seed; thus, was
expected to be negative. Similarly, Roundup-
Ready cotton seed and conventional cotton
seed are inputs in the production of herbicide-
resistant cotton and conventional seed cotton,
respectively; therefore, pj was expected to be
negative.
Although herbicide-resistant BXN (Buctril-
resistant) cotton seed was first introduced in
1995 (Ward et al. 1995) and Roundup-Ready
cotton seed became commercially available in
1996 (Johnson 1996), insufficient supply was
available to meet farmer demand until 1999,
when most farmers were able to purchase her-
bicide-resistant cotton seed if they wanted it.
The binary variable D was included in Equa-
tion (9) to account for differences in years
when sufficient herbicide-resistant seed was
available to meet demand compared with
years when herbicide-resistant seed was not
available or not available in quantities suffi-
cient to meet demand. Thus, p* was expected
to be positive.
The sign of was expected to be negative
because herbicides are a more important input
in the i»oduction of conservation-tillage cotton
and fuel is a more important input in the jao-
duction of conventional-tillage cotton. Roundup
is a commonly used bum-down herbicide in
conservation-tillage systems; hence its price was
used as a proxy for prices of herbicides used in
conservation-tillage systems. A decrease in the
price of Roundup {RUPR) relative to the price
of fuel {FUPR) would decrease the cost of pro-
ducing conservation-tillage cotton relative to the
cost of producing conventional-tillage cotton,
encouraging farmers to move away fixrm con-
ventional-tillage towards conservation-tillage
cotton production.
Conservation-tillage practices reduce the
risk of late planting because fewer machinery
operations are r^ulred and crops can gener-
ally be planted when conditions are too wet
for conventional-tillage operations (Bates and
Denton; Harper; Phillips and Hendrix). Heavy
575
Roberts et al.: Herbicide-Resistant and Conservation-Tillage Cotton 637
Table 2. Adoption of Herbicide-Resistant and Conservation-Tillage Cotton for 1998-2004
Proportion of Tenaessee
Cotton Acreage
1998
1999
2000
2001
2002
2003
2004
Herbicide-iesistant, P{H)
0.091
0.677
0.845
0.934
0.959
0.998
0.995
Conservation-tillage, P(C)
0.364
0.549
0.670
0.777
0.709
0.735
0.782
Herbicide-resistant and
conservation-tillage, PiHC)
0.061
0.410
0.625
0.732
0.696
0.733
0.781
Source: Doane Marketing Research, Inc.
rainfall during April and May when farmers
are engaged in tillage and planting operations
makes timely tillage and planting more diffi-
cult, increasing the risk of late planting. Heavy
spring rainfall was hypothesized to encourage
cotton farmers to rent no-till planting equip-
ment, custom hire no-till planting operations,
or retrofit their conventional planters for no-
till planting (Bradley 2001). Conversely, light
spring rainfall might encourage farmers to en-
gage in what some call “recreational tillage”
because many farmers feel they should be out
working in the field when the weather is good
(e.g., Alesii and Bradley, personal communi-
cation; Delta Farm Press; Fletcher). The latter
occurs because farmers who are affected by
heavy spring rainfall are at the margin of con-
servation-tillage adoption and seldom convert
completely hy selling their tillage equipment
(Dumler). These marginal adopters can bring
their tillage equipment back online when the
weather is good if they have douhts about the
relative profitabilities of the two tillage prac-
tices. Therefore, y, was expected to be posi-
tive. A positive -yj implies that increases in
rainfall encourage adoption of conservation-
tillage practices by the same amount as de-
creases in rainfall encourage abandonment of
conservation-tillage practices. DRAIN was in-
cluded in Equation (10) to test the hypothesis
that April and May rainfall of more than one-
half standard deviation above its mean has a
different effect on adoption of conservation-
tillage practices than rainfall of lesser
amounts: thus, 74 was expected to be positive.
Heavy rainfall in the previous year
{NRAIN) may have a different effect on tillage
decisions than heavy spring rainfall. It may
cause farmers to rut their fields during harvest,
requiring spring tillage; thus, the sign of 7 ,
would be negative. Alternatively, heavy rain-
fall in the fall may cause farmers to look to-
ward future spring tillage operations and begin
planning for conversion to conservation tillage
to avoid a perceived risk of late planting. If
farmers ^ply past heavy rainfall to their till-
age decisions in this way, 75 would be posi-
tive; thus, the sign of 7 , was ambiguous.
Theoretically, cotton is produced on the
“best” cotton land in terms of potential profit
compared with other crops. Consequently,
changes in cotton acreage would typically oc-
cur on marginal cotton land that may be more
erodible than land that is already in cotton pro-
duction. We hypothesized that farmers are
more likely to use conservation-tillage practic-
es on this marginal land than on the less-erod-
ible land already in cotton production; thus, 75
was expected to be positive. Farmers who in-
crease cotton acreage or who produce cotton
for the first time may be less risk averse than
those who do not, and they may be more will-
ing to adopt new technologies. If this hypoth-
esis were correct, P, would be positive, and
the positive expectation for 75 would be rein-
forced.
Results
Bayes’ Theorem
Shares of Tbnnessee cotton acreage produced
with each technology and with both technol-
ogies for 1998 through 2004 are presented in
Table 2 and the conditional probabilities in
Equations (1) through (4) are presented in Ta-
ble 3. In all years except in 2003, the condi-
tional probability of using herbicide-resistant
seed given conservation-tillage practices,
i®(fflC), is greater than the conditional prob-
576
638 Journal Agricultural and Applied Economics, December 2006
Table 3. Conditional Probabilities Showing the Relationships Between Adoption of Herbicide-
Resistant Cotton Seed and Conservation-Tillage Cotton Prodnction Practices, 1998-2004
Conditioi:^
ftobability
1998
1999
2000
2001
2002
2003
2004
P(H|C)
0.169
0.747
0.932
0.968
0.981
0.997
0.999
0.047
0.593
0.668
0.817
0.905
1.000
0.981
P(C|H)
0.674
0.605
0.740
0.805
0.726
0.735
0.785
PiCVi)
0.333
0.431
0.294
0.377
0.331
1.000
0.143
“ P(E\C) rad P(//|C) arc condWonal probabilities of a Tennessee cotton acre being produced with herbicide-resistant
seed IH) given that it is produced with conservation-tillage practices (C> or conventional-tillage practices (C), respec-
tively. P(C/H) and P(C|fl) are conditional probabilities of a Tennessee cotton acre being produced with C given that
it is produced with H or conventional cotton seed (H), respectively.
ability of using herbicide-resistant seed given
conventional tillage practices, P(H\C), which
indicates that cotton farmers who had adopted
conservation-tillage practices had a higher
probability of adopting herbicide-resistant cot-
ton seed than those farmers who had not
adopted conservation-tillage practices. This
finding suggests that diffusion of herbicide-re-
sistant seed technology was faster among
farmers who used conservation-tillage practic-
es than among those who did not. Also, the
gap between P{H\C) and P(H\C) narrows
over time, and in 2003 and 2004 these con-
ditional probabilities are almost equal to each
other and equal to the marginal probability of
adopting herbicide-resistant seed (P(W) in Ta-
ble 2), suggesting that differences in tillage
practices had less influence on the probability
of adopting herbicide-resistant seed in later
years because almost all Termessee cotton
acreage was in herbicide-resistant seed in
2003 and 2004 regardless of tillage method.
Results also suggest that adoption of her-
bicide-resistant cotton seed influenced the
probability of adopting conservation-tillage
practices as indicated by J“(C | /# ) being greater
than P(C\H) every year except 2003 (Table
3). In this case, however, the gap between the
two conditional probabilities does not narrow
over time, indicating that adoption of herbi-
cide-resistant seed continued to have an influ-
ence through time on the probability of adopt-
ing conservation-tillage practices. The
conditional probability of 1 in 2003 resulted
from only 1,088 Tennessee cotton acres being
produced with conventional cotton seed in that
yeaj; all of which were produced with conser-
vation-tillage practices.
Hie Bayes’ results suggest a simultaneous
relationship between adoption of herbicide-re-
sistant cotton seed and adoption of conserva-
tion-tillage practices. These results bode well
for the simultaneity hypothesis in the logit
analysis.
Logit Analysis
Results from the simultaneous logit model es-
timated with three-stage least squares are pre-
sented in Table 4. All coefficients but one have
their hypothesized signs and the high system
weighted-average /f ^ (0.95) suggests a good fit
to the data. Multicollinearity diagnostics
(Beisley, Kuh, and Welsch) indicated collin-
earity between the intercept and CTAC in both
equations. Thus, multicollinearity may have
seriously degraded the standard errors of the
coefficients for CTAC, rendering tiie results
from hypothesis testing inconclusive for those
coefficients (Beisley, Kuh, and Welsch).
Results from the estimation of Equation (9)
in Thble 4 suggest that the probability of
adopting conservation-tillage practices (CAC)
significantly influenced the probability of
adopting herbicide-resistant cotton seed and
results from the estimation of Equation (10)
indicate that the probability of adapting her-
bicide-resistant seed (HAC) significantly influ-
enced the probability of adopting conserva-
tion-tillage practices for Tennessee cotton
production. As suggested by the conditional
probability results in Table 3 and the 1997—
577
Roberts et al.: Herbicide-Resistant and Conservation-Tillage Cotton
ts 00 y-V
? es i « a s
'n , d S o o
^ ♦ ‘w^ *. O O
^ gv 00 -N cn 00 M
t-v o ^ f<J
o o o «/% r»
ri d d o o d d
fc I
S3 i
I o S §
^ S § S
Si p- „ S
7 tJi 02 K
Jp ^ « J_ oi
^ O 00 O
vn p» 'O fn
^ d d d d
{ !
ik d x-N O x-S
*r> ^ ^ xn
*<«• S m vO m >0
vH „ Q ^
o cs tn >©
d d — C'i
i i
639
578
640 Jourrud of Agiicultuml and Applied Economics, December 2006
2004 mean elasticities in Table 4, these influ-
ences are not symmetric. While both elastici-
ties are positive, the number of cotton acres in
herbicide-resistant seed increases (decreases)
by 1.74% for a 1% increase (decrease) in the
probability of adopting conservation-tillage
practices (CAC), while the number of cotton
acres in conservation-tillage practices increas-
es (decreases) by only 0.24% for a 1% in-
crease (decrease) in the probability of adopt-
ing herbicide-resistant seed (HAC).
Results for Equation 9 (Table 4) also in-
dicate that the short-run supply of Tennessee
cotton acreage in herbicide-resistant seed in-
creases (decreases) by 0.78% when the
Roundup Ready cotton seed price decreases
(increases) by 1% relative to the conventional
cotton seed price (RSPR/CSPR) and that the
probability of adopting herbicide-resistant
seed was higher during the 1999-2004 period
than in earlier years when it was not available,
or before sufficient supply of herbicide-resis-
tant seed was produced to meet demand, as
evidenced by the positive coefficient for D.
Findings from Equation (10) suggest that
the short-run supply of Tennessee cotton acre-
age in conservation-tillage increases (decreas-
es) by 0.36% when the price of Roundup de-
creases (increases) by 1% relative to the price
of fuel (RUPR/FUPR) (Tkble 4). In addition,
the finding that the coefficient for RAIN is sta-
tistically significant, while the coefficient for
DRAIN is not, suggests that symmetry exists
in cotton farmers’ response to increases or de-
creases in spring rainfall. The elasticity for
RAIN indicates that conservation-tillage cotton
acreage increases by 0.46% when spring rain-
fall increases by 1% and it decreases by the
same amount when rainfall decreases by 1%,
other things remaining constant. The positive
coefficient for NRAIN suggests that heavy
rainfall in the fall of the previous year increas-
es the probability that cotton farmers will
adopt conservation-tillage practices in the
spring.
Conclusions
Results suggest that the introduction of her-
bicide-resistant cotton seed in Tennessee in-
creased the probability that farmers would
adopt conservation-tillage practices. Along
with the direct benefits of incre^ed profit po-
tential and the substitution of nomesidual her-
bicides for residual herbicides, the introduc-
tion of herbicide-resistant cotton seed
indirectly contributed to increased conserva-
tion of Tennessee soils. This indirect environ-
mental benefit of reduced sod erosion should
not be ignored when considering the costs and
benefits of herbicide-resistant cotton produc-
tion. Also, farmers who had previously adopt-
ed conservation-tillage practices were more
likely to adopt herbicide-resistant cotton seed,
indirectly reducing their use of residual her-
bicides and increasing their profit potential as
they reduced erosion. Thus, the synergistic re-
lationship between adoption of herbicide-re-
sistant cotton seed and adoption of conserva-
tion-tillage practices for cotton production
likely contributed to reduced soil erosion, re-
duced residual herbicide use, and increased
profit during a period of low cotton prices.
[Received September 2005: Accepted April 2006.}
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582
The Economics of
Genetically Modified Crops
Marin Qaim
Department of Agriculnira! Econtwiits and Rural Development,
Georg-Ai^ost-University of Goettingen, 37073 Goettingen, Germany;
email: {nqaiin@iini^De(tingen.de
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i.
1. INTRODUCTION
A genetically modified (GM) crop is a plant used for agricultural purposes into which one
or several genes coding for desirable traits have been inserted through the process of
genetic engineering. These genes may stem not only from the same or other plant species,
but also from organisms totally unrelated to the recipient crop. The basic techniques of
plant genetic engineering were developed in the early 1980s, and the first GM crops
became commercially available in the mid-1990s. Since then, GM crop adoption has
increased rapidly. In 2008, GM crops were being grown on 9% of the global arable land
{James 2008).
The crop traits targeted through genetic engineering are not completely different from
those pursued by conventional breeding. However; because genetic engineering allows for
the direct gene transfer across species boundaries, some traits that were previously difficult
or impossible to breed can now be developed with relative ease. Three categories of GM
traits can be distinguished: Fim-generation GM crops involve improvements in agronomic
traits, such as better resistance to pests and diseases. Second-generation GM crops involve
enhanced quality traits, such as higher nutrient contents of food products. Third-generation
crops are plants designed to produce special substances for pharmaceutical or industrial
purposes.
The potentials of GM crops are manifold. Against the background of a dwindling
natural resource base, productivity increases in global agriculture are important to ensure
sufficient availability of food and other raw materials for a growing population (von
Braun 2007). GM crops can also bring about environmental benefits. Furthermore, new
seed technologies have, in the past, played an important role for rural income growth and
poverty alleviation in developing countries (e.g., Hazell & Ramasamy 1991, Fan et al.
2005). These effects are also expected for GM crops {FAO 2004). Finally, nutritionally
enhanced crops could help improve the health status of consumers (c.g., Bouis 2007,
Unnevchr et al. 2007),
In spite of these potentials, the development and use of GM crops have aroused signif-
icant opposition. Public reservations are particularly strong in Europe, but they have also
spilled over to other countries and regions through trade regulations, public media, and
outreach efforts of antibiotech lobbying groups (e.g., Pinstrup-Andersen & Schioler 2001,
Miller 6c Conko 2004, Herring 2007, Paarlberg 2008). The major concerns are related to
potential environmental and health risks, but there are also fears about adverse social
implications (e.g., Altieri 2001, Friends of the Earth 2008). For instance, some believe that
GM technology could undermine traditional knowledge systems in developing countries.
Given the increasing privatization of crop improvement research and proliferation of
intellectual property rights (IPRs), there are also concerns about the potential monopoli-
zation of seed markets and exploitation of smallholder farmers (e.g., Sharma 2004).
Because GM crops are associated with new potentials and issues, their emergence has
also triggered substantia! research dealing with economic and policy aspects. This article
reviews the available research on the economics of GM crops. Section 2 gives a brief
overv'iew of the status of commercialized GM crops and expected trends for the future.
Then, work related to the analysis of impacts at the micro and macro level is discussed.
Whereas Sections 3 and 4 address impacts of first-generation GM applications, Section 5
refers to second-generation crops from an ex ante perspective. Sections 6 and 7 focus on
consumer acceptance and the economics of regulation, including aspects of biosafety as
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well as food labeling and IPRs. In the concluding section, policy and research implications
are discussed.
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2. STATUS OF GM CROPS
2.1. Commercialized GM Crops
The commercial application of GM crops began in the mid-1990s. Since then, the technol-
ogy has spread rapidly around the world, both in industrialized and developing countries
(Figure 1). In 2008, GM crops were being grown on 125 million ha in 25 countries. The
countries with the biggest share of the GM crop area were the United States (50%),
Argentina (17%), Brazil (13%), India (6%), Canada (6%), and China (3%) (James
2008). Strikingly, among the countries of the European Union (EU), only Spain grows
GM crops on a significant scale. Although a few other EU countries have approved
individual GM technologies, the commercial area is still negligible, because of public-
acceptance problems and unfavorable regulatory frameworks.
In spite of the widespread international use of GM crops, the portfolio of available
crop-trait combinations is still very limited. At present, only a few first-generation tech-
nologies have been commercialized. The dominant technology is herbicide tolerance (HT)
in soybeans, which made up 53% of the global GM crop area in 2008. fTF soybeans are
currently grown mostly in the United States, Argentina, Brazil, and other South American
countries. This technology accounts for 70% of worldwide soybean production.
GM maize is the second-most dominant crop and covered 30% of the global GM area
and 24% of total maize production in 2008 (James 2008). GM maize involves bTF and
insect resistance, partly as separate and partly also as stacked technologies. Insect resis-
tance is based on different genes from the soil bacterium Bacillus thuringiensis (Bt). These
Bt genes control the European corn borer, the corn roorworm, and different stemborers
(Romcis et al. 2008). Bt maize is grown mostly in North and South America, but it is also
planted to a significant extent in South Africa and the Philippines.
Figure 1
Development of the global area using genetically modified crops (1995-2008).
Source: James (2008).
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GM crops with significant area shares also include cotton and canola. Bt cotton with
resistance to bollworms and budworms is particularly relevant in developing countries.
In 2008, India had the largest Bt cotton area with 7.6 million ha, followed by China with
3,8 million ha. South Africa, Argentina, Mexico, and a few other countries use this
technology as well. In the United States, Be and HT cotton are employed, partly with
stacked genes. Until now, HT canola was grown mostly in Canada and the United States.
A few other GM crojw, including HT alfalfa and sugarbeet as well as virus-resistant
papaya and squash, have been approved in individual countries, so far covering only
relatively small areas.
2.2. GM Crops in the Pipeline
A couple of GM technologic previously developed for food crops either were never
commercialized or were withdrawn from the market because of consumer-acceptance
and marketing problems. Examples include Bt and virus-resistant potato as well as HT
wheat. Yet, such technologies may be reintroduced, should public acceptance improve. A
number of other GM crop technologies that provide insect resistance or HT are ready to
be commercialized. For instance, Bt rice has been field tested extensively in China and
other countries (Huang et al. 2005, Cohen et al. 2008). Different Bt vegetables — including
eggplant, cauliflower, and cabbage — are likely to be commercialized soon in India and
other countries in Asia and Africa (Krishna & Qaim 2007, Shelton et al. 2008). HT rice is
also in a relatively advanced phase within the research and development (R&D) pipeline
(Hareau et al. 2006).
Other first-generation GM technologies that are being developed include fungal, bacte-
rial, and virus resistance in major cereal as well as root and tuber crops (Halford 2006).
Their market introduction can be expected in the short to medium run. Plant tolerance to
abiotic stress — such as drought, heat, and salt — is also being worked on intensively. Yet,
because the underlying genetic mechanisms are complex, the work is at a more basic level,
so significant commercial releases can be expected only in the medium run (Herdt 2006,
Ramasamy et al. 2007).
Second-generation GM technologies in the pipeline include product quality improve-
ments for nutrition and industrial purposes. Examples are oilseeds with improved
fatty acid profiles; high-amylose maize; staple foods with enhanced contents of essential
amino acids, minerals, and vitamins; and GM functional foods with diverse health benefits
(Jefferson-Moore & Traxler 2005, Pew Initiative on Food and Biotechnology 2007).
Enhancing food crops with higher nutrient contents through conventional or GM
breeding is also called biofortificarion. A well-known example of a GM biofortified crop
is Golden Rice, which contains significant amounts of provitamin A. Golden Rice could
become commercially available in some Asian countries by 2012 (Stein et al. 2006,
Pocrykus 2008). Other biofortification projects include the development of GM sorghum,
cassava, banana, and rice enhanced with multiple nutrients (Qaim et al. 2007). Such crops
may become commercially available over the next 5-10 years.
Third-generation GM crops involve molecular farming where the crop is used to
produce either pharmaceuticals such as monoclonal antibodies and vaccines or industrial
products such as enzymes and biodegradable plastics (Moschini 2006, Halford 2006).
Although concepts have been proven for a number of these technologies, product develop-
ment and regulatory aspects are even more complex than they are for first- and second-
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generation crops. Substances produced in the plants must be guaranteed not to enter the
regular food chain with a zero-tolerance threshold. TTierefore, plants that are not used for
food and feed purposes will likely be chosen for product development, or approvals for
third-generation GM crops will be given for use under contained conditions only. In either
case, this brief overview reveals that the GM crops available so far represent only a very
small fraction of the large future potentials of plant genetic engineering.
3. MICROLEVEL IMPACTS OF FIRST-GENERATION GM CROPS
Because HT and insect-resistant Bt crops have already been used for a number of years,
numerous microlevel impact studies have been carried out in different countries. Many
such studies are based on random sample surveys, comparing the performance of adop-
ters and nonadopters of GM crops (Kalaitzandonakes 2003, Naseem & Pray 2004,
Qaim 2005, Gandhi & Namboodiri 2006). However, such with-without comparisons
can be associated with a selectivity bias. On the one hand, if adopting farmers are more
skillful than their nonadopting counterparts, the net technological impacts may be over-
estimated, because the group of adopters may show better performance even without
GM technology. On the other hand, if the technology is adopted only by farmers under
specific conditions, net impacts may be underestimated. For instance, Bt technology is
expected to be particularly beneficial in high pest pressure environments. Therefore,
simply comparing the productivity of adopters in high pest pressure environments with
that of nonadopters in low pest pressure environments would lead to a downward bias in
impact assessment.
Different approaches have been used to reduce a potential selectivity bias. For instance,
some authors have observed developments over time, involving several rounds of data
collection (e.g,, Pray et ai. 2002, Sadashivappa & Qaim 2009). Others have combined
survey data of GM farmers with calculations of what would have been without technology
adoption {e.g., Gianessi et al. 2002, Brookes & Barfoot 2008). In addition, within-farm
comparisons have been made in situations where adopting farmers continued to use
conventional crops on part of their land (e.g., Qaim &c de Janvry 2005). Econometric
approaches to deal with selectivity issues are explained below.
3.1. Farm-Level Impacts of HT Crops
HT crops are tolerant to certain broad-spectrum herbicides such as glyphosate and glufo-
sinate, which are more effective, less toxic, and usually cheaper than selective herbicides.
Accordingly, farmers who adopt HT technology benefit in terms of lower herbicide
expenditures. Total herbicide quantities applied were reduced in some situations, but not
in others. In Argentina, herbicide quantities were increased .significantly {Qaim & Traxler
2005), in large part owing to the fact that herbicide sprays were substituted for tillage. In
Argentina, the share of soybean farmers using no-till doubled to almost 90% since the
introduction of HT technology {Trigo &C Cap 2006), whereas in the United States and
Canada, no-till practices expanded through HT adoption (Kalaitzandonakes 2003, Fer-
nandez-Comejo & Caswell 2006). In terms of the yields achieved, no significant difference
between HT and conventional crops is seen, in most cases. Only in a few examples when
certain weeds were difficult to control with selective herbicides did the adoption of HT
and the switch to broad-spectrum herbicides result in better weed control and higher crop
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yields. These include HT soyb^ns in Romania and HT maize in Argentina (Brookes &
Barfoot 2008).
Overall, HT technology reduces the cost of production through lower expenditures for
herbicides, labor, machinery, and fiiel. Yet, because HT crops were developed and com-
mercialized by private companies, a technology fee is charged on seeds, which varies
among crops as well as coimtries. Several early studies for HT soybeans in the United
States showed that the fee was of a similar magnitude or sometimes higher than the
average cost reduction, so that gross margin effects were small or partly negative (e.g.,
Duffy 2001, Fernandez-Comejo et al. 2002). Comparable results were also obtained for
HT cotton and HT canola in the United States and Canada (Fulton & Keyowski 1999,
Marra et al. 2002, Phillips 2003, Nascem & Pray 2004). The main reasons for farmers in
such situations to continue using HT technologies were easier weed control and savings in
terms of management time. Fernandez-Cornejo et al, (2005) showed that the saved man-
agement time for U.S. soybean farmers translated in part into higher off-farm incomes.
Moreover, farmers are heterogeneous, such that many adopters have benefited in spite of
zero or negative mean gross margin effects. The average farm-level profits seem to increase
over time, partly as a result of seed-price adjustments and farmer-learning effects.
In South American countries, the average gross margin effects of HT crops, especially
HT soybeans, are larger than in North America (Trigo & Cap 2006). While the agronomic
advantages are similar, the fee charged on seeds is lower, as HT technology is not patented
there. Many soybean farmers in South America use farm-saved GM seeds. Qaim Sc
Traxler (2005) showed that the average gross margin gains through HT soybean adoption
are in a magnitude of more than $20 per ha for Argentina.
3.2. Farm-Level Impacts of Bt Crops
Insect-resistant Be crops have different effects than do HT crops. Bt crops produce pro-
teins that are toxic to larvae of some lepidopteran and coleopteran insect species. There-
fore, Bt is a pest-control agent that can be used as a substitute for chemical insecticides.
Following Lichtenberg & Zilberman (1986) and Zilberman et al. (2004), this can be
expressed in a damage-control framework:
y = F(x)[l-D(z,Bi;N)],
where Y is the effective crop yield, and F( )is potential yield without insect damage, which
depends on variable inputs, x. D( )is the damage function determining the fraction of
potential output being lost to insect pests; it can take values in the 0-1 interval. Crop
losses depend on exogenous pest pressure, N, and they can be reduced through the
application of chemical insecticides, z, and/or the use of Bt technology. If pest pressure is
high and farmers use a lot of chemical insecticides in the conventional crop, Bt adoption
should lead to substantial insecticide reductions.^ However, Bt technology can also impact
effeaive crop yields. Even though the Bt gene does not affect potential yield, F(-), it can
lead to a reduction in crop losses, D{ ), when there is previously uncontrolled pest dam-
age, thus leading to a higher Y.
'Pemsl et a!. (2008) pointed out that natural pest-control agents such as beneficial insects could also reduce crop
losses but that these are often suppressed throu^ chemical insecticides. Therefore, even without Bt, a reduction in
chemical insecticides may be possible in specific situations. However, compared with chemical insecticides, Bt is
much less harmful to beneficial inse<^ (Shelton et al. 2009).
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Insecticide reduction and yield eififecK are closely related: Farmers who use small
amounts of insecticides in their conventional crop in spite of high pest pressure will realize
a sizeable yield effect through Bt adoption, whereas the insecticide reduction effect will
dominate in situations when farmers initially use higher amounts of chemical inputs. The
same principles also hold for other pest-resistant GM crops. In general, yield effects will be
more pronounced in developing rather than in developed countries, because pest pressure
is often higher in the tropics and subtropics and resource-poor farmers face more severe
constraints in chemical pest control (Qaim & Zilberman 2003).
3.2.1. Empirical evidence. The Bt-insecticide-yield linkages are diagrammed in Figure 2
using field trial data with Bt cotton in India. As shown, Bt does not completely eliminate
the need for insecticide sprays because some crop damage still occurs when the technology
is used. The reason is that Bt toxins are very specific to certain pest species, whereas other
insect pests, especially sucking pests, remain unaffected.
What do the agronomic impacts look like under practical farmer conditions? Table 1
confirms that both inseaicide-reducing and yield-increasing effects can be observed
internationally. Yield effects of Bt cotton are highest in Argentina and India. For Argen-
tina, the explanation is simple: Conventional cotton farmers underutilize chemical insec-
ticides, so that insect pests are not effectively controlled (Qaim & de janvry 2005). In
India, however, insecticide use in conventional cotton is much higher (Qaim et al. 2006).
This suggests that factors other than insecticide quantity influence damage control in
conventional cotton and, thus, the yield effects of Bt technology. These factors include
insecticide quality, insecticide resistance, and the correct choice of products and timing of
sprays.
For Bt maize, similar effects are observable, albeit generally at a lower magnitude
(Table 1 ). Except for Spain, where the percentage reduction in insecticide use is large, the
more important result of the use of Bt maize is an increase in effective yields. In the United
States, for instance, Bt maize is used mainly against the European corn borer, which is not
Insecticide (amount of active ingredients in kg/ha)
Figure 2
Relationship between insecticide use and cotton crop losses with and without Bt in India.
Source: Qaim & Zilberman (2003).
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589
Tnl>Ic 1 ,'\vcr.^sic f:irm-lo\c! acronomic and ecoaoinic effects of Bt CTOps
Y-Ji-ySr-Arr-,-
■
Bt cotton
Argentina
47 !
33
23
Qaim & de Janvry 2003, 2005
Australia
48
0
66
Fitt 2003
China
65
24
470
Pray et al. 2002
India
41
37
135
Qaim et a!. 2006, Sadashivappa &C
Qaim 2009
Mexico
77
9
295
Traxler et al. 2003
South
Africa
33
22
91
Thirtic ct al. 2003, Gouse ct a!. 2004
United
States
36
10
58
Falck -Zepeda et al. 2000b, Carpenter
et al. 2002
Bt maize
Argentina
0
9
20
Brookes Sc Barfoot 2005
Philippines
5
34
53
Brookes & Barfoot 2005, Yorobe &
Quicoy 2006
10
11
42
Brookes Sc Barfoot 2005, Gouse et a!.
2006
63
6
70
Gomez-Barbero et al. 2008
United
States
8
5
12
Nascem Sc Pray 2004, Femandez-
Cornejo & Li 2005
often controlled by chemical means {Carpenter et al. 2002).^ In Argentina and South
Africa, mean yield effects are higher because pest pressure is more severe than it is in
temperate climates. The average yield gain of 11% shown in Table 1 for South Africa
refers to large commercial farms. These farms have been growing yellow Be maize hybrids
for several years. Gousc ct al. (2006) analyzed on-farm trials that were carried out with
smallholder farmers and white Bt maize hybrids in South Africa. They found average yield
gains of 32% on Bt plots. In the Philippines, average yield advantages are 34%.
Preliminary evidence based on field-trial observations also exists for other Bt crops.
Huang et al. (2005) observed high insecticide reductions but relatively small yield effects
for Bt rice in China, whereas Krishna 8c Qaim (2008b) reported significant insecticide and
yield effects for Bt eggplant in India.
^Morc recently, a different Bt mai2e technology has been commercialized in the United States to control the corn
rootworm complex, agaimt which significant amounts of chemical insecticides arc used in conventional agriculture.
However, representative studies on the impacts of this new Bt maize technology under farmer conditions are not
available.
672 Qaim
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590
o
a.
.o
3.2.2. Econometric estimates. Econometric analyses with different model specifications
confirm the net insecticide-reducii^ and yield-increasing effects of Bt technology. For Bt
maize, Fernandez-Cornejo & Li (2005) provided estimates for the United States, and
Yorobe & Quicoy (2006) did so for the Philippines. More studies are available for Bt
cotton: Huang et al. (2002a) employed an insecticide-use model and a production function
with a damage-control specification to estimate the effects in China. A similar analysis
was done by Qaim & de Janvry (2005) in Argentina. Bennett et al. (2006) estimated
Cobb-Douglas-type production hinctions for a sample of farmers in India.
Qaim et al. (2006) also estimated productivity effects of Bt cotton in India, differentiat-
ing between Bt gene and germplasm effect. They showed that part of the impact varia-
bility observed in India during the first years of adoption was due to the incorporation of
the Bt gene in only a few cotton varieties that were not suitable for all locations. In such
situations, a yield drift can be observed; that is, the positive Bt gene effect is counteracted
by a negative germplasm effect. This underlines the finding that the benefits of GM can be
fully realized only when the technology is inserted into a number of locally adapted
varieties.
Thirtle et al. (2003) used a stochastic frontier approach with data from farmers in
South Africa to show that Bt adoption helps to increase the technical efficiency of cotton
production in the small-farm sector. Kambhampati et al. (2006) did a similar analysis for
India. Many of these econometric analyses used instrumental variable approaches to avoid
or reduce selectivity issues and problems of endogeneity. One study by Crost et al. (2007)
also used panel data techniques for the estimation of Bt productivity effects.
I
3
X>
3.2.3. Gross mai^in effects. The gross margin effects of Bt technologies are also shown in
Table 1, In all countries noted, Bt-adopting farmers benefit; that is, the economic advan-
tages associated with insecticide savings and higher effective yields more than outweigh
the technology fee charged on GM seeds. The absolute gains differ remarkably among
countries and crops. On average, the gross margin gains are higher for Bt cotton than
for Bt maize, and they are also higher in developing as opposed to developed countries.
In addition to agroecological and socioeconomic differences, the GM seed costs are
often lower in developing countries, owing to weaker IPRs, seed reproduction by
farmers, subsidies, or other types of government price interventions (Basu & Qaim 2007,
Sadashivappa 6c Qaim 2009).
Agricultural policies are also partly responsible for the different gross margin effects.
For instance, in the United States, China, and Mexico, the cotton sector is subsidized,
which encourages intensive production schemes and high overall yields. The situation is
similar for maize in Spain. By contrast, Argentinean farmers are not subsidized; instead,
they face world-market prices. Especially for cotton, world-market prices have been de-
clining over the past 10 years, thus eroding the economic benefits resulting from techno-
logical yield gains. Furthermore, within countries, farmer conditions are heterogeneous so
that the effects are variable (Qaim et al, 2006, PemsI & Waibel 2007).
3.3. Poverty and Distribution Effects
Seventy-five percent of all poor people in the world are smallholder farmers or rural
laborers. Therefore, GM crops may also have important implications for poverty and
income distribution in developing countries. If only rich farmers were to benefit, inequality
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591
would increase. Yet, if resource-poor farmers could access GM crops suitable for their
situations, the poverty and equity effects may be positive. Apart from technological char-
acteristics, this also depends on the institutional setting at national and local levels (Qaim
et al. 2000, Evenson et al. 2002). For instance, strong IPRs and high seed prices as well as
information, credit, and infrastructure constraints can hinder poor farmers’ proper access
to GM seeds, even if the underlying technology is suitable for smallholder agriculture (e.g.,
Qaim & de Janvry 2003, Thiitle et al. 2003, Qaim 2005, Edmeades & Smale 2006).
So far, HT crops have not been widely adopted in the small-farm sector. Smallholders
often weed manually, so that HT crops are inappropriate, unless labor shortages or weeds
that are difficult to control justify conversion to chemical practices. The situation is very
different for Bt crops. Especially in China, India, and South Africa, Bt cotton is often
grown by farms with less than 3 ha of land (Huang et al. 2002a,b; Qaim et al. 2008). In
South Africa, many smallholders grow Bt white maize as their staple food (Gouse et al.
2006). Several studies show that Bt technology advantages for small-scale farmers are of a
similar magnitude as those of larger-scale producers. In some cases, the advantages can be
even greater (Pray et al. 2001, Morse et al. 2004, Qaim et al. 2008}.^
However, few studies exist that have analyzed wider socioeconomic outcomes, includ-
ing effects on rural employment and household incomes. This dearth of broader microievel
research may the reason for the ongoing controversy surrounding the poverty and rural
development implications of GM crops. Subramanian & Qaim {2009a, b) provide the first
comprehensive work in this direction. Building on a village social accounting matrix and
multiplier model, they examined direct and indirect effects of Bt cotton adoption in India.
Their results show that the technology is employment generating, especially for hired
female agricultural laborers, which is due to significantly higher yields in need of harvest-
ing. The technology also generates employment in other sectors linked to cotton produc-
tion, e.g., trade and services.
Simulated impacts on household incomes are shown in Figure 3. Each additional
hectare of Bt cotton produces 82% higher aggregate incomes than are obtained from
conventional cotton, implying a remarkable gain in overall economic welfare through
technology adoption in India. For landless households, the positive income effects are
relatively small. More female employment for cotton harvesting is counteracted by less
male employment for spraying operations. However, all types of farm households — in-
cluding those below the poverty line — benefit considerably more from Bt than from
conventional cotton. These findings demonstrate that GM crops can contribute signifi-
cantly to poverty reduction and rural development, when they are suited to the small-farm
sector and embedded in a conducive institutional environment.
3,4. Environmental and Health Effects
In addition to the economic and social impacts of GM crops, there are also environmental
and health implications. In the public debate, potential environmental risks, such as
undesirable gene flow or impacts on nontarget organisms, arc often in the fore. Food
safety concerns are also raised. Shelton et al. (2009), Weaver & Morris (2005), and
’Especialiy for India, bioiech critics still report that Bt cotton ruins smallholder farmers. However, such reports do
not build on representative data (Qaim et al. 2006, 2008). Gruere et al. (2008) showed that the occasional claim of
a link between Bt cotton adoption and farmer suicides cannot be substantiated.
674 Qaim
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592
CO
o
IS
Q
I
a
50Q
r
■C:
r; 20r>
m
0
Figure 3
Household income effects of Bt cotton compared with conventional cotton in India. The results are
based on simulations with a social accounting matrix and multiplier model for a typical cotton-
growing village in the Indian state of Maharashtra. Two simulations were run, both considering an
expansion in the village cotton area by 1 ha. The first scenario assumes that the additional hectare is
cultivated with Bt cotton, whereas the serond assumes that it is cultivated with conventional cotton.
Accordingly, differences between the two scenarios can be interpreted as net impacts of Bt technology
adoption. Adapted from Subramanian & Qaim (2009a).
Bradford et ai. (2005) have reviewed such risks, concluding that most are not specific to
the technique of genetic modification but would be present for any conventionally produced
crops with the same heritable traits. Although potential risks need to be further analyzed and
managed, GM crops can also induce substantial environmental and health benefits.
I-....
Landless Poor formers Vulnerable Rich farmers
farmers
Total
3.4.1. Environmental benefits. Adoption of HT crops does not lead to reductions in herbi-
cide quantities in most cases, but selective herbicides, which are often relatively toxic to the
environment, are substituted by much less toxic broad-spectrum herbicides. Moreover,
tillage operations are cut and no-till practices expanded, helping to reduce soil erosion, fuel
use, and greenhouse gas emissions (Qaim & Traxler 2(X)5, Brookes 8c Barfoot 2008).
For Bt crops, the main environmental benefits are related to reductions in chemical
insecticide applications. Reductions in pesticide use have been particularly significant in
cotton, the most pesticide-consuming crop worldwide. Brookes & Barfoot (2008) esti-
mated that between 1996 and 2006 Bt cotton was responsible for global savings of 128
million kg of pesticide active ingredients, reducing the environmental impact of total
cotton pesticides by 25%. Figure 4 shows that Bt adoption leads to overproportional
reductions in the most toxic insecticides.
In the first years of Bt crop deployment, it was predicted that insect populations would
soon develop Bt resistance, which would undermine the technology’s effectiveness and
lead to declining insecticide reductions over time. However, until now, Bt resistance has
not been observed under field conditions, which may be due to successful resistance
management strategies, such as the planting of non-Bt refuges (Hurley et ai. 2001, Bates
et al. 2005). In countries where no such strategies are implemented, Bt resistance has also
not been reported. However, other factors can lead to changes in Bt effects over time.
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593
I
India Argenluia
0%
- 20 %
-40%
-80%
-80%
- 100 %
Figure 4
Insecticide reductions through Bt cotton by toxicity class. Results ate based on within-farm compar-
isons obtained from surveys in different cotton-growing regions of India and Argentina. Following the
international classification of ^sticides, toxicity class I comprises the most toxic products, whereas
toxicity class IV comprises the least toxic products. Based on data from Qaim Sc Zilberman (2003),
Qaim et al. (2006), and Qaim Sc de Janvry (2005).
In China, for instance, insecticide applications increased again after several years of Bt
cotton use, in spite of the absence of Bt resistance. Wang et al. (2006) attributed this to
secondary pests, which may have become more important through the Bt-induced reduc-
tion in broad-spectrum insecticides. Their analysis, however, was based on only one year
of observations with increased insecticide applications, making conclusive statements pre-
mature (Hu et al. 2006). Using data collected over a period of five years, Sadashivappa 8c
Qaim (2009) did not find any evidence of secondary-pest outbreaks in India,
GM crops may also help preserve agrobiodiversity. Conventional breeding leads to new
crop varieties. If a particular new variety produces a large productivity gain, it may spread
widely, potentially replacing a large number of older varieties and landraces. This oc-
curred to some extent during the Green Revolution in Asia (Cooper et at. 2005). Develop-
ing additional conventional varieties with similar characteristics can be a long and costly
process. In contrast, the development of GM traits through genetic engineering can be
backcrossed at moderate costs into numerous varieties.'' Therefore, instead of replacing
local varieties, GM versions of these varieties can be made available. Indeed, in most
countries where GM technologies have been commercialized, a large number of varieties
carrying specific GM traits can be observed (e.g., Qaim 2005, Trig© &C Cap 2006, Qaim
et al. 2008). More than a technical question, the impact of GM technologies on varietal
diversity depends on the design of IPR and biosafety policies, breeding capacities, and
other institutional conditions (Zilberman et al. 2007).
3.4.2. Health benefits. GM crops, especially Bt crops, are also associated with health
benefits. Direct health advantages for farmers arc a result of less insecticide exposure
’’This is also one reason why genetic engineering is a complementary tool and not a substitute for conventional
breeding. GM traits will always have to be incorporated into locally adjusted germplasm.
class I OToxicttydassIl SToxlcity class lU & IV
6j6 Qaim
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during spraying operations. Often, the health hazards for farmers applying pesticides are
greater in developing as opposed to developed countries because environmental and health
regulations are more lax, most pesticides are applied manually, and farmers are less
educated and less informed about negative side effects. Pray et al. (2001) and Huang
et al. (2003) showed that the frequency of pesticide poisonings was significantly lower
among Bt cotton adopters than among nonadopters in China. Hossain et al. (2004) used
econometric models to establish that this observation is causally related to Bt technology.
Bennett et al, (2003) made the same observation for Bt cotton in South Africa, and there is
first evidence that similar effects can also be expected for other Bt crops in smallholder
agriculture, such as Bt rice in China (Huang et al. 2005, 2008). Using econometric
estimates and a cost-of-illness approach, Krishna & Qaim (2008b) projected that Bt egg-
plant in India may produce farmer health benefits worth approximately $4 million per year.
For consumers, Bt crops can yield health benefits through lower pesticide residues in
food and water. Furthermore, in a variety of field studies, Bt maize was shown to contain
significantly lower levels of certain mycotoxins, which can cause cancer and other diseases
in humans (Wu 2006). Especially in maize, insect damage contributes significantly to
mycotoxin contamination. In the United States and other developed countries, maize is
carefully inspected, so lower mycotoxin levels may be most responsible for reducing the
costs of testing and grading. But in many developing countries, strict mycotoxin inspec-
tions are uncommon. In such situations, Bt technology could contribute to lowering the
total health burden (Wu 2006, Qaim et al. 2008).
4. MACROLEVEL IMPACTS OF FIRST-GENERATION GM CROPS
Numerous studies using macrolevel economic surplus models have analyzed the broader
welfare effects of GM crops. When the market of only one single crop is considered,
partial equilibrium models are used, whereas general equilibrium models are employed
when indirect effects and spillovers to other markets and sectors are also of interest.
4.1. Partial Equilibrium Approaches
Whenever new crop technologies are adopted on a large scale, the productivity increase
will cause the crop’s supply curve to shift downward, leading to a change in producer and
consumer surplus (Alston et al. 1995). Because most GM technologies currently available
have been commercialized by the private sector, technology rents accrued by innovating
companies need to be considered (Moschini & Lapan 1997).
Price et al. (2003) estimated that in the late 1990s Bt cotton generated a total annual
economic surplus gain of approximately $164 million in the United States, of which 37%
was captured by farmers, 18% by consumers, and 45% by the innovating companies.
Falck-Zepeda et al. (2000b) also reported similar results. Because Bt cotton adoption in
the United States has increased since then, absolute surplus gains are higher today, but
relative surplus distribution remains approximately the same (Fernandez-Cornejo &c
Caswell 2006).
For Bt cotton in China, Pray et al. (2001) estimated economic surplus gains of approxi-
mately $140 million in 1999, with only 1.5% going to the innovating companies and the
rest captured by farmers. IPR protection in China is weak, and use of farm-saved Bt
cottonseeds is widespread. Under these conditions, it is difficult for companies to capture
innovation rents. Cotton consumers did not benefit in 1999 because the government
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595
controlled output markets, thus preventing a price decrease. Recently, markets have been
liberalized, so Chinese consumers now benefit from Bt cotton technology. In India, Bt
cotton surplus gains were projected at $315 million for 2005 (Qaim 2003). Because cotton
prices there are not fully liberalized, consumer benefits were not considered. Farmers
capture two thirds of the overall surplus gains; the rest accrues to biotech and seed
companies. Bt cotton in India is commercialized in hybrids, so use of farm-saved seeds is
low. Thus, the private sector innovation rent is higher than in China.
For Bt maize in the United States, Wu (2002) estimated a total surplus gain of $334
million in 2001. Approximately half of the gain accrued to producers, followed by indus-
try profits (31%). The consumer share was relatively small. For Bt maize in Spain,
Demont & ToIIens (2004) calculated welfare gains of approximately $2 million in
2003, of which 60% went to farmers and 40% to seed companies. The relatively low
absolute gain is due to the fact that Bt maize in 2003 covered only an area of approxi-
mately 25,000 ha. Similar effects were shown during the early years of Bt maize adoption
in the Philippines (Yorobe & Quicoy 2006).
A number of studies have examined the partial equilibrium effects of FIT soybeans
(e.g., .Mo.schini et al. 2000, Falck-2^peda et al. 2000a, Qaim & Traxlcr 2005). Most of
these studies use multiregion models. Worldwide welfare gains of HT soybeans were on
the order of US$1 billion in the late 1990s. Gains have grown since then as a result of
increased adoption. At the global level, downstream sectors and consumers are the main
beneficiaries, capturing more than 50% of surplus gains. The effects vary strongly by
country, however. Within the United States, farmers capture approximately 20% of the
national welfare gains versus almost 60% accruing to Monsanto as the innovating compa-
ny. By contrast, in Argentina, the farmer surplus share is 90%. These differences are
largely due to different levels of IPR protection (Qaim 6c Traxler 2005).
In addition to such ex post studies, ex ante snidics for GM crops have also been carried
out in different countries. Examples include analyses for Bt maize and different HT crops
in the EU (Demont et a!. 2004, 2008), HT rice in Uruguay (Hareau et al. 2006), Bt
eggplant in India (Krishna 6c Qaim 2008b), drought-tolerant rice in India and Bangladesh
(Ramasamy ec al. 2007), and virus- and Insect-resistant sweet potato in Kenya (Qaim
2001). These ex ante studies confirm that GM crops can bring about sizeable welfare
gains, with distributional effects dependent on IPRs and other institutional conditions.
4.2. General Equilibrium Approaches
I Many of the available general equilibrium studies use the multiregion computable general
equilibrium (CGE) model and associated database of the Global Trade Analysis Project
(Henel 1997). This model captures the vertical and horizontal linkages between markets
within regions and between regions via bilateral trade flows. The results of several global
impact studies are summarized in Table 2.
Bt cotton adoption entails global welfare gains in the range of $0.7-1. 8 billion per year.
The differences across studies partly reflect the use of different versions of the basic model.
More importantly, however; the assumed technology adoption rates in different regions
matter. Because Bt adoption continues to increase, the aggregate welfare gains are increas-
ing too. Most CGE studies for Bt cotton to date found the biggest regional welfare effects
occurred in China (e.g., Huang et al. 2004, Frisvold 8c Reeves 2007), but India, where the
technology was commercialized later; has been catching up rapidly. Anderson et al. (2008)
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Table 2 Projected global welfare gains from GM crops (CGE model results)''
1 u-m
Frisvold 5c Reeves (2007)
Bt cotton
2005
1.4 billion
Elbehri 8c MacDonald (2004)
Bt cotton
2001
1.8 billion
Anderson & Yao (2003)
Bt cotton
2005
1.4 billion
Anderson et al. (2008)
Bt cotton
2001
0.7 billion
Nielsen & Anderson (2001)
GM oilseeds and maize
-
9.9 million
Anderson Sc Yao (2003)
GM soybean and maize
—
7.0 billion
Hareau et al. (2005)
Bt rice
-
2.2 billion
Hareau et al. (2005)
Drought-tolerant rice
—
2.5 billion
Hareau et al. (2005)
HT rice
—
2.1 billion
Anderson 8c Yao (2003)
GM rice
-
2.0 billion
^Abbreviations: CGE, coniput.able genera) equilibrium; GM, genetically modified; HT, herbicide tolerant.
estimate that widespread adoption of Bt cotton in India and other countries of South Asia
will result in additional regional welfare gains on the order of $1 billion per year.
Larger international markets result in bigger effects for GM oilseeds and maize. With
widespread international adoption of HT and insect resistance in these crops, annual
welfare gains could be approximately $10 billion (Nielsen & Anderson 2001). A ban on
production and imports by the EU, however, could reduce these global gains by two thirds,
because of foregone benefits for domestic consumers and the far-reaching influence of EU
policies on international trade flows and production decisions in exporting regions
(Tothova 8c Oehmke 2005).
For GM rice, large global welfare gains are projected as well. For other rice technolo-
gies, such as Bt, HT, and drought tolerance, and assuming moderate adoption levels in
rice-producing regions, Hareau et al. (2005) estimated global welfare gains of $2. 1-2.5
billion per year, with India and China gaining the most. Huang et al. (2004) projected that
the welfare gains in China alone could reach over $4 billion when different first-generation
GM rice technologies are widely adopted. The studies available to date provide lower bound
estimates of the global welfare effects of GM crops, because positive environmental and
health externalities have not been properly quantified.
5. POTENTIAL IMPACTS OF SECOND-GENERATION GM CROPS
First-generation GM crops involve direct productivity and income effects, which can be
evaluated at the micro level and then integrated into macrolevel modeling approaches.
Second-generation crops, which involve enhanced quality attributes, must be evaluated
differently. Quality improvements generally lead to a marginal utility increase and a higher
willingness to pay (WTP) among consumers. In a market model, this can be represented as
an upward shift in the crop’s demand function. There are no ex post impact studies
available for second-generation GM crops, because such crops have not been widely
adopted. However, several authors have carried out conceptual analyses and ex ante
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simulations of the welfare effects imder different conditions in developed countries (e.g.,
Jefferson-Moore & Traxler 2(X)5, Giannakas &c Yiannaka 2008}.
In developing countries, the situation is different, especially when looking at technolo-
gies that are targeted to the pooi; such as biofortified GM crops. Widespread production
and consumption of biofortified staple crops could reduce micronutrient deficiencies,
improve health outcomes, and provide economic benefits (Bouis 2007). Yet, it is uncertain
if they would command higher market prices, because the poor are often not aware of
their micronutrient deficiencies and may not be willing or able to pay a quality premium.
Therefore, biofortified crops in developing countries may not lead to an upward shift in
demand, so social welfare effects must be evaluated differently (Qaim et al. 2007).
Dawe et al. (2002) looked at the potential nutritional effects of Golden Rice by analyz-
ing likely improvements in vitamin A intakes in the Philippines. This approach implicitly
builds on a measure of program success that has been used for other micronutrient inter-
ventions, namely the achieved reduction in the number of people with micronutrient
intakes below a defined threshold. However, since micronutrient intake is not an end in
itself but only a means to ensure healthy body functions, it is more appropriate to go
further and quantify health outcomes directly. Zimmermann & Qaim (2004) and Stein
et al. (2006) suggested an alternative approach in their analyses of the potential health
benefits of Golden Rice. They defined the benefit of the technology as the difference in
health costs related to vitamin A deficiency with and without Golden Rice.
In their ex ante analysis, Stein et al. (2008) used representative household data from
India to show that Golden Rice could reduce the health costs of vitamin A deficiency by up
to 60%. They also calculated a high cost-effectiveness of Golden Rice, which compares
favorably with other nutrition and health interventions, and a high social rate of return,
which compares favorably with other agricultural R&D investments (Qaim et al. 2007).
Anderson et a!. (2005) used a macro CGE model to simulate the benefits of Golden Rice at
the global level. Modeling consumer health effects among the poor as an increase in the
productivity of unskilled laborers, they estimated worldwide welfare gains of over $15
billion per year, with most of the benefits accruing in Asia. In China, for instance, Golden
Rice was projected to entail a 2% growth in national income (Anderson et al. 2005).
Significant economic and health benefits can also be expected for other biofortified
crops, such as iron- and zinc-dense staple foods or crops containing higher amounts of
essential amino acids (Qaim et al. 2007). The potentially high cost-effectiveness of biofor-
tification in developing countries is due to the fact that the approach is self-targeting to the
poor, with biofortified seeds spreading through existing formal and informal distribution
channels. However, possible issues of consumer acceptance must be considered. Especially
when no price premium is paid in the output market, suitable strategies to convince farm-
ers to adopt such crops are needed. A combination of quality traits with interesting
agronomic traits may be a practicable avenue.
6. CONSUMER ACCEPTANCE OF GM CROPS
In spite of the great potential of GM crops and the benefits that have already materialized,
public attitudes toward the technology are often negative, and consumer acceptance
remains an issue.^ Consumer perceptions are often dominated by health, environmental,
^This is in contrast to pharmaceutical applications of GM technologies, which are widely accepted by the public.
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social, and ethical concerns, which are not always based on the best information but
which have emerged as important driving forces of biotechnology policies (Miller &
Conko 2004, Paarlberg 2008). One rcason for the partial acceptance may be that most
GM crops now available involve agronomic traits with limited direct benefits to consu-
mers. Consumer acceptance may increase when second-generation, quality-enhanced GM
foods or crops with combined agronomic and quality traits are introduced.
Aspects of GM crop acceptance have widely analyzed in the literature; most studies
determine consumers’ WTP for GM-free foocb or the willingness to accept a discount for
GM foods. These findings help us understand the values consumers attach to the GM
attribute especially in the absence of observable market data. There are two approaches used
for estimating WTP. The first approach involves choice modeling or contingent valuation
surveys to obtain stated-preference data from consumers. Most of the available studies for
GM crops build on this approach, both in developed (e.g., Lusk 2003, McCluskey et al.
2003, Moon & Baiasubramanian 2004) and developing countries (e.g., Kimenju & De
Groote 2008, Krishna & Qaim 2008a). The advantage of stated-preference surveys is that
representative data can be obtained. The disadvantage, however, is the potential hypothetical
bias, as consumers state their preferences without any direct financial implications. The
second approach avoids this bias through experimental auctions, although samples are
usually smaller and not representative of the total population. The experiments are often
designed such that participants bid with real money or are presented with opportunities to
exchange a given GM product for a corresponding GM-free product or vice versa. Such
experimental auctions have been used for analyzing consumer acceptance in the United States
and the EU (e.g., Huffman ct al. 2003, Lusk et al. 2006).
Lusk et al. (2005) provide a meta analysis, regressing the WTP results from individual
studies on a set of explanatory variables. Across all studies in the analysis, the weighted
mean WTP for GM-free products is a premium of 23% more than that for GM products.
However, remarkable differences arise. The WTP is significantly higher in Europe than in
the United States, and it is significantly lower for processed than for fresh GM foods.
Studies using experimental auctions result in a lower WTP for GM-free foods on average.
Individual analyses also show a significant influence of consumer characteristics such as
age, education, income, or gender, but the direction of the influence is not uniform.
A difference in WTP for GM and GM-free products indicates that many consumers
do not consider these options as perfect substitutes. In that case, introducing GM
technology would be associated with a negative externality, which would need to be
accounted for in welfare economics studies (Giannakas & Fulton 2002, Lapan &
Moschini 2004). However, past experience shows that both stated-preference and exper-
imental data do not always correctly predict actual consumer behavior. Moreover, con-
sumer responses are strongly dependent on the type of information available at a certain
point (Huffman et al. 2003), so GM acceptance may potentially change rapidly. The
public media play an important role. Especially in Europe, media reports about GM
crops have been predominantly negative.
In general, available studies suggest that second-generation GM foods will be more
acceptable to consumers than first-generation products (Lusk et al. 2005). This supports
the hypothesis that GM acceptance levels will rise when quality-enhanced crops with more
direct consumer benefits become available. There are also indications that consumers in
developing countries have more positive attitudes toward GM food than their counter-
parts in developed countries (e.g., Kimenju Sc De Groote 2008, Krishna Sc Qaim 2008a).
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One possible explanation is that they are generally poorer and sometimes food insecure;
thus they may be more open to producrivity-incrcasing technologies.
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7. ECONOMICS OF GM CROP REGULATION
Because GM crops are associated with several potential market failures, the technology is
heavily regulated. For instance, GM crops may be associated with environmental and
health externalities, so biosafety and food safety regulations have been put in place. For
consumers, the GM characteristic of food products is a credence attribute, indicating that
labeling regulations can help to reduce transaction costs and problems of asymmetric
information. The development of GM technologies leads to public goods that can easily
be reproduced, so IPR protection is needed as an incentive for private sector R&cD invest-
ments. However, because every regulation is associated with trade-offs, the optimal level
should be determined on the basis of solid economics research (Just et ah 2006).
7.1. Biosafety and Food Safety
Governments have an important role in ensuring that novel foods are safe for human
consumption and that novel agricultural inputs do not cause major negative impacts on
the environment and long-term agricultural production possibilities. Most countries,
with the notable exception of the United States, consider GM crops to be novel foods,
regardless of the characteristics of their final product. Hence, new laws and institutions
to regulate potential biosafety and food safety issues have been established, requiring
that GM products be approved before they may be grown in, consumed in, or imported
into a country (Herdt 2006). Because approval processes are not internationally harmo-
nized, they have become a major barrier to the spread of GM crops and technologies
around the world. For instance, the EU has not yet approved some of the GM maize
technologies that are used in the United States and Argentina, which obstructs trade not
only in technologies but also in commodity and food markets. In the EU, this is related
to public-acceptance problems. In other parts of the world, however, the lack of GM
crop approvals is often due to human and financial capital constraints. Smaller develop-
ing countries, in particular, have been unable to legislate and operate a biosafety regu-
latory system to date. This has shut them off from some of the international markets
{Pray ct al. 2006).
In countries where a biosafety system is in place, most of regulators’ efforts are put into
preventing the commercialization of products that may harm people or the environment
(i.e., type I errors). Often, regulators are extremely cautious, requiring many regulatory
trials over a long period of time. However, lengthy biosafety and food safety testing
procedures come at a cost. Kalaitzandonakcs et al. (2007) estimated the private compli-
ance costs for regulatory approval of a new Br or HT maize technology in one country at
$6-15 million. Commercializing the same technology in other countries will entail addi-
tional costs. Beyond these direct regulatory costs, there are indirect costs in terms of
foregone benefits (preventing the use of safe products is referred to as type 11 errors). Pray
et al. (2005) estimated that a two-year delay in the approval of Bt cotton in India led to
aggregated losses to farmers of more than $100 million.
Such high regulatory costs slow down overall innovation rates. They also impede the
commercialization of GM technologies in minor crops and small countries, as markets in
68z Qaim
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such situations are not large enough to justify the fixed-cost investments. Expensive
regulations are also difficult to handle by small firms and public sector organizations,
thereby contributing to the further concentration of the agricultural biotech industry. Were
such lengthy and complex procedures necessary to regulate high-risk products, then the
costs involved would be justified. But this does not seem to be the case. Because the use of
genetic engineering does not entail unique risks, it is illogical to subject GM crops to a
much higher degree of scrutiny than conventionally bred crops (Bradford et ai. 2005). The
regulatory complexity observed today appears to be the outcome of the politicized public
debate and the lobbying success of antibiotech interest groups (Miller &c Conko 2004).
Some reform of the GM regulatory framework will be necessary, and economists have
an important role in this respect in terms of quantifying costs and benefits. Lichtenberg Sc
Zilberman (1988) suggested a safety rule approach for more efficient pesticide legislation
under uncertainty. The same approach could also be useful in the context of GM crops. It
combines a probabilistic risk assessment model with a safety rule decision mechanisms
that is equivalent to the use of significance levels for statistical decision making (Sexton
et al. 2007). The safety rule approach can be employed for cost-benefit or risk-benefit
analyses. Hence, transparent criteria and maximization techniques are used to bring
science and objectivity to decision-making processes that are often influenced by political
economy considerations and a precautionary approach.
7.2. Labeling and Coexistence
Several countries have introduced or considered introducing a food-labeling system. In
general, mandatory or voluntary labeling is possible. Mandatory labeling is often used to
warn consumers of specific health risks (e.g., cigarettes), whereas voluntary labeling is
more common to differentiate products with desirable characteristics for marketing pur-
poses (e.g., organic). Both systems can convey the same information to consumers. Given
that only GM products that are considered to be safe are approved for market release, no
warning of risks is required on labels. Therefore, the issue is mainly one of heterogeneous
consumer preferences, which — from an economics perspective — would be best addressed
through voluntary labeling of GM-free products (Golan ct al. 2001). The EU, however,
has established a mandatory system, which is more costly and can reinforce the notion
that GM products are inherently unsafe. The motivation underlying the EU approach is
that consumers have a right to know, which is different from the need to know approach
in the context of risk communication. Moschini (2008) argued that the right to know
approach is too open ended and potentially unbounded, because it can be invoked for
virtually anything.
Labeling involves market segregation and a system of identity preservation, which can
be quite costly. The cost is negatively correlated with the threshold levels allowed for the
adventitious presence of GM material. Again, these thresholds are not related to risks but
are a political decision; very low thresholds can lead to prohibitive segregation costs.
Giannakas & Fulton (2002) and Lence Sc Hayes (2005) showed that labeling in general
and segregation costs in particular can influence the welfare effects of GM crops signifi-
cantly. Dissimilar approaches across countries can also lead to serious problems in inter-
national trade.
Labeling and segregation are also related to coexistence. The EU, in particular, has
established rules to ensure the coexistence of GM crops with conventional and GM
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601
farming, which involve a number of technical and legal specifications, from minimtrm
distance requirements for cultivation to liability and insurance measures (Beckmann et al.
2006). The high degrees of complexity, uncertainty, and direct costs associated with
these coexistence rules represent clear disincentives for EU farmers to adopt GM crops
(Demont & Devos 2008, Breustedt et al. 2008).
7.3. Intellectual Property Rights and Public-Private Partnerships
In the United States and most other developed countries, living organisms and parts
thereof have been patentable since the 1980s. This has spurred a tremendous amount of
private sector biotechnology research. Nowadays, more than 75% of all patents in agri-
cultural biotechnology are held by the private sector, mostly by a few large multinational
corporations (Graff et al. 2003). Although strong patents and other forms of IPRs provide
an incentive for private sector R&D, they are associated with higher prices and the usual
static welfare losses in monopoly situations. As noted above, the degree of IPR protection
in a country has an influence on GM crop adoption and benefit distribution. When GM
seed prices are too hi^, resource-poor farmers face access problems (Qaim & de Janvry
2003). Therefore, the optimal level of IPR protection and enforcement is situation specific
(Giannakas 2002).
The proliferation of IPRs on genes, processes, and technologies has led to access and
freedom-to-operate problems within the biotechnology industry. Because the develop-
ment of a single GM crop may require the use of dozens of patented intermediate
technologies, licenses have to be negotiated with multiple parties, involving high trans-
action costs (Santaniello et al. 2000). In that sense, the freedom-to-operate problem may
contribute to further industry concentration. Public sector research organizations, in
particular, are at a disadvantage because they often have relatively little to offer in
return for licenses from private companies. Even the largest public sector patent holders,
such as the University of California and the United States Department of Agriculture,
own less than 2% of total agricultural biotechnology patents versus the more than 10%
owned by individual multinational companies such as Monsanto and DuPont (Graff et al.
2003).
However, public sector organizations combined hold 24% of the patents, and in
some areas they could develop GM crops without relying on patents from the private
sector. Graff & Zilberman (2001) suggested an IPR clearinghouse mechanism to reduce
transaction costs for such public sector collaborations and joint venture.?. A working
example is the Public Intellectual Property Resource for Agriculture (PIPRA), bringing
together intellectual property from more than 40 universities and public agencies and
helping make their technologies available to innovators around the world (http://www.
pipra.org).
Such public sector initiatives are important, as certain research and technology areas
will not be addressed by private companies because of the limited size of the potential
markets or other constraints. Examples include technologies designed especially for poor
farmers and consumers in developing countries (Qaim et al. 2000, Lipton 2001). In such
areas, more public research is needed. Moreover, more public-private partnerships should
be sought to harness the comparative strengths of both sectors (Rausser et al. 2000,
Byerlee & Fischer 2002). Usually, universities are better suited to carry out basic research,
whereas private companies have advantages in more applied research and development
684 Qaim
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602
(Rajagopai et ai. 2009). There are numerous examples of public-private research coopera-
tion in agricultural biotechnology, but none of these projects has yet led to a commercia-
lized CtM crop. Ex ante studies show that well-designed partnerships can be advantageous
for all parties involved (Krishna & Qaim 2007, 2008b). Nonetheless, more research is
needed to develop best practices for the transfer of technologies and know-how as well as
the development and commercialization of GM crops.
00
o
Q
a
I
8- CONCLUSION
GM crops have been used commercially for more than 10 years. To date, most of the GM
crops employed have been HT and insect resistant. Available impact studies show that
these crops are beneficial to farmers and consumers and produce large aggregate welfare
gains. Moreover, GM crops bring about environmental and health benefits. GM crops
may also be well suited for small-scale fanners, because such seed technologies are scale
neutral. The empirical evidence shows chat Bt crops in particular can have significant
income-increasing and poverty-reducing effects. Farmers in developing countries some-
times benefit more than farmers in developed countries, which is partly a result of weaker
IPR protection and, thus, lower seed prices. Yet, income distribution effects also depend
on the wider institutional setting, including farmers’ access to suitable seed varieties,
credit, information, and other input and output markets. More public and institutional
support will be needed to realize the benefits for the poor on a larger scale.
GM technologies currently in the research pipeline include crops that are tolerant to
abiotic stresses and crops that contain higher amounts of nutrients than traditional crops.
The benefits of such applications could be much greater than the ones already observed.
Against the background of a dwindling natural resource base and growing demand for
agricultural products, GM crops could contribute significantly to food security and sus-
tainable development at the global level. New technologies are crucial for the necessary
production increases.
In spite of these potentials, public opinion regarding GM crops remains divided, espe-
cially in Europe. Concerns about new risks and lobbying efforts of antibiotech groups
have led to complex and costly biosafety, food safety, and labeling regulations, which slow
down innovation rates and lead to a bias against small countries, minor crops, small firms,
and public research organizations. Overregulation has become a real threat for the further
development and use of GxM crops. The costs of regulation in terms of foregone benefits
may be large, especially for developing countries. This is not to say that zero regulation
would be desirable, but the trade-offe associated with regulation should be considered. In the
public arena, the risks of GM crops seem to be overrated, while the benefits are underrated.
Economics research has an important role to play in finding ways to maximize the net
social benefits. More work is needed to quantify possible indirect effects of GM crops,
including socioeconomic outcomes as well as environmental and health impacts. Further-
more, economists need to contribute to the design of efficient regulations and innovation
systems in light of changing framework conditions. Although the gradual move from
public to private crop improvement research is a positive sign of better-functioning mar-
kets, certain institutional factors seem to contribute to increasing industry concentration.
This could lead to adverse outcomes in terms of technology development and access. Such
issues need further analysis.
wtinv.annualreview5.org • The Economics of Genetically Modified Crops 68^
SUMMARY POINI'S
1. tiM clop^ have used coinrncti.jjlly !ti5 ino-.
and developing COURtdeS. So far. hethiculc Uit
have been rhe pfirRafy emes employed.
2. hTjp.-n.t studies !^OW that these crops are .a
and produce, large aggregate welfare gains. In umov
counmes benefir more dian farmers m devt liipt-d
3. Moreover, GM crops^.Wing alx>ut <
psuikular allow $ighiBcani reducti
tiohs
ops^an al«> be smtabte for smali-scaie i.un
developing countries shows chat rhey coi
: 0verrt^taQon has become a threat for
;GM cfopSv The foregone h
: dcveUjpmg countries. ^
i^Econrsmics research has an important role tt
he neESoeiarbene6is. Mofe;wbrit is needed
of GM crops, indoding socioeconomic outc*
healA impacts. -
economists need to ^oninbut'
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604
DISCLOSURE STATEMENT
The author is not aware of any affiliations, memberships, funding, or financial holdings
that might be perceived as affecting the objectivity of this review.
ACKNOWLEDGMENTS
Constructive comments from David Zilberman and Steve Sexton are gratefully acknowl-
edged, Most of my research related to the economics of GM crops was supported finan-
cially by the German Research Foundation (DFG).
gfi
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www.annualreviews.org • The Economics of Genetically Modified Crops 693
611
Contents
Annual Review of
Resource Economics
Volume 1, 2009
I g
i
Prefatory Article
An Amateur Among Professionals
Robert M. Solow 1
Policy Analysis and Design
Agriculture for Development: Toward a New Paradigm
Derek Byerlee, Alain de Janvry, and Elisabeth Sadoulet 15
Governance Structures and Resource Policy Reform:
Insights from Agricultural Transition
Johan EM. Swinnen and Scott Rozelle 33
Distortions to Agricultural Versus Nonagricultural
Producer Incentives
Kym Anderson 55
Public-Private Partnerships: Goods and the Structure of Contracts
Gordon Rausser and Reid Stevens 75
Environmental Regulations and Economic Activity:
Influence on Market Structure
Daniel L. Millimet, Santanu Roy, and Aditi Sengupta 99
The Development of New Catastrophe Risk Markets
Howard C, Kunreuther and Erwann O. Michel-Kerjan 119
The Curse of Natural Resources
Katharina Wick and Erwin Btdte 139
Experiments in Environment and Development
Juan Catnilo Cardenas 157
Behavior, Environment, and Health in Developing Countries:
Evaluation and Valuation
Suhhrendu K. Pattanayak and Alexander Pfaff. 183
612
I ^
Resource Dynamic
Irreversibility in Economics
Charles Perrings and William Brock 219
Whither Hotelling: Tests of the Theory of Exhaustible Resources
Margaret E. Slade and Henry Thille 239
Recent Developments in the Intertemporal Modeling of Uncertainty
Christian P. Traeger 261
Rent Taxation for Nonrenewable Resources
Diderik Lund 287
Land Use and Climate Change Interactions
Robert Mendelsohn and Ariel Dinar 309
Urban Growth and Climate Change
Matthew E. Kahn. 333
Reduced-Form Versus Structural Modeling in Environmental and
Resource Economics
Christopher Timmins and Wolfram Schlenker 351
Ecology and Space
Integrated Ecological-Economic Models
John Tschirhart 381
Integrating Ecology and Economics in the Study of Ecosystem Services:
Some Lessons Learned
Stephen Polasky and Kathleen Segerson 409
The Economics of Urban-Rural Space
Elena G. Irwin, Kathleen P. Bell, Nancy E. Bockstael,
David A. Newbum, Mark D. Partridge, and JunJie Wu 435
Pricing Urban Congestion
Ian W.H. Parry 461
The Economics of Endangered Species
Robert Innes and George Frisvold 485
On the Economics of Water Allocation and Pricing
Yacov Tsur 513
Technology and Innovation
The Economics of Agricultural R6cD
Julian M. Alston, Philip G. Pardey, Jennifer S. James, and
Matthew A. Anderson 537
via Contents
Annu. Rev. Resoiir. Econ. 2009.1:665-694. Downloaded from arjoumaIs.annualreviews.org
613
Supply and Demand of Electricity in the Developing World
Madhu Khanna and Narasimha D. Rao 567
Energy Efficiency Economics and Policy
Kenneth Gillingham, Richard G. Newell, and Karen Palmer 597
Recent Developments in Renewable Technologies: R&cD Investment in
Advanced Biofuels
Deepak Rajagopal, Steve Sexton, Gal Hochman, and David Zilberman ... 621
Fuel Versus Food
Ujjayant Chakravorty, Marie-Helene Hubert, and Linda Nostbakken . , . 645
The Economics of Genetically Modified Crops
Matin Qaim 665
2 ^
c
o
Errata
An online log of corrections to Annual Review of Resource Economics articles
may be found at http://resource.AnnualReviews.org
Contend ix
614
rndSdmit. 46,604-607. 1998
Evolved resistance to glyphosate in rigid ryegrass (LoUum
rigidum) in Australia
Stephen B. Powics
CRc ibr "Weed Manasement S)'siems, Waiw
Campus. Univeniiy of Ad^aide, PMB 1
Osmond SA $064, Asisaaiia. Present addmss:
'97emm Wee^ Inidathv, Facuhf of Agri^tur^
Univetney of Auitndu, Nedia^ WA
6907, Australia
Dd>rah E Lorraine-Ojiwiil
Dqamaem of Oop Praaxcioa. Campus,
Unmnity ^idbuidc^ PMB t Giea Osmoi^ SA
5064, Awnralw
Janu»J. Deilcmr
Agriodituy RoKtidi Insdeuic, NSW Agnculture
a^ CRC fer Weed Maiu^goBeae Synetm, Onage,
NSW 2800. Austnim
FoUovdng 15 yr of mccesdul use^ ^yj^osate fiuled to control a population of the
widespreu grass weed rigid ryegraa in Australia. Tius popukrion ;»oved to be
resistant ro ^yphosate in pot dose'inponse experiments conducnxl outdoors, exUb-
iting 7> to 1 1'fold resistance wbm compart to a suscepdbie population. Some
cross-resistance to didofep-med^ (diotu; 2.5‘&it0 was also obsennid. Similar levds
of o>ntrol of the resistant and susceptibie popula^os were obtained following ^
pUcatioa of amitrol^ chlonulfiuon. fituatrop-P-irntyl. panging sethmTdim, sinuH
zine, or cralkoxydim. The presence of ;^^hoeace reustamx in a major weed spedes
indkaia a need for changes in glyph^tate use panemL
Nomwirfararer Amitroie; chlotsulfurom didofep>medQ>i; Suadfop-P-butjdt dy-
pbosatc paraquat; sethoxydim; rraUmrydim; rigid ry^rass. lolium riffdum
Gaud. LOLRL
Keywuidaa Herbicide resistance, ^rphosatt remiitaiKe. iOLRI.
Chxiswpher Heston
Comspoomog autfaon Oqparaneiu of Oop
^t»eesioo sod CRC for Wwd MaBagemstr
Systenu, Ifomnicy- of Adeiaidc PMB 1 Glos
Onaond. SA 5064 Aiuoaiias
Giyphosans Is the worltEs most widely used hetbiddev
cooadng fof 11% of woridwide herbicide sales (Powles ee
aL 1997). It is a noosefecthre herbidde with no soil acting
(Groebard azul Addnsoa 1985). Therefor^ » is aa ideal
herbicide for use prepiant, in follow fields and for spot os
directed use to convol an extensive annud and
perennial weeds. Glyphosate has been wid^ used for dl of
these purposes for more than 20 yr (Bradshaw et d.^ 1997).
Recently; genedcally-enguacered giyphosaie>eoIeranc oops,,
notabty soybean max (L) Man) and cotton (Guh-
sypium hirmtum L.), have been maskmd in Nbrdi America:
under the Roundup Ready* labd (I^t^erae et at 199^;
Powies ec at 1997). This development will undoubtably in-
crease glyphosate use;
The inttnsiwt use of Herbiddet in a^culmre has led to
the ^pearance of resistaac weed popukdoa» (Holt ec d.
1993; Powles and Holtum 1994). In a few agiiculturd areas,
the (fovdopmcnc of widespread herbidde resistance in weeds
has compromised the use certain herbidde chemistrie*
(Powles ec at 1997). In some cases^ such as the acetolaccate-
inhibiting sulfonylurea herbldtfos, tesiscance has appeared
remarkably rapi^ (Gill 1995; Saari ec at 1994); however
for ocher herbicides, resistance has appeared sporadically or
not at alt This is so for ^ypho»m, vdiere, through more
than two decades of use, no cases of herbidde resistance
from field use have been reported (Bradshaw et at 1997;
Dyer 1994).
Rigid ryi^;cas$ Is a widdy established grass «%ed of crops
in southern Aoiscralia that has displaydi a propensity to
evolve resistance to herbidd» (Hall et d. 19^; Preston ec
604 • Weed Science 46, Septcmbex-October 1998
aL 1996). Ri^d ryegcasa la present in large numbers over
the 40 million ha that embrace the southern ^iscraHan win-
mr cropping and pasture region, and currently, populations
of this spedes di^lay resistance to most of the major her-*
blade chemistries In use in Australia, except giyphosam
(Hail et at 1994; Powles et d. 1997; Presmn et d.*i996).
However, glyphosate is now wide^ used to control rigi^
ryegrass across this region, and the intense selection pressure
thus applied to this panzculariy iesistaoce*prone species
makes g^hosate resistance a likdy outcome. A preliminary
report O^dey et at 1996) has suggested glyphosate resis-
tance can evolve in r%id ryepass.
Hece^ we document evolvra resistance n> glyphosate in a
population of rigid ly^rass from an orchard in Australia
following two to three armud applications of ^yph(»aie for
15 yr.
Materials and M^octo
The putadve resistant biotype of ci^ ryegrass was orig-
inally obtdned (iom an orchard near Onn^, New Sou^
Wdes, Australia. Glyphosam u 720 u> 1,440 g ae ha’*
been used two or three times a year for 15 yr to control
weeds within rofws of trees. Seed from plants growing in the
orchard was collected in December 1995. Seedling from
this seed were treated with glyphosam at 450 g ae ha~* on
two separate occasions during M;qr 1996 at Ae Aree-lcaf
stage and Ac Ara^ollcr stage. Sumvors of Ais treatment
were crossed among Aemscives as described by Taxdif et d.
(199^, and Ae resulting Fi seed was used for ail ftmher
615
OtyphoMM^aAha**)^ Oly ph o t ai (g htf^)
Figure 1. Ramiue o ( the kiunm wscepdUe (o) and pucum resinaits Ficuri 2. Dry wegts of dw known luscxpobte (o) and puemve resimnc
popuiatbns of r>TgraM » varying dose races of ^yphosate isopropy*' poputadoo* i^id cyccraBS 21 d after appUacioa (OAA) of varying
laroiae. Data ate from a su^dostMc^oose experiment with feucreplkana ma of gfypboata ito(»«i^uiiiiic. Data are mm a sii^ d^nspoase
condacned oo .seedlings gcosnng in pots. Pbtnei ate mean survivaL ± SE. experiment svidi feut repUeaies conduoed on senlUngi gnnrii^^ in poca.
Mr» arc mean dry sve^^ per plant ± SE.
oqsenizMnQi. A known susceptible ri^ ryegrass popukdon
was used as a control in all experioNsnea.
Pot <k»se>response experimeats were conducted outdoors
during umunn and winter, the normal growing season for
this species in southern Ausoralia. Seed was nminated in n
germinacon cabinet 12 b, C, 39 li^c
period,. 12 h, 19 C dark penod for 6 d. Gaminaced se^
Ungs were transplanmd to 17-cm-diam poa containing po 6 v
dng soil witb 12 seedllngy per pot and were grown outdoom
G^hosatewas a^ikd at a rangp of rams oota 9 to> 7,200^
g ae ha.'^ to plana at the cwo> to three-leaf stage devcl'
opmenCr F<Ktc ^yiduMate dose-response experiments, were
c»ndua»ii Experiment 1 used glyphoiate ammoniunk^ ap^
plied on A(»ti 16* 1997; Experimen 2 used ^rphosase am*^
monium ^^lied on 5, 1997; Eroeiiment 5 used
phosaee ammooiuxn applied on June ^ 1997^ and Experii-
menc 4 used slrahosaie crimerium^ appUed oa Augusc 2%
1 997* Other heroiddo usedr— amiooiQ chlonmlfbroir, fli»
azifop-P-butyi, paraquar, sethoxydiW stma^i^ and
traikoxydiio—were applied at the lowoenonnal use race ta
control rigid rye^ass in Austral except for dkkrfbpottfhs-
yi, whkb was applied at rates ranguig&MB 9 os 1,309 gab
ha~^ Tliese heAiddes were a{^U» to planxa tf the two- tta*
three-leaf stage from eo August- 1997. Few eadi herb^
cide rate, four rq>lkaae{iM|wesiattS^ Hetbaddes were ap-
plied wt^ a laborami^iiknvig^tmlHqyDqfer equipjpedwitb
T-|et fan ao 3 zlei,ae|^aiid^^Fiiag%f£.Out|^ horn the
sprayer was cal&ratqgPsk o? E. haP^ ara pressure of U5(k
uPz. Ail herbiddeswaaajfplMdaaraMnmetdal ^umuUrionsw
with adjuvants as recqniftignded Bj^the hcrbtdde manufac-
curers. ' '
Planes were returned ounkxMe after treatment, and the
response to herbicides was roorded after 2t d. Plants were
record^ as alive if tlwy had strongly dlfered since applk»-
cion of the herbidde. Shoots were removed at soil le>w and
dried at 60 C for 72 h to a constant weight. Mortality data
were sub^ to probic analysis using the computer program
POLOPC (198^ m detenzline LD 5 <y values. Probit andysis
gives equadoos of the following form;
r =* 5 + (it + ^ loj^ tiJ
where F is the expeaed probic, 4 is the Incetcepc and b the
slope of the probic Ime and is da log of the dose ram
(Fumey 1971). The LD 50 can be caicukttd from dus equa*-
don by solving for a pr^ic of 5.
RotuKs and Dltcusoton
The known susccpdble population oi ri^d ryegram wssn
readily controlled by g^yphosate, with very fow suivivota as>
rates of 459 g ae hf ^ or hi^ies (F^tue 1). In conoas^ tfa^
putative icaiscant popuktimi was markedly less afreemd 1 ^
giyphosattw requiring high tates for subnandal mortality;
Glyphoaaoe ax 459 % ae bar* dramadcally reduced
wdg^ accumuladbn of ihesuscepdble populadon and also
dearfy dama«d tfie resistant pluits (F^^are 2 ); however,
most the utttr pknie survxv^ At this rau^ dry weight
accumuladoos of susccpdble and resistant populadons
were 9 and 5996 of untreai^ a>ncn>ls; lespecdvely
This experiment wax repeated three times with the iso-
propylamine sab formulation of dyphosaie and once with
the txtmesiuai sab formubdon: of ^yphosam, and in each
case; the orchard populanoit dbpla^ resistance. The con!-
cennadoa hexbfcide required to kill 50% (LDso) of the
susceptfoSe populatuMt vari» b e twe en 59 and 174 gw ha~^
dqondiiig OB the season and type of formuladon vTable 1 ).
Tm LD 90 for the tesiscanc popuiatvm varied bcTR^en 609
and 1,809 g ae On alt occasions, the osistant popur
ladon proved to be between?- and 11 -fold resistant. Lower
rates of glyphosace isopropyUmine were required n> conmd
both popuhmons.ki and June during cooler wcauher,
compart to Aprik The recommended rate of ^yphosiue
trimesiunr for control of aimual lyegras is 33% hij^er than
that for dlyphosaie isopropyiamine Therefore, it is not sur-
prising that LD$o* ^ gxj^hosate trimesiUm ^re h^^er
thaa those obtained for ^phosaro Isoptr^syiaihine under
similar environmental conditions,
There have been a number of previous reports of toler-
ance of populadons of plant specie* to g^yphosate. Plant
breeders have deliberately selecom lines of perennbi ryegrass
{Lalium patnwl^ (Johnsron and Faulkner 1991), birds^t
trefoil (Z<7nKf comicuiatus L.) (Boerboom et al. 1990, 1991),
Festuca longifolia ThuilL, and red fescue {Festuca rubra L.)
(Johnsron et aL 1989) to ateatn low level gi)phosate toler-
Powles et al; Evolved resistance »> gjyphosate * 605
616
Tam^ I. Amount of glyphewK Kquircei for 50% momlicy of susceptible and resisunt pepukdoia of rig^ *7«r*» in four sepenm
experiments of the type shown in Figure 1. Values are LDso', calculated by probit analysis of tl« foil dose responae. Values in jarencfaesU
represent the 95% confidence intervals. R/S is the ratio of 11350 of the fesistaat popubtion to duu of the susceptible popularioo.
Experiiseiu
Herbicide foratularion
Susopribie
Resistant
R/S
L0„
(g ae ha'‘) — —
i
GlyplKuaie Isopropytamme
174 (156. 200)
1.718 (l.«3. 2,137)
10
2
Gi^hos^ isopropyiamme
106 (95. 119)
746 (507. 998)
7
3
G^hosate isopropyiamine
59 (24, 82)
623 M71, 764)
11
4
G^hosate crimesium
154 <135. 174)
U58 (1,009, 1,525)
3
uicc. Several nsuurally cxxuiring lines of field bindweed
{Convolvulus arvemis L) dispbQ«d hyphenate tolerance
withdut selection from i^hosate (OeC^maro and Wellet
1984; Duncan and We^ 1987; Westwood and Wetter
1997). In all of these casesy resistance appeared » be about
two- to fivefbUi compared to normal lines of the same spe-
cies. In none of the above cases had resistance appeared In
weed spedes as the result of normal co mmer c i al use of
phosate in the fidd. A preiiminarf repon, based on a sin^
dose-re^nse experiment a>nducred under ^asshouse coo-
didons, suggests dm evolved resistance may have occurred
in ano^er populadon of r^d tyegasi from northern Vic-
toria (Pratley et ai. 1996). Here, we have established (Figure
1 ; T;d}k 1) chat substantial res i s t an c e to ^yphosace is present
in a ^^faosare-sdected field pr^uladon of rigid ryegrass*
Herbicide cross-resistance (resistance to dis sim i t ar herbi-
cides) is common in jMpuladons of rigid lyegrim (Hall ec
at 1994t Preston et aL 199^^ Crosfr-resisande posea a se-
rious pra crica lli prol^em fmweed concrob as it can dra m a c -
ically reduce t he herbicide opdons available
Therefore the resiscaac populadon was examined for rest^
to a range of othv nerbktdcf applied at the rawest
recommended field rate to bocb resistant and suscepdbfie
populadons. The resioanc populadon proved to be as sera-
slave as the suscepdble pof^don to alTof these herbiddee
except cUcIofbcHrtteth)HI (Table 2). The pcmibiircy of resi*-
ounce m diclorop-methyl was further examined by conduce-
ing a fill! dose-response a^petimenc (Rguie 3>. This excee-
iment established that a difforenoe la response codiHotop-
methyi was evident b et w ee n the resmaneanJ suscombl*'
populadons; however; the glyphosate-rraistantt pr^cuadon*
was only d^ut 2.5-fbld resistant to dich^bpmethyf at the
TABt6 2. Response ofsuseejjwiUesadrtaBeun mpa&ttions of ri^
i:)^graa to alremaiive heflH$^^|iIwla£^lo«ess recommend-
ed rate; Herbicuks were xppfledas see^B^ pewmg io pots at
ihe nra- to tht(«-le^stage..\UMVaf«pan9tfsarvh>ai :±S£<^four
replkaces. ■ • ' '
Herbicide and rate
(g active ingredient ha'^)
Suscep^ibr
Routuur
Amitrole (700)
40- ±5 45±9
CblorsuJfuroD (15)
3 ± 3
0
Diclofop-medi^ (375)
27 ±6-
79 ±-1
Fluaafop-P-butyl (53)
0
0-
Paraquat (200)
0
0
Sethffitydim (186.8)
0
0
Stmazine (1620)
5'± 3
2 ± 2
Tralkoxydim (200)
0
0
L05a. This result is s^;ruficant, as the ryegrass popukdon
had not ptevioudy been exposed to diclofop-mediyL
Coruidering the highly successful long-rerm use of gly-
phosate (Bradshaw et aL 1997)* it is rernarkabie that more
examples of resistant plants have ru>t been idendfied. Several
explanations have put fi>rvraid m explain this obser-
vadon* includir^ the ihabUtty to generate ^cdoirai target-
sire mutadons witbiit enolpyruvylshikimare-B-phospliace
(£PSP) synthase in plana (Fa<i^;etre et aL 1991), and the
low rates of metabolisnx oi ^^imsate in plants (Kbmoba et
aL 1992). This has led some authors to predict that evolved
g^hosate resistance in weeds is unliluly (Bradshaw et aL
1997y. The prescQC study has demonRzared dm ewshwLr
resistarure to gjyphosate hw now ^qrpeared in rig^d ryegRUfc
Worldwide; rigid tyegass it by far the most resistance-
prone weed spedes, with ex tensiv e resiscance to numerous
herbicides (Hall et aL 199^ Rswkr ec aL 1997; Prestoor er
aL 1996); That tesmance has nowocomed in a g^lrosace-
selccted field populadon of ri^ ryegrass (Figure 1; TaUr
1) demoitsccates thav ^yphosate resistance can occur followB-
ing persisrent use; the tmportuice of ^yphosate in
world agriculture Its current high use, and impending in-
creased usage widSr mns^mic crops; the evoludoit of gly-
pbosate resistance is a sig?uficant devebpment in world ag-
riculture. k would be prudent to accept dm resistance can
occur to this hi^i^ Suable herbidde and to encourage
^ypbosatr use pazretna. within integrated straregies that do
not impose a strong sdbedon pressure for resistance.
Figohb 3. Response of (he known suscepdble (o) and ^yphosace resistant
(*) populations of rigid tycffats co varying dose rates of didofop-methyi.
Data are fiom a sin^ dote response experiment with ibur repiicates con-
ducted on seedlings g r owi ng in poo. Poinn ue mean survival ±. SE.
606 • Weed Science 46, Seprenfoer-October 1998
617
Sources of Matertais
‘ Giyphosate aoptooTHamine was Roundup CT® by Monsanto,
Australia UA, P.O. Box 6051, St Kilda RdskI Central, Victotii
8008'Auscra^
^ GiyphoML«s ttitaesium {trirnwhylsulfoniuin jTMS] salt) was
Touchdown® Crop Care AMStndasia, Pty. Ltd, P.O. Box 431 1,
Melbourne, Vl«oria 3001 Australia.
Acfonowfedgments
The authon dank Monsanto AustraUa LtA, Crop Cue Aus-
tralasia ?ty. L^, Rh6ne*Boidenc Rural AimiaUa, AsrEvo, Pty. Ltd..
Novartis Ausoalia, and DuPont (Ausaalia) Ltd- for gifts of for-
muiand herbicides.
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Bocrfxwii^ C M., D. L. and D. A. Somei*. 1990. Mechanism of
^yphosaro roleKUwe in bkdsfoot oefeii (X«ar wmindtfio). Weed Sd.
38:463-467.
Bradshaw, L D., S. R. S. L. KiofoaU, airf B. H. Wdls. 1997.
Pttspecdvei on dw^Kwaas reramuice. TechnoL 11:189-198.
DeCennaro, R R and S. C W^et 1984. Dlfiemjdai senaitmty of field
bindweed {Comn&mhitarvenm) biotjTa to giyphosate. WeedSci 32i
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Duncan, C N. and S. C WeSet 1987: Hdicdiilify of giyphosate naoep-
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and JAM. Holnia^ eda. HedMckk Ro t i t aa ce in Plants: Blol^ and
BlochenoMiy: Boca Ratoob Ha Lswiiu
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sibie oissa resistance and muld^ ttsistancc Pagts 243-261 in SL
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Biology and Biodieraisay. Boca Ratos, Fit Lewis..
Hole, J. S., JAM. Holtusib and S. B. RroHes. 199% Mechanisms askd
agronomic aspects of herhiddr nsistaiMs Anmi. Rew Plant PhysioL.
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JdiBston, D. T. and J. S. FauJitnet 1991. Herbicide resistance in the (
minaceae — a plww breetfcrs view. Pages 519-330 «i J. C Casdey
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synthase acme J. BioL Chem. 266:2256^22369.
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ware]
Powies, S. B. and JAM. Holtum, eds. 1994. HerHd^ Resinance ii
Plants: Biology and Biochemtstzy. Bocu Ratoir, FL; Lewis. 353 p.
Powlcs, S. B., C Picstoa. L B. Bryan, and A R. Jutstsm. 1997. Hetbidd
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Pratky, J.. P. Beu^ R Ebeibadb, M. Inmd. a.^ J. Biosrot: 1996. Gb*
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to acetyi-coetnyme A caifamgdaae-inlubidng heihiddes endowed a
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ivwu) biotypes. Wsed Sd; 45:2-1 1.
Raeivtd DetembtrS^ 1997^ and approved Jtau It, 1998.'
Powies et al: Evolvedi resistant^ w ^yphosate • 607
618
WWSd<rn« 47:412-415. 1999
Resistance to glyphosate in Lolium rigidum. II. Uptake,
translocation, and metabolism
Paul CC. Feng
Correspon<ltiig aui^or. Monsanto Co. GG5G. 700
Chestedidd Village linkway, St. Louis, MO 63198;
p3ullcng@monsanto.coin
James E. Piadey
Charies Stun University, Wa^a, New South
Wales 2679, Australia
Joseph A. Bohn
Monsanto Co., St. Louis. MO 63198
Experiments were conducted to detennine potential mechanisms of ^yphosate re-
sistance in Loiium riguUtm liom Australia. ^^G-Glyphosate uptake, translocarion, and
met^lism were compared benwen resistant (R) and sensitive (S) biotypes. The R
seed (48118a) represenwd the Fj progenies of plants having survived a L73'Iig ac
ha”* (4.8 Ll«*’)ap{rficadon of a ^imdup* formubtion. TheS seedwasasenskive
biotype of L. ri^um &Dm Australia. Plane (one to four dilers, 2 to 4 vde old) were
presprayed with a hi^ (1.26 kg ae ha'*) or a low (0.28 kg ae ha'*) dose of for-
mulated ^yphosaa. The first leaf of tl« first tiller, whidb wis shidded from the
spray, was immediately treated with a *^C-gIyphosate solution via manual application
to the adaxial surbee. Harvest was made 6 days after treatment (DAT), and gly-
phosate residues in the leaf wash, treated le^, roots, and shoots were quantified
based on radioactivity as percentage of applied dose. Tlie overall radioactivity recov-
eries were very good (90.2 to 97.3% of applied dose). R and S plants showed
comparable uptake at the hi^ (79.2 vs. 78.0%) or die low (64.0 vs. 64.7%) doses
of glyphosare. About one-half of the absorbed ^yphosatc in both R and S (32.9 to
38.3% appL) was translocated into the plant distributed almost equ^y into
roots (13.6 to 16.0% appl.) and shoots (18.1 ro 22.6% appl.). Autoradiography
studies demonstrated no dUFerence in tissue localization of ^yphosau [Ktw<»n the
R and S plants. For metabolism studies, tissues from inchvidu^ plants were homog-
enized in water, and extracts were analyzed by anion exchange high-pressure liquid
chromatography (HPLC) with radioactivity detection. There was little to no metab-
olism of glyphosate in extracts from various tissues of either R or S plants. Based
on these resets, we conclude that neither uptake, translocation, nor m«abolism play
a major role in glyphosate resistance in L ri^um.
Nfomcndatiire: Giyphosatr, Lolium ri^dum, LOLRI, rigid ty^tass.
Key words: Hetbicide resistance, glyphosate resistance, LOLRI.
Herbicide resistance is a frequent topic of review in the
literatuie stemming from an increasing number of cases
worldwide (Heap 1997; Hole ee al. 15)93; Moss and Rubin
1993). An intcmacionaJ survey documented over 216 weed
species that have evolved resistance to herbicides (Heap
1997). About one-third of these cases involve triazine resis-
tance. Resistance to acetolactate synthase (ALS) inhibitors
shows die fostest increase.
Among herbidde-tesistant weeds, Lolium ri^um Is per-
haps the mom; infiunous. Lolium rigidum is the first example
of a weed that demonstnued cross-resistance to multiple her-
bicide chemistries including aryloxyphcnoxyproprionates, cy-
dohexanedioncs, suifonyluxras, and dinitroaniiines (Powles et
al. 1990). Studies have shown diat the mechanism of L rig-
idum resistance is not due to any barrier to herbidde upta^
or translocation but to induction of several herbidde d<^-
dation enzymes (Presmn ct ai. 1996). Several foctors have
been attributed to die dei^opment of herbidde resistance in
L rigdum in Australia, induding wide distribution; diverse
genetic bac%round; a requirement for cross-poUinadon fa-
cilitating outcrossing; and high selection pressure from re-
peated use of the same heibicWes (Tardif et al. 1997).
Evoivcment of weed resistance to glyphosate in the en-
vironment has been pcrccivol to be a highly unlikdy event
(Bradshaw et al. 1997). However, L ri^um resistance to
^yphosatc has b«m detected in Australia. The first rase of
resistance was observed in a field in Echuca, Australia, where
^yphosatc had been applied repeatedly for presowing con-
trol of weeds (Pratlcy ct al. 1996). The second case was
r^oned recently in an orchard in Australia following mul-
tiple annual applications of glyphosate for 15 yr (Powles ct
al. 1998). Pradey ct al. (1999) describe bio^uarion of
glyphosate resistance in L. rigidum from the Echuca site.
Tire present manuscript examines the uptake, translocation,
and metabolism of *^C-gIyphasaK in the resistant L rigi^m.
Materials and Methods
R and S seed of L rigidum^ was provided by Charles Smrt
Unrvetaty, W^ga Wagga, Australia. The R sasi represented
dre FI progenies of plants havii^ survived a 4.8-L ha * (1.73
ac ha” *) application of Roundup (360 g L' *). The S satd
was a sensitive biotype of L rigidum from Australia.
Glyphosate, *^C-labeIcd at the phosphonomethylene (C-
3) sice,^ was obtained from New England Nuclear. The spe-
cific activity of *^C-glyphosate vras 1,457 MBq mmol'*
(517,000 dpm M-g"*), and it was derermined to be 99.5%
pure by HPLC analysis. *^C-Glyphosate was neutralized
with NaOH, diluted with water to a cont^ntradon of 0.50
Md stored at -20 C. MON OSIS^ (an cthoa^ated
tallowamine surfactant used in Roundup), glyphosate-iso-
propylamine salt^ (MON 0139), and Roundup Original^
were provided by Monsanto.
412 • Weed Science 47, July-August 1999
619
Uptahs and Traadocati<m ^dies
Seed was germinated in sod (50/50 Metromix blend with
fertilizer) in 10- by 10-cm pots in die geeenhcHise (52 C day
and 25 C ni^t widr supplemental iigbtir^. Tlie average ger-
mination for seed, was only about 3(^. Hie Idxded use rate
of glyphosate for the asntrol of L rsgidum in Australia is OJ.
TO 0.4 % ha"^ (Pracley ct ai. 1999). R and S L riffdtm (two
m six loives, 2 to 4 wk old) was pKCspr^^ with a higji (1.26
ha"*) or a low (0.28 kg ha’*) dose of Roundup Original
(187.1 L ha’* spray volume). Just prior to j^raying, the first
leaf of the first tifler was covered widh a wax paper deeve to
prevent interception of the ^ray solution. Immediately afier
the spray, the sleeve wb removed, and a *^C-gl)phosate dosing
solution was applied. The *'*Og^ht»ace dosing solutions
were prepared to nnatdi the volume, the surfectant concentra-
tion, and the gjyphosate concentration of the spray solutions.
A representative L npdum leaf blade vras spray^ initially with
warer, the average volume of spray intercqition was 6 pJ. Cal-
culations shovrcd that for the 0.28-kg ha * dose, die ^ray
solution contained 0.03% MON 0818 and 1.5 jtg ae pi *
glyphosate; the corre^nding 1 .26-kg ha' • spray solution con-
rained 0.14% MON 0818 and 6.8 pg ac pi’* ^phosatc.
*'^C-Gi)phosatc (782, (KX) or 1.51 pg) was mixed widi
MON 0818 ind MON 0139 so that in 6 -pl volume, it con-
ralnoi the same surfectant and glyphosate concentrations as
the spray solutions. The dose was applied as 6 - by 1 -pi drops
to the adsodaJi leaf surfiKS.
Following application of *'^C-gi)^hosate, plants were
tnmsferred to a growth chamber {12-h day/night, 29 C day,
25 C night, 60% humidity, 450 pE m'^ s'* light). M har-
vest (6 DAT), the *^C-treated leaf was excised at the base
and spray washed with water then methanol (— 10 ml each).
The washes were pooled and analyzed for radioactivity. The
treated leaf was dicn placed in a combustion cone. The rest
of die plant was washed to remove soil from the roots. The
plant was then separated into roots and shoots, and these
tissues vrere placed in individual combustion cones that were
dried overnight at 70 C.
Quantitation of Radioactivity
Analysis of tissue radioactivity was accomplished using a
Packard 387 sample oxidizer wth Oximate 80 robotics.^
The oxidizer, which was routinely tested by combustion of
standard sunples, recovered > 98% of radioactivity with no
carryover to sutxessivc samples. *^C-Glyphosate in tissue
was completely oxidized to '^C 02 , which was trapped in a
liquid scintillation cocktail and quantitated by Tracer Ana-
lytic counters.^ Based on initial applied radioactivity per
plant, percentages were calculated for residues localized in
the created lea£ Total translocation of glyphosate into the
plant was calculated by addition of radioactivity from the
shoot and root sections. The sum of the localiz^, translo-
cated, and leaf vrash provided total radioactivity recovery.
We had planned to use 10 plants per treatment that were
carefully matched in size and growth stage. But because of
low and unpredictable germination, the actual number of
r^licatts per treatment ranged from 5 to 20 plants. Because
each plant was dosed and processed individually, uptake and
translocation of glyphosate were calculated for each r^licate
plant. Average and standard errors were calculated from the
r^Hcates within a treatment.
Metabolism Studies
Plants (R and S) employed for these studres were treated
die same as those in the uptalre and tianslocadon studies.
Metabolism of gjyphosatc was examined in tissue extraos
from the treated leaf, shoots, and roots of ea«di plant Tissues
were initially mincoJ into small pieces using sdssors and ho-
mogenized using a Polytron tissue miser® in water (~0.75
mO. Homc^enares were centrifu^ (14,000 X ^ at 4 C for
25 min), and aliquots of supernatane were analyzed for ra-
dioactivity. Approximately 200- to 500-}jd volumes of tissue
extracts containing 30,000 k> 200,000 dpm were analyzed by
HPLC. Metabolites (^yphosate and aminontethyl phosphon-
ic acid, AMPA) were identified based on retention times, and
percCTtagc distribution was quantified based on radioactivity.
HPIX^ Analysis
The HPLC system was assembled using components
from Waters Ass^iates® with a flow-chroi^ radioactivity
detcaor from Radiomatics.*® An Alitech strong anion ex-
change (SAX) column** (5 jim, iO by 250 mm) was em-
ploy^ at a flow rate of 3 ml min’*. The solvent gradient
cmplo^d two buffers, 5 and 100 mM KH 2 PO 4 , pH 2.0
witii 4% methanol. The gradient was programmed as fol-
lows: 5 mM (100%) for 2 min, 5 to 100 mM (100%)
linearly in 3 min, and 100 mM for 10 min. The radioac-
tivity detector (RAD) employed a scintiUant*^ at a flow rate
of 9 ml min'*. Mixtures of •'^C-standaids were routinely
analyzed prior to sample analyses. The following retention
times were typically obtained: AMPA, 5.5 min; glyphosate,
11.5 min; and N-acetyl AMPA, 14.4 min.
Antoradic^raphy Studies
Plants used for these studies were treated the same as
chose in uptake and translocation studies. R and S planes
(four each) were presprayed with glyphosate ac 0.28 ac
!u"*, and the shielded leaf was treated with a *^C-^yphosatc
solution. Plants vrere maintained in the growth chamber and
Irarvested 2 and 5 DAT. Plants were washed, pressed, dned,
and exposed to x-ray film‘d at -80 C for 4 d.
Results and Discussion
Significant resistance to glyphosate was demonstrated in
R pl^ts during spray titration studies (Pracley et al. 1996,
1999). While S plants were completely killed at < 0.22 kg
ac ha * of glyphosate, the R plants had 93% survival. Fur-
thermore, 30% of R plants were unaffeaed by a treatment
of 0.43 kg ae ha’* glyphosate.
Uptake and TranslocaUon Studies
Both R and S plants were presprayed with a hi^ or low
rate formulated ^yphosacc followed by manual application
of *^C-g)yphosatc to the first leaf of die first tiller, which was
shidded fiim the spray. Even chough the ^yphosace dose var-
ied, ail plants received the same amount of radioactivity.
Feng et al.: Resistance to glyphosate • 413
620
Taw^ I. Total recovery and tiptalcc of ’^C-glyphosate m R and S
rigid i^^^rass (£. ri^um) 6 DAT.
’^C'GlyiAosarc as
Bioevpe
Rate
% apt^ dose
in Kps)
<kgacha-!)
Fractions
{avwage £ SE)
RC20)
1.26
Total recovery
97.3 ± 1.5
Uptake
79.2 ± 4.0
Leaf wash
18.1 ± 4.4
S (5)
Total recovery
96. 1 ± 5.3
Uptake
78.0 ± 4.2
Leaf wash
18.1 ± 3.4
R(7)
0.28
Total recovery
92.1 ± 5.5
Upake
64.7 ± 6.2
L^wash
27.4 ± 6.4
S{10)
Total recovery
90.2 ± 3.9
Uptake
64.0 ± 6.0
L^wash
26.2 ± 7.0
Total recoveries of applied radioactivity 6 DAT were cal-
culated for the replicates within each treatment and averaged
from 90.2 ± 3.9 to 97.3 — 1.5% (Tabic 1). Based on d»c
excellent radioactivity recovery, all calculations are reported
as percentages of applied dose. Total plant uptake was nearly
identical for R and S plants widhin the same creacmenc dose.
At the high dose (1.26 kg ae ha *), uptake in R and S plants
was 79.2 ± 4.0 and 78.0 ± 4.2%, respectively. At the low
dose (0.28 ae ha"’), uptake in R and S was 64.7 ± 6.2
and 64.0 ± 6.0%, respectively. The hi^ dose demonstrated
slightly higher uptake, presumably due to the hi^er surfac-
tant and ^yphosate concentration in the dosing solution.
Glyphosatc not recovered from plants was recovered in the
treated le^ tvash. Recovery ranged from 18.1 ± 4.4 to 27.4
± 6.4% of the applied dose.
Table 2 shows distribution of radioactivity into plant
tissues, vtdiich included the treated leaf, roots, and shoots.
Radioactivity in the treated leaf represented glyphosate chat
was loaded Into the leaf (and hence, not removed by the
wash) but not translocated in the plant. On« again, Uric to
no difference was detected between the R and S plants in
radioactivity locdized in the created leaf. For both R and S,
the high d^ localized more radioactivity (45.1 ± 4.4 and
45.1 ± 62%, respectively) than die low dose (26.4 ± 6.1
and 28,8 ± 7.0%, respectively). Total translocation of ^y-
phosate was similar In R and S plants and ranged from 18.1
± 2.2 to 22.6 ± 2,2% in shoots and from 13.6 ± 2.0 to
15.8 ± 2.6% in roots. In contrast to uptake, similar trans-
location was observed at both hi^ and low doses of gly-
pbosate. These results indicate chat although uptake was
higher at the h^ dose, increased localization of glyphosate
in the treated lc« rcsvdttd in comparable translocation as the
low dose. Tbc hi^ dose not only contained more glyphosate
but also more su^ctwt. We speculate chat the high surfac-
tant concentratison caused greater tissue injury in the created
leaf, thus ne^dvely affecting translocation (Feng et ai. 1998).
TTie conclusion is that there is little to no difference in ^y-
phosace uptake and translocation between R and S plants.
Autonutio^raphy Studies
The translocation results provided a quantiutivc but
gross distribution of glyphosate In shoots and roots. Auto-
radiography studies were conducted m provide a more de-
Ta«.e 2, Translocation of '^C-glyphosate to shoots and roots of R
and S rigid ryegrass (L. rigidum) 6 DAT.
Biot}'pe
{«i^
Rate
{kg ae ha‘9
Tissue fractions
'*C-Glypiiosatc as
% appl d<xe
(av«age ± SE)
R(20)
1.26
Shoot
18.1 ± 2.2
Root
16.0 ± 1.6
Total translocation
34.2 ± 3.4
Treated leaf
45.1 ± 4.4
S(5)
Shoot
19.3 ± 2.4
Root
13.6 ± 2.0
Total translocation
32.9 ± 3.9
Treated leaf
45.1 ± 6.2
R(7)
0.28
Shoot
22.6 ± 2.2
iteot
15.7 ± 4.6
Total translocation
38.3 ± 5.7
Treated leaf
26.4 ± 6.1
S(10)
Shoot
193 ± 3.3
Root
15.8 ± 2.6
Total O'anslocatioR
35.2 ± 5.6
Treated leif
28.8 ± 7.0
tailed, albeit qualitative analysis of tissue disctibuclon. R and
5 plants, as in the above studies, were presprayed with 0.28
kg ha~’ glyphosate followed by treatment with ’‘’C-gly-
phosace dosing solution. R and S plants visuaHzed 2 and 5
DAT demonstrated little different in tissue distribution. In
general, the highest concentration of glyphosate was ob-
served in the treated leaf, followed by other leaves of the
same tiller, and then leaves of other tillers. Roots proximate
to the treated leaf received more ^yphosatc. Young shoots
and the crown showed more gjyphosate than the oltkr clUers
and leaves. Translocation of glyphosate in both R and S L
ri^dum appeared similar to other planes (Klevorn and Wyse
1984; Wallace and Bellindcr 1995) and proceeded from
source to sink tissues (Franz et ai. 1997).
Metabolism Studies
These studies employed plants that were treated the same
as those in the uptake and translocation studies. Instead of
combustion, the tissues were homogenized and extracts an-
alyzed by SAX-HPLC/RAD. Tissues (roots, shoots, and the
treated leaf) from Individual R and S plants were harvested
6 DAT and analyzed.
HPLC was embraced with a mixture of standards
including glyphosate and AMPA. Analysis of the dosi;^ so-
lution showed two peaks identified based on retention time
as glyphosate (83.6%) and AMPA (12.7%) (Table 3). Al-
Tarle 3. Distribution of radioactivity as glyphosate or AMPA in
tissue extracts of R and S rigid ryegrass {L. rig^um) as determined
by SAX-HPLC 6 DAT.
Biotype
{it reps)
Rate
(kg ae ha ')
Fracrions
**C-Glyphosate as
% distribution
(average ± SE)
Dosing solution
None
Glyphosate
83.6
AMPA
12.7
R(9)
1.26
Glyphosate
78.4 ± 2.4
AMPA
16.6 ± 2.0
S(6)
0.28
Glyphosate
86.5 ± 1.8
AMPA
12.2 ± 1.8
414
Weed Science 47, July-Au^t 1999
621
thoi^ the purity of the original ^^C^yphosate was vejy
high (99.5%), storage of ^yphosate as a dilute water solution
at -20 C must have caus^ some d^radation to AMPA over
time. Analysis of tissue extracts (treated le^, roots, and
shoots) fiom R and S pknts a>nsistendy displayed two major
peaks identified as glyphosate and AMPA. Ba:ause no differ-
ence in distribution was deteoed among various tiisues of
plants, we averted all tlw resula within R and S blotypes
(Table 3). Hie distribution of nulioactivity betw«n ^ypho^
ate and AMPA in R plants was 78.4 ± 2.4 and 16.6 ± 2.0%,
respectively. In comparison, die distribution in S plants was
86.5 ± 1.8 and 12.2 ± 1.8% for glyphosate and AMPA,
respectively. Although R plants showed sli^dy lower dy-
phosatc and higher AMPA than S plants, this minor diror-
ence in composition is believed to be insufficient to account
for the level of resistance observed in whole piano. Previous
work using Roundup Ready Giycine max (L) Mcrr. (soybean)
and Brassica napus L. (canola) seedlings containing the gly-
phosate degradation ^ne (Barry ct aL 1992) showed almost
complete conversion of glyphosate to AMPA within a few
days after treatment (unpublished data).
The results of these studies demonstrated similar patterns
of gl)phosate uptake, translocation, and metabolism in R
and S biotypes. Lolium rig^um plants displayed extensive
uptake of glyphosate (—70% of the applied dose). About
one-half of the absorbed dose was oeported from the treated
leaf into the plant, with nearly equal distribution between
shoots and roots. Our results suggest that neither uptake,
translocation, nor metabolism play a major role in giyphos-
atc resistance in L. rigidum.
Powics ct al. (1998) recently reported evolved resistance
to ^yphosate in L rigidum in an orchard in Australia; the
mechanism of resistance is currendy under invesrigarion.
Through recurrent selection, glyphosate resistance has also
been demonstrated in Lolium perenne L. (perennial ryegrass),
aithoi^h the mechanism remains unknown (Johnston and
Faulkner 1991). The mechanism of glyphosate resistant has
also been examined in sensitive and resistant Convolttulus
arvemis L. (field bindweed). Neither absorption nor trans-
location could account for differencial sensitivity of R and
S biotypes to glyphosate (Westwood ct aJ. 1997). Further
studies demonstrated increased shikimate pathway activity
and higher concentration of phenolics in R than in S plants
(Westwood and Weller 199^. The authors concluded that
multiple mechanisms at cellular and metabolic levels ac-
counted for glyphosate resistance in C arvemis. Our own
investigations in L. ri^um are also progressing toward cel-
lular or biochemical mofianisms of resistance. Studies are
underway to determine the sensitivity of EPSPS (5-cnoI-
pyruvyI-shikimate-3-phosphate synthase) to glyphosate and
the overexpression of EPSPS as potential mc^anisms of re-
sistance in L. ri^um.
Sources of Materials
' R and S L ri^um seed. Dr. Jim Pratlcy, Charles Sturt Uni-
versity, Waj^ Wa^a, Australia.
^ RadiolabcI«l glyphosate. New England Nuclear, Boston, MA.
^ MON0818, Monsanto Co.. St. Louis, MO.
^ Glyphosate isopmpyiamine salt {MON0139), Monsanto Co.,
St. Louis, MO.
^ Roundup Original, Monsanto Co., St. Louis. MO.
^ Packard 387 sample exxidizer with Oximaie 80 robotics, PKkard.
Downers Grove, IL
^ Tracor Analytic countere, Austin, TX.
* Polytron tissue miser, Brinkman, Wcsdiury, NY.
® HPIX3 system components, Waters Associates, Marlborough,
MA.
Flow-throu^ radioactivity detector, Radiomatics, Downers
Grove, IL
** Ailtech SAX column, Allsphcre, Deerfield, IL
.^omflow scintillant, DuPont, Boston, MA.
Biomax MR x-ray film, Kodak, Rochester, NY.
Acknowledgments
We thank Dave Schafer, Tommy Chiu, Steve Voss, and John
V^koun for technical assistance.
Literature CHed
Barry. G. E., G. M. Kishore, S. R. Padgctie, ct al. 1992. Inhibitors of
amino acid biosynthesis: strategies lor imparting ^yphosate tolerance
to crop plants. Pages 139-145 in B. K. Singh, H- E. Fiores, and ).
C Shanntm, eds. Biosynthesis and Molecular R^uJation of Amino
Adds in Plans. Rockville. MD; American Sodety ofPlant Phy^c^iss.
Bradshaw. L D., S. R. Padgene. S. K. Kimball, and B. H. Wells. 1997.
Peta>cctives on glyphosate resistance, We«i Tcdinol. 11:189-198.
Feng, P.C.C., j. S. Ryerse. and R. D. Sammons. 1998. Cor^don of leaf
damage with uptake and translocation of glyphosate in velvedeaf
rilon ihfophnuti). Weed Technol. 12:300—307-
Franz, ). E., M. K. Mao. and J. A. Sikorski. 1997. Uptake, transport, and
metabolism of glyphosate in pUnts. Pages 143—186 in Glypnosatc: A
Unique Gbbal Herbicide. Wadtington, DC: American Chemical So*
ciety Monogr. 189.
Heap, !. M. 1997. The occurrence of herbicide-resistant weeds worldwide.
Ptatic. Sci. 51:235-243.
Holt, |. S., S. B. Powics. and Jj\.M. Holtum. 1993. Mechanisms and
agronomic aspects of herbicide resistance. Annu. Rev. PImt Physiol.
MtJ. Biol. 44:203-209.
Jcdinsron, D. T. and J. S- Faulkner. 1991. Herbicide resisunce in the Gra-
minaccae — a plant breeder's view. P^cs 319-330 in ). C. Caseiey. G.
W. Cussans, and R. T. Atkin, eds. Herbicide Resistance in WKds and
Cron. Oxford; Bunerworth-Heinemann.
Klevorn, T. B. and D. L Wyse. 1984. Effects of leaf girdling and rhizome
girdling on glyphosate and phoroassimilaie discri^tion in quaci^rass
X/^npyron repem). Weed Sci. 32:402-407.
Moss. S. K. and B. Rubin. 1993. Herbiddc'tevstant weeds; a worldwide
perspective. ]. Agric. Sci. 120:141-148.
Powles, S. B.. J.A.M. Holtum. J. M. Matthews, and D. R. Uijegten. 1990.
Herbicide cross-resistance in rigid ryegrass iLeiium rindum Gaud.).
Pages 394-406 in Managing Ruistance to Agrochem^s. Waking-
ton, DC: American Chemicu Society Symposium Ser. 421,
Powles, i B., D. F. Loriaine-Colwjli, J. J, Callow, and C. Preston. 1998.
Evt^ved resistance to glyphosate in rigid ryegrass (lolium rigidum) in
Australia. Weed Sci. ■«;60^07.
Pradey, J. E., P. Baines. R. Eberbach. M. Incerti. and J. Brostw. 1996.
Glyphosate resistance In annual ryegrass. Page 126 iit J. Virgona and
O. Michalk, eds. Proceedir^ of (he llch Annual Conference of the
Grasslands Society of New :^uch Wales. Wagg;a Wagga, Ausetalia: The
Grasslands Society of NSW.
Pratlcy. J., N. Urwin, R. Stanton, R Baines. J. Brostet, K. Cullis, D. Schafw,
|. Bohn, and R Krueget. 1999. Resistance to glyphosate in Lolium
ripdum. !. Bioevaiuarion. Weed Sci. 47;405-411.
Preston, C., F. J. Tardif, J. T. Christopher, and S. B. POwles. 1996. Multifde
resisunce to dissimilar herbicioe dKmistries in a biotype of Lolium
rigidum due to enhanced activity of several heibicide degrading en-
zymes. Pestic. Biochem. Physiol. 54:123-134.
Tardif, F. j.. C. Preston, and S. B. Powics. 1997. Merfunisms of hwbicide
multiple resistance in Lolium ripdum. Pages 1 17-124 in R D. Prado,
j. Jorrin, and L. G. Torres, eds. Weed and Crop Resistance to Pfar-
bicidcs. The Hague, The Netherlands: Kluwer.
Wallace, R. W. and R. R. Bellinder. 1995. Glyphosate absorption and trans-
location in rust-irUixted quad^rass npens). Weed Sci. 43:1-6.
Westwood, J. H. and S. C. Weller. 1997. (^Uuiar mechanisms influence
differential glyphosate sensitivity in field bindweed {Convolvuiuj at-
wwu) biotypes. Weed Sd. 45:2-11.
Westwood, J. H., C. N. Ytrkes, and S. C. Weller. 1997. Absorption and
translocation of ^rahosu:e in tolerant and susceptible blotypes of Add
bindweed (ConvUwdus arvemis). Weed Sci. 45:658-663.
Received February II, 1999, and approved June 29, 1999.
Feng ei al.: Resistance to glyphosate • 415
622
AgBloForum, 12(3S,4): 370-381. 02009 AgBloFonim.
Adoption of Best Management Practices to Control Weed Resistance
by Corn, Cotton, and Soybean Growers
George B. Frisvold
University of Arizona
Terrance M. Hurley
University of Minnesota
Paul D. Mitchell
University of Wiscon&'n
Utis study ^amined adoption of 10 best management practices
<BMPs} to contrd weed resistance to h^tiddes using data ^om
a survey of more than 1 .CK}0 US com, coUcNt, and soybean
growere. Count-data models were estimated to explain the total
number of BMPs frequently practiced. Ordered-probit regres-
sior» were used to e>q3lain the frequency of individual BMP
adoption. Growers practicing a greater number of BMPs fre-
quency had more education, but less ferming e)q3erience; grew
cotton; expected higher i^elds relative to the county average;
and farmed in counties witii a Itwer coefficient of variation (CV)
yield of tiieir pHmary crop. Yield e)q)ectations and variabifity
were significant predictors of adoption of indMdual BMPs. Most
growers frequently adopted the sarr^ seven BMPs. Extension
efforts may be more effec^ve if they targeted the three practices
wj8i low adoption rates. Counties with a high-yield CV would be
areas to look for low BMP adoption.
Key words: weed, herbicide, resistance management, corn.
a)tton, soybeans, adoption.
introduction
In 2008, agricultural producers planted more than 80%
of US cotton and com acreage and more than 90% of
soybean acreage to transgenic glyphosate-tolerant.
Roundup Ready® (RR) seed varieties (US Departm^t
of Agriculture Agricultural Marketing Service [USDA
AMS], 2008; USDA National Agricultural Statistics
Service [NASS], 2008). Many studies report significant
pecuniary and non-pecuniary benefits to growers from
using glyphosate-resistant varieties (Gianessi, 2008;
Marra, Pardey, & Alston, 2002; Marra & Piggott, 2006;
Mensah, 2007; Piggott & Marra, 2008).
The evolution of glyphosate-resistant weeds threat-
ens the sustainability of these benefits, however. The
number and range of glyphosate-resistant weeds has
been increasing in the United States since commercial-
ization of RR crops (Heap, 2009). The evolution of
weed resistance to herbicides also poses problems for
other herbicide-resistant crops, such as LibertyLink® or
Clearfield® crops. The potential for pests or weeds to
develop resistance in response to frequent applications
of a narrow set of chemicals with the same mode of
action is well established in the literature (Carlson &
Wetzstein, 1993; Holt & Lebaron, 1990; Powles &
Shaner, 2001; Shaner, 1995). Beckie (2006, pp. 793)
identifies, “recurrent application of highly efficacious
herbicides with the same site of action” and “annual
weed species that occur in high population densities” as
key risk factors for the evolution of herbicide resistance
in wads.
However, strategies for reducing the risk of pest
resistance are also well-documented (Burgos et al.,
2006; Culpepper, York, & Kichicr, 2008; Gressei 8c
Segel, 1990; Monsanto, 2009a, 2009b; Mueller, Mitch-
ell, Young, & Culpepper, 2005; Nalewaja, 1999;
Prather, DiTomaso, & Holt, 2000; Steckel, Hayes, Sc
Rhodes, 2004; Stewart, 2008). Commodity groups,
extension specialists, and Monsanto have recommended
that growers adopt various best management practices
(BMPs) to prevent or delay the spread of glyphos^e-
r^istant weeds (Burgos et al., 2006; Culpepper et al.,
2008; Monsanto, 2009a, 2009b; Steckel et al., 2004;
Stewart, 2008). These strategies fall under the more gen-
eral rubric of integrated weed management (IWM),
components of which include weed scouting; avoidance
on over- reliance on a compound or compounds with a
single mode of action against weeds; preventing herbi-
cide-resistant gene spread, non-chemical control such as
tillage, and crop rotations. A key element of this strat-
egy is diversifying herbicides used, relying on multiple
compounds with different modes of action.
This study examines the frequency of grower adop-
tion of 10 different BMPs to prevent or delay weed
resistance. Primary survey data on more than a thousand
US com, cotton, and soybean growers was used to char-
acterize the nature of BMP adoption. Count-data models
were estimated to explain the total number of BMPs fre-
quently practiced. Ordered-probit regressions were used
to explain the frequency of individual BMP adoption.
623
Previous Studies
There are four strands of literature pertinent to the
underetanding of grower adoption of BMPs. First, weed
science studies describe how weed resistance to herbi-
cides evolves, the approaches to prevent and respond to
resistance, and toe roles of different BMPs in prevention
and response (e.g., Beckie, 2006; Green, 2007). These
are not economic studies per se, but do consider eco-
nomic incentives and trade-offs. Second are normative,
economic modeling approaches (e.g., Gorddard, Pan-
neli, & Hratzler, 1995; Llewellyn, Lindner, Pannell, &
Powles, 2001; Pannell & Ziiberman, 2001; Weersink,
Llewellyn, & Pencil, 2005). Here, toe susceptibility of
weeds to herbicides is examined as an exhaustible
resource. Growers face an intemporal trade-off between
weed-management practices that maximize short-run
returns versus practices that delay resistance. Delaying
resistance may be l^s profitable in toe short-run, but
more profitable in toe long nm. Third, positive, empiri-
cal analyses collect and analyze data on ^ower percep-
tions and behavior regarding weed resistance (e.g.,
Hammond, Luschei, Boerboom, & Nowak, 2006; John-
son & Gibson, 2006; Wilson, Tucker, Hooker, LeJeune,
& Doohan, 2008). While the economic models highli^t
how growers should manage resistance, these empirical
studies examine what steps growers actually take to
manage it. These studies also shed light on grower ratio-
nales for their behavior. Fourth, there is the econometric
approach (Llewellyn et al., 2007). The first step in this
£^>proach Is to develop a dynamic economic model of
weed management, including resistance management.
Results from the theoretical model guide variable selec-
tion and statistical specification for multivariate regres-
sion analysis. Finally, the multivariate regression
analysis tests hypotheses generated from the theoretical
model. Thus, the prescriptive, theoretical model informs
specification of the descriptive, statistical model. In
turn, statistical model results test the validity of and
hypotheses generated by the theoretical model.
Conceptual Framework
Following Llewellyn et al. (2001, 2007), we freat the
adoption of weed resistance BMPs as a dynamic optimi-
zation problem. A grower ch(X)ses application rates of a
preferred herbicide, Hp and adoption of different BMPs,
Mf , to maximize the net present value (NPV) of returns.
Max NPy- m
( 1 )
AgBioForum, 12(3&4}. 2009 \ 371
wito respect to Hi, Mj^ subject to
, Pi, Hi. Ml . Xi)-, df/ dHi > 0;
( 2 )
where
Pi “ crop price
Yf = crop yield
5i = percent yield loss from weed damage
Nf = pre-treatment weed population
Ri *= weed resistance to the herbicide
Hj = level of herbicide use
Ml - vector of resistance management pr^tices
Xt - behavior of neighbors or external factors that
increase resistance
Ch- cost of herbicide treatment
Cf^= cost of resistance management
Vf = other variable costs
P ** discount factor
Equation 2 characterizes the evolution of resistance.
Initially, use of the herbicide reduces damage
{d6(/ 6H, < 0), but also increases resistance
(df / BHi > 0). Evolution of resistance renders the herbi-
cide less effective (^S(/ dHj dRi > 0). Resistance-man-
agement BMPs, Ml , slow the evolution of resistance
(df f Ml < 0), but entail additional costs, Cji^Af^). BMPs
may reduce damage in the current period (ddf/dMi < 0).
However, these alternatives may be less effective or
more expensive than frequent applications of the pre-
ferred herbicide. For example, repeated applications of
glyphosate may be more profitable (at least in toe short-
run) than applying tank mixes or additional residual her-
bicides.^ Many growers manage herbicide-resistant
crops in combination wito no-till practices. While sup-
plemental tillage offers the option of non-chemical con-
trol, it would require growers to forego some benefits of
no-till systems (such as reduced fuel costs or soil ero-
sion).
This stylized model c«q)tures key features of weed
BMP adoption. First, BMPs are costly to adopt. Yet they
/. The model presented hen treats use of multiple herbicides
with different modes of action as part of the set of BMPs in
Mf A more complete, but more complicated, model could con-
sider resistance evolution of different classes of herbicides,
not Just the preferred herbicide. This would involve midtple
equations such as fQ, but could allow for examination of the
"optimal rotation” of herbicides.
Frisvold. Hurley, &Mitdiell— Adoption of BMPs to Con^l\^^f^5istarKe by Ccm. Cotton, and Soybean Growers
624
slow resistance and can, in some cases, substitute for
herbicide ^plications in reducing current damage.
Thus, some BMPs may be profitable to adopt ^art from
their contribution to resistence management. If BMPs
reduce current profitability, however, growers will not
adopt them unless (a) they effectively slow resistance,
(b) their contribution to future profitability counteracts
their short-run costs, and (c) growers recognize the
BMPs’ contribution to future profitability.
Even if the damage function ^() and resistance-evo-
lution equation J[) are such that adoption of BMPs
increases the NPV of long-run profits, growers may still
not adopt them. Growers must have sufficient informa-
tion about SQ and JQ to expect that their own adoption
of BMPs is profitable in the long run. A potential role of
extensicm is to increase knowledge about S() and ^).
ITiere is more scope for individual growers learning
about the effect of practices on current weed damage,
^0, than on the evolution of resistance,^. High vari-
ability in production ouhromes, however, may make
such learning more difficult.
Anotiier fector affecting grower adoption is whether
growere perceive weed resistance to be subject to their
own control. Pannell mid Zilberman (2001) have argued
that resistance management is subject to greater individ-
ual control than insect pest management, indicating diat
common pool externalities discoursing resistance man-
agement should be less of a problem. If, however, grow-
ers perceive diat resistance depends on external factors
rather than their own actions (i.e., the effect of Of I Xf
dominates the effect of ^ f Mf ), this will discourse
BMP adoption. In a study of Ohio farmer perceptions of
weed management, \^iIson ct al. (2008) found growers
attributed weed introduction and spread to external nat-
ural fectors and neighbor behavior. At the same time,
they placed less emphasis on the importance of their
own actions.
Hie evolution of resistance may also spur adoption
of BMPs. As resistance to an herbicide develops, rely-
ing solely on that herbicide becomes less effective at
mansing weeds. In effect, as dS^/dHj approaches zero,
growers may be forced to shift to other weed-control
methods. Various studies suggest that development of
herbicide-resistant weeds in Ausftalia and Canada has
spurred greater adoption of BMPs (Llewellyn et al.,
2004; Powles, Preston, Jutsum, & Bryan, 1997; Wilson
et al., 2008). Thus, one may see use of BMPs not to pre-
vent resist^ce but as a means of mitigating it.
This simple model suggests testable hypotheses.
Firet, growers will be more likely to adopt BMPs that
have immediate benefits in terms of controlling current
AgBioForum. 12(3&4). 2009 1 372
weed populations. Second, this effect will be stronger
for growers with higher potential yields because percent
reductions in damage have a hi^er payoff. In contrast,
growers will be less likely to adopt practices that do not
provide obvious, shoit-nm benefits. Third, powers
experiencing resistance problems may increase BMPs as
their traditional means of control becomes less effective.
Fourth, implementing complex, interrelated BMPs may
require more human capital. So, one may expect more
use of BMPs among growers with more education.
Greater education helps lower costs of implementing
BMPs (C//). Fifth, greater variability in agronomic and
economic outcomes may dis(x>urage BMP adoption.
Pannell and Zilberman (2001) note the importance of
observability and trialability in encouraging adoption of
new technologies. In areas with highly variable produc-
tion outcomes, growers may have more difficulty
assessing the effects of and returns to BMP adoption.
Data
Data were collected via a telephone survey conducted
by Marketing Horizons for Monsanto in November/
December of 2007. The survey was designed to be a
random, representative sample of com, cotton, and soy-
bean growers from the Great Plains eastward. Data col-
lection was restricted to farms with 250 or more acres of
the targeted crop. Responses were obtained from 401
cotton growers, 402 com growers, and 402 soybean
growers. While growers were “targeted” to respond to
questions about a particular crop, they often also pro-
duced other crops. For example, many cotton growers
who were asked detailed questions about cotton produc-
tion also grew com or soybeans.
The survey included four sections. The first asked
questions about operator and farm characteristics. These
included operator education and experience, acres oper-
ated, percentage of operated land owned, acres of differ-
ent crops grown, acreage planted with herbicide-tolerant
crops, crop-rotation practices, and extent of livestock
production. The second section asked growers about
their current weed management; adoption of weed-resis-
tance BMPs; herbicides and/or tillage used for pre-plant,
pre-emergent, and post-emergent weed control; and tim-
ing and frequency of jxist-emeigent weed management.
The third section asked growers about their attitudes
regarding various weed-managemimt concerns, such as
crop yield, crop-yield risk, crop price, crop-price risk,
herbicide costs, seed costs, overhead costs, labor and
management time, crop safety, operator and worker
safety, environmental safety, erosion control, and conve-
Frisvold, Hurley, & Mitchell — Ackiption of BMPs to CorHrol Wted Resistance by Com, Cotton, and Soybean Grovmrs
625
AgBioForum, 12(3&4), 2009 1 373
1. Ff^uency of resistance best maru)seinentpra^»s(^IIF> adoption (percent of respondents practlclnp>.
HjBggHHjl
SHSHBHHii
HiSHii
m'ence. Tlie fourth section asked growers about the cost
of their weed-management program and die value of the
benefite they derived using a RR weed-management
program.
For this study, weed-resistance management prac-
tices were categorized into 1 0 separate BMPs:
1 . Scouting fields before applying herbicides
2. Scouting fields after herbicide applications
3. Start with a clean field, using either a bumdown her-
bicide application or tillage
4. Controlling weeds early when they are relatively
small
5. Controlling weed escapes and preventing weeds
from setting seeds
6. Cleaning equipment before moving from field to
field to minimize spread of weed seed
7. Using new commercial seed that is as free from
weed seed as possible
8. Using multiple herbicides with different modes of
action
9. Using tillage to supplement herbicide applications
10. Using die herbicide-labei recommended application
rate
Growers could choose among five responses when
^ked how frequently they iwlopted a BMP: (1) always,
(2) often, (3) sometimes, (4) rarely, and (5) never.
(Growers could respond, '“don’t know,” but these
accounted for 0.3% of responses). Six BMPs were
always practiced by a majority of growers (Table 1).
There were three BMPs, however, that a significant
share of growers never practiced. These included clean-
ing equifffnent before moving between fields (31%),
using multiple herbicides with different modes of action
(13%), and using supplemental tillage (32%).
Table 2. Frequency of weed resistance BMP adoption {p«r-
cont of resDondents)
Scout bofom
63%
11%
Scout after
81%
15%
4%
Ciaan field
75%
13%
12%
Control early
89%
9%
2%
Control Mcapes
79%
15%
6%
Clean equipment
25%
20%
54%
New seed
94%
3%
2%
Different modes
39%
33%
28%
Supplemental
tillage
21%
28%
53%
Use label rata
93%
4%
1%
Table 2 combines the share of BMPs practiced often
or always, then rarely or never for the same data. There
arc seven practices that 75% of growers practice fre-
quently (often or always; Table 2): use new seed (94%),
follow label rate (93%), start with a clean field (75%),
scout before (83%), scout after (81%), control weeds
early (89%), and control weed escapes (79%). Again,
one can see that the remaining three BMPs — using mul-
tiple herbicides with different modes of action, cleaning
equipment, and supplemental tillage — ^were practiced
less frequently (Table 2).
Adoption patterns were remaikably similar across
producer groups. Seven of the BMPs were practiced by
71% or more of com, cotton, or soybean producers (Fig-
ures la, lb, Ic). Moreover, these were tfie same seven
practices. All three of the producer ^ups used multiple
herbicides with different modes of action, cleaned
equipment, or practiced supplemental tillage much less
frequently. Less than half of any of these producers
practiced these tiiree BMPs often or always. More com
producers used multiple heiticides with different modes
Frfsvofcf. Hurfey, & Mitchell— Aflbplfon of BMPs to Control Wsed Resistance by Com. Cotton, and Soybean Grovmrs
626
Figure la. Percent of com growers adopting BMPs often or
always.
Figure 1b. Percent of soybean growers adopting BMPs
often or always.
Figure 1c. Percent of cotton growers adopting BMPs often
or always.
AgBioFcrum, 12(3&4). 2009 \ 374
Figure 2. Percentage of growers often or always adopting
BMPs by total number of BMPs adopted and targeted crop.
of action often or always (49%) than either cotton (38%)
or soybean (28%) growers.
Cotton growers were more likely to practice more
BMPs often or always than were com or soybean grow-
ers (Figure 2). More than 70% of cotton growers prac-
tice seven or more BMPs often or always, compared to
58% of com producers and 55% of soybean producers.
About 45% of cotton growers practiced eight or more
BMPs often or always compared to 35% for com grow-
ers and 24% for soybean growers. About 95% of cotton
growers often or always adopted five or more BMPs.
Methods
Integrated weed management (IWM) involves adoption
of multiple, interrelated practices. For empirical
research, this raises questions about how one measures
adoption when “adoption” involves making selections
from a suite of different practices. Some studies con-
sider adoption of individual practices, while othei^
attempt to develop indexes characterizing the intensity
of adoption. Hollingsworth and Coli (2001) developed a
scoring system based on a weighted sum of practices
adopted. Hammond et al. (2006) used an index that was
an unweighted count of the total number of practices
adopted. Llewellyn et al. (2007) considered those grow-
ers who adopted three or more practice (out of a possi-
ble six) as IWM adoptere.
We analyzed data concerning BMP adoption in two
ways. First, multivariate count-data analysis was used to
identify which factors explained the total number of
BMPs a grower adopted fiequently (often or always).
Friswld, Hufley, & MitcheH— Adop^ of BMPs to Cwrtrol Weed Resistance by Com, Cotton, and Soybean Growers
627
AgBsoFowm, 12{3&4}. 2009 ( 375
For example, which toors help predict whether a groww
will adopt ei^t practices frequently as opposed to seven?
Here .the dependent variable is similar to the unweighted
index approach of Hammond et al. (2006). Next, muhi-
variate ordered-probit regressions were estimated to iden-
tify ^ore that help explain how frequently a grower
practiced a particular, single BMP.
For the multivariate regression analyses, in addition
to the Marketing Horizons survey data, county-specific
variables were created using data from the USDA
NASS. Tliese included the coefficient of variation (CV)
of county crop yields of the targeta! crop. CV is the
standard deviation of yields divided by the mean of
yields over 10 years. The yield CV was included to test
the hypothesis that growers in counties with greater
yield risk had different patterns of BMP adoption.
Growers were asked what they expected their taiget
crc^ yields would total. An Index was created that was
the ratio of growers’ expected yields to their counties’
average yields. This variable was included to test the
hypothesis that growers with higher-than-average yields
(perhaps better managers or growers farming under con-
ditions that are more favor^le) were more likely to
adopt BMPs more frequently.
The number of BMPs a grower adopts often or
always can only be an integer from 0, 1, 2, ... up to 10.
This means a Poisson (or other count data) model is
more appropriate than standard linear regression, which
can yield parameter estimates that are inefficient,
biased, or both and can yield nonsensical predicted val-
ues (Greene, 1997; King, 1988). A Poisson regression
assumes that the mean and variance of the dependent
variable are equal. This assumption can overestimate the
statistical significance of regression parameter estimates
when there is over-dispersion (variance greater than the
mean) or underestimate their statisUcal significance
when there is under-dispersion (variance less than the
mean). However, estimation here followed McCullagh
and Nelder (1989), who fit a Poisson regression that
relaxes this restriction. McCullagh and Nelder use the
Pearson chi-square method to estimate a scale parameter
s, such that s = \ if the mean and variance are equal, s >
1 if the variance exceeds the mean (over-dispersion),
and j < 1 if the variance is less than the mean (under-dis-
persion). We also estimate a generalized negative bino-
mial regression as an alternative to a Poisson regression
because it also allows for separate estimation of mean
and variance (Cameron & Trivedi, 1998; Greene, 1997).
Next, ordered-probit regressions were estimated sep-
arately for each of the 10 BMPs. When asked how fre-
quently they adopted a given BMP, respondents could
Table 3. Descriptive stadsUcs for variables used in regres-
sions.
Number of BMPs practiced often
or atwa;^
6.838
Com producer («1 if targeted
producM^ ss 0 ofoer^e)
0.342
Soybean producer (si if targeted
producer; s o oUiervrtse)
0.355
Cotton producer (si If targeted
producer, s 0 ottierwlse)
0.303
Years of education
14.042
Years farming
29.799
Crop acreage (acres)
1422
Percent of land owned
41.611
1.540
1.816
12.116
1196
32.060
Raises livestock (s1 if yes; » 0
otherwise)
0.368
Percent RR (percent of ta^^ed
crop planted to RR varieties}
87.026
Yield difference (percent
difference of grower's expected
targeted crop yield compared to
county lO-year average)
29.559
Yield CV (county 10-year
coefficient of variation of
targeted of yield of grower's
targeted crop)
0.177
Resistance concern <si if yes If
grower Indicated weed
resistance vres a concern; » 0
otherwise)
0.516
Herfindahl Index (Measure of
crop specialization » 1 for
complete specialization;
minimum value of 0.25)
0.536
Custom applications (percent of
herbicide appUcations to
targeted cn^ made by custom
applicators)
28.577
County resistance (^i if weed
resistance reported in county; «
0 otherwise)
0.126
CRD resistance (percent of
counties in 'crop reporting' with
reporls of weed resistance)
8.932
28.275
44.120
0.084
0.160
41.871
20.679
Number of observations
1,006
Source: Marketing Horizons Survey and NASS county-level
answer 1 -always, 2-often, 3-sometimes, 4-rarely, or 5-
never. In addition, respondents could answer “don’t
know,” but few responded this way, so we deleted these
few observations fiom die regression analysis.
Frisvold, Hurley, S Mitchell — Adop^n of BMPs to Control Wbed Resistance by Com, Cotton, and Soybean Growers
628
AgBioFotvm. 12(3&4). 2009 \ 376
wood ;
Sate effects
Negat^ebinorrittl
pm
fkxrf!.
Slgnif.
•iVx-.- -
Intercept
1.798
0.000
1.797
0.000
1.797
0.000
Soybean
-0.009
0.640
-0.01
0.623
-0.016
0.393
-0,015
0.396
Cotton
0.080
0.f00
0.079
0.111
0.074
0.002
0.073
0.003
Raise livestock
-0.002
0.913
-0.002
0.89
-0.006
0.686
-0.006
0.896
Resist concern
0.005
0.756
0.006
0.704
0.006
0.69
0.006
0.667
County weed resistance
0.047
0,172
0.048
0.169
0.050
0.142
0.050
0.147
Education
0.011
0.010
0.011
0.010
0.012
0.003
0.012
0.003
Years farming
■0.001
0.059
■0.001
0.058
-0.000
0.143
-0.000
0,15
Crop acres
0.0000
0.148
0.00001
0.134
O.OOOOf
0.085
0.00001
0.084
% land owned
0.000
0.304
0.000
0.27
0.000
0.252
0.000
0,239
RR acres
0.000
0.53
0.000
0.522
0.000
0.532
D.OOO
0.514
Yield diff
0.0000
0.037
0.0000
0.035
0.0000
0.054
0.0000
0.048
Yield CV
-0.358
0.006
•0.366
0.006
-0.314
0.007
-0.319
0.007
Herfindalii
0.074
0.124
0.073
0.135
0.056
0.22
0.056
0.229
% custom ap.
0.000
0.469
0.000
0.519
0.000
0.580
0.000
0.588
CRD weed
-0.002
0.016
-0.002
0.015
■0.001
0.053
■0.001
0.057
IV
0.057
0.040
0.Q58
0.038
m
0.078
0.042
0.078
0.043
KS
0.179
0.001
0.162
0.001
s (Scale)
0.332
0.043
0.335
0.043
Llkeflhood ratio test statistic
91.302
0.000
90.689
0.000
61.875
0.000
61168
0.000
d.f.
32
32
15
15
• Only significant state effects reported. Boldface denotes significance at 5% level. Boldface with italics denotes significant at 10%
level.
The set of covariates used in the regression models
included (I) dummy variables for target crop grown and
whether a grower sold livestock; (2) years of grower
education and farming experience; (3) total crop acres
and percent of cropland owned; (4) the percentage of
target crop planted to RR seed varieties in the previous
year; (5) percent of herbicide applications carried out by
a custom applicator; (6) a Herfind^l index based on the
proportion of die crop acreage planted to com, cotton,
soybean, and other crops, which increases as a grower
becomes more specialiwd; (7) a dummy variable indi-
cating that the grower listed weed resistance as a concern
in an open-ended question about weed management con-
cerns— growers were not asked directly if resistance was
a concern; (8) grower expected yield as a percent of
county average yield and the coefficient of variation of
target crop yield in the grower’s county; and (9) measures
of reported herbicide resistance. Two measures of
reported herbicide resistance were constructed based (mi
proprietary data obtained from Monsanto. These were (a)
a dummy variable Indicating weed resistance to herbi-
cides has been reported In a grower’s coun^ and (b) the
percentage of counties in a grower’s crop reporting dis-
trict where weed resistance has been reported.
Table 3 reports descriptive statistics for variables used
in the regressions. Tfre sample included 1,006 observa-
tions after deleting those observations with missing data.
Adoption rates of RR varieties are high, with an average
of 87% of the acres of targeted crops planted to those
varieties. Grower yield expectations also seem high rela-
tive to county averages. On average, growers expected
their yields to exceed their county’s 10-year average by
29%. This may reflect optimism on the part of producers,
but recall that (a) growers were surveyed about their pri-
mary crop, md (b) our sample includes larger producers,
only those growing 250 or more acres of the targeted
crop. So, it might not be too surprising that relatively
large growers, specializing in production of a crop expect
Fnsvold, Hurley. S Mitchell-— Adoption of BMPs to Control Wfeed Resistance by Com, Cotton, and Soybean Growers
629
higher-than-average yields. Or, growers* responses
reflect their potential yield, perhaps reflecting the highest
yield th^ ob^ned in recent years.
Results — Count-Data Analysis
Table 4 reports count-data regression results where the
dependent variable is the total number of weed BMPs
that a grower reported using either often or always.
Table 4 reporte results for generalized Poisson and nega-
tive binomial regressions with and without state ftxed
effects. The Poisson and negative binomial specifica-
tions yield similar results, with both models suggesting
under-dispersion. Based on the likelihood statistics, we
can reject the hypothesis of no state-level effects. How-
ever, only three states individudly had statistically sig-
nificant effects- The default s^e is Iowa, and the
regression coefficients for Illinois, Indiana, and Kansas
were all positive and significant This suggests that
compared to Iowa, growers in these states tend to prac-
tice more BMPs often or always, while growers in other
states tend to practice about the same number of weed
BMPs as Iowa’s growers.
A number of variables were significant across all
specifications. The number of BMPs adopted
• increased wifti a grower’s level of education,
• increased for growers with expected yields greater
than the county average yield,
• was lower in counties with more variable yields
(measured by the county yield CV), and
• was lower in crop- reporting districts reporting more
resistance problems.
In regressions with state effects, the number of years
of fanning experience was negatively associated with
the number of BMPs adopted, suggesting that younger
fanners tend to adopt more BMPs. Separate models esti-
mated by target crop did not perform well and so are not
reported here — for the separate com and soybean mod-
els, the null hypothesis of all zero coefficients (except
for the cx^nstant) could not be rejected at the 5% level of
significance.
In sum, younger, more educated growers who expect
to obtain higher-than-average yields practiced a greater
number of BMPs often or always. Growers in regions
with grwter percentege yield variability practiced fewer
BMPs. The relationship between local resistance epi-
sodes and grower BMP adoption was mixed. Growers in
crop-r^orting distticts with more counties reporting
resist^ce practiced fewer BMPs. Yet, growers forming
AgBioForum, 12(3&4). 2009 j 377
in counties reporting resistance, tended to adopt more
BMPs. This latter relationship was not significant, how-
ever.
Cotton growers and larger operators appeared to
adopt more BMPs, but this affect was attenuated by
including state-specific effects. The attenuating elfect of
state variables may come from the fact that there was no
overlap of growers in surveyed cotton and com states
and only a small overlap between surveyed cotton and
soybean growers. Hence, there is a relatively high corre-
lation between the state dummy variables and the cote^n
grower dummy variable.
Ordered-Probit Results
Table 5 reports results for separate order^-probit
regression (breach ofthe lOBMPs. The dependent vari-
able is the frequency of practicing a given BMP, where
growers could choose ^tween frequencies of never,
rarely, sometimes, often, or always. Table 5 reports the
effects of explanatory variables that were si^ificant at
the 5% and 10% levels. A positive sign (+) indicates an
increase in the probability of practicing the BMP more
frequently, while a negative minus sign (-) indicates the
variable decreased the frequency of adopting the BMP.
Table 6 summarizes results of the orderol-probit
regressions by explanatory variable. It reports the vari-
ables that had significant effects (at the 10% level) on
adoption of each weed-resistance BMP. Results are
summarized with and without state effects, with the data
pooled across all growers.
In the count-data regressions, targeted cotton pro-
ducers were more likely to adopt more BMPs often or
always, but including state-specific effects attenuated
this cotton-grower effect. This pattern repeats itself with
frequency of adoption of individual BMPs. Targeted
cotton producers appear to have a higher probability of
more fi^uent adoption of a number of individual BMPs
in the ordered probits. However, once we include state
effects, the statistical significance of these relationships
declines. In both ordered probits, soybean producers use
multiple herbicides with different modes of action less
frequently. In the count-data regression, a negative asso-
ciafion existed between being a soybean producer and
the number of BMPs adopted often or always, but the
association was not significant.
The probit regressions also show that growers who
expect yields higher than the county average are more
likely to use multiple herbicides with different modes of
action. In contrast, growere in counties with greater
yield variability less frequently used herbicides with dif-
Fiisvokl, Hurley, & Mitchell — Adoption of BMPs to Cor4r^ Weed Resistance by Com, Cotton, and Soybean Growers
630
Yoars Annins
Crop acres
Percent land
owied
Roundup
Ready acres
Yield
difference
Herfindahl
Index
Custom
application
Crop rep.disL
resistance
County vmed
resistance
Resistance Is
a concern
NE
NC/SCAW
NO
OH
Adoption frequency categories: never, rarely, somef/mes, often, always; + denotes variable had a pos^ve and signi^cant impact on
frequency of adopffon; - denotes variable had a negative and significant impact on frequency of adoption
^ regression coefficient significant at 5% level: ^ ooefRcient sigryhcartt at 10% level
* P-value of lOrelihood ratio test of null hypothesis diat /egresston coefficients of all explanatory variables = 0
Frisvold, Hurley, & Mitchell — Adoption of BMPs to Cotnrol Weed F^sistance by Com, Cotton, and Soybean Growers
631
AgBioFotvm, 12(3&4}. 2009 1 379
fcrent modes of action, practiced weed scouting, and
Table 6. Slgntncant variables from onfered-probit regressions and their effect on ttie frequency of adopting weed resfetance
BMPs.
.xz 1
Soybean
Control early (-)
Diff. modes (-)
Diff. modes {-)
Suppl. tiage (-)
Cotton
S«)ut before (+)
Clean equip,
Scout before (+)
Clean equip.(+)
Sccajt aSer (+)
Suppl. tiage (+)
New Seed (-}
Education
Scout after {+)
Scout after (+)
Clean equip. (-)
Diff. modes {+)
Suppl. tillage (-)
Years ferming
Control early (+)
IM. modes (-)
Control early (+)
Diff. modes (-)
Control esc. (-)
Suppl. tillage (-)
Crop acres
Scout before {+>
% land owned
Scout before (+)
Scout before (■♦•)
Clean field {-)
Roundup Ready aci^
New Seed (+)
Label rate (+)
New Seed (+)
Label rate (+)
Diff. modM (-)
Sup(^. tillage (-)
Clean field (-)
CHff. modes (-)
>1efd tMerwtee
Control esc. (+)
Diff. modes (+)
Scout before (+)
New Seed (+)
Scout after (+)
Diff. modes (+)
County yield CV
Scout after (-)
Control esc. (-)
Scout before (~)
Control esc. (-)
Diff. modes {-)
Scout after (-)
Suppl. tillage (-')
Diff. modes (-)
Herfindahl index
Clean field {-)
Suppl. till. (+)
Custom applications
Scout after (-)
Conbol esc. (-)
Clean field {-)
Control esc. (-)
Resistance In CRD
Control esc. (-)
Diff. modes (->
Conifol early (-)
Control esc. (-)
Restsfence In county
Diff. modes (+)
Diff. modes (+)
Resistance a concern
Clean field (+)
Diff. modes (+)
Clean equip. (-)
Suppl. tillage (--)
Clean equip. (-)
New Seed (+)
Siwl. till. (-)
New Seed (+}
Label rate (-)
Raised livestock
Scout after (-)
Diff. modes (+)
Scout after (-)
controlled weed escapes. The positive impact of
expected yield and the negative impact of yield variabil-
ity are consistent witfi the coimt-data regressions.
A higher percentage of acreage planted to RR seed
varieties was associated with ^eater use of new seed
and less-frequent use of multiple herbicides with differ-
ent modes of action. RR acre^e was associated with
more frequently following heiticide-label rates. Grow-
ers expressing a concern about resistance in the open-
ended questions used supplemental tillage and cleaned
equipment less frequently, but used new commercial
seed more frequently. Growers operating in a county
with reports of weed resistance more frequently used
multiple herbicides widi different modes of action.
Conclusions
Although cotton growers adopted BMPs somewhat
more frequently, BMP adoption patterns were remark-
ably similar across crops. For all three crops, adoption
rates of the same three BMPs were low. These were
cleaning equipment, using multiple herbicides widi dif-
ferent modes of action, and supplemental tillage. The
other seven BMPs were practiced frequently (often or
always) by all three grower types.
Generalized Poisson and negative binomial regres-
sion results suggest that factors significantly and posi-
tively associated with adopting more BMPs include (a)
having more education; (b) having less experience (per-
haps being younger?); (c) growing cotton; (d) expecting
higher yields relative to the county average; and (e)
farming in counties wift a lower yield coefficient of
Piisvofd, Huriey, & MitcheH AdopUon of BMP*s to Control Weed Resistantx by Com. Coffon, and Soybean Growers
632
variation. In the ordered probits, farming in a counQ^
with a larger coefficient of variation of target crop yield
reduced the probability of fr^uent adoption of several
BMPs. Highly wiable production outcomes may hin-
der the observability and Salability of BMPs (Pannell
& Zilberman, 2001). With greater yield variability, it
may be more difficult for growers to assess outcomes or
benefits of BMP adoption. In contrast, the ratio of a
grower’s expected yield to the county average yield
mcre< 2 sre«ithe probability of frequent aefoption of BMPs.
There may be some form of a “good manager^’ effect at
work, where growers with hi^er yields (or at least
higher expected yields) than their neighbors tend to
adopt more BMPs mwe frequently. If BMPs increase
current returns by minimizing percent yield loss to
weeds, gains fi-om damage reduction would be greater
for growers with higher yields.
The survey data suggests that most growers are fre-
quently adopting most BMPs. Extension efforts may
thus be more effective by targeting a minority of grow-
eis (and a few practices). In particular, counties with a
high coefficient of variation of crop yield would be
areas to look for low BMP adoption.
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Acknowledgements
Support for this project was provided by the Arizona,
Minnesota, and Wisconsin Agricultural Experiment Sta-
tions, HarvestChoice (http://www.harvestchoice.org),
and Monsanto. The authors gratefully acknowledge the
helpful comments and data-collection efforts of
Michelle Obermeier-Starke, John Soteres, and other
researchers at Monsanto. All conclusions and any
remaining errors arc the authors’,
Frisvofd, Hurley. & MHchea — Adoption of BMPs to Cor^l Weed Resistance by Com. Cotton, and Soybean Growers
634
Weed Technology 2Q!)9 23:363-370
Selecting for Weed Resistance: Herbicide Rotation and Mixture
Hugh J. Beckie and Xavier Reboud*
Herbidde rotations and mixtures are widely recommended to manage herbicide resistance. However, Httie research has
quantified how these practices actually affea the selairion of herbicide resistance in weeds. A 4--yr experiment was
conducted in western Canada from 2004 to 2(K)7 to examine the intact of herbicide rotation and mixture in selecting for
acetolactaie synthase (ALS) inhibitor resistance in the annud broatUeaf weed, field pennycress, co-occurring in wheat.
'IreatmenK consisted of the ALS-inhibitor herbidde, ethamcisulfuron, applied in a mixture with bromoxj'nil/jMCPA
formulated herbicide (photosystem-11 inhibitor/synthetic auxin), or in rotation with the non-ALS inhibitor at an ALS-
inhihicor application frequency of 0, 25, 50. 75, and 100% (i.e., aero to four applications, respectively) over the 4-yr
period. The field pennycress seed bank at the start of the experiment contained 5% ethametsuifuron-resistant seed.
Although weed control was only raai^tnally reduced, resistance frequency of progeny of survivors increased markedly after
one ALS-inhibitor application. At the end of the experiment, the level of fcsi.stance in the seed l>ank was buffered by
susceptible seed, increasing from 29% of recruited seedlings after one ^plication to 85% after four applications of the ALS
inhibitor. The level of resistance in the seed bank for the mixture treatment after 4 yr remained similar to chat of the
nontreated (weedy) control or 0% Al^-inhibitor roiarion frequency treatment. The results of this study demonstrate how
rapidly AI.,S-inhibiior resistance can evolve a.s a consequence of repeated application of herbicides with this site of action,
and supports epidemiological information from farmer questionnaire survey's and modeling simulations that mixtures are
more effective than rotations in mitigating resistance evolution through herbicide selection.
Nomenclature: Bromoxy'nil; eihametsulfrron; MCPA; field pennycress, Thbspi arveme L. THIAR; wheat. Triticum
aeitivitm L. ‘AC Barrie’.
Key words: ALS inhibitor, herbicide resistance, resistance management, seed bank, selection pressure.
Herbicide rotation can be defined as the application of
herbicides of different sites of action (i.e., groups) to multiple
crops over muhipie growing seasons in a field (Beckie 2006).
The level of adoption of herbicide rotation for weed rcsi.stance
management has increa.sed markedly over the past decade in
the prairies of western Canada (provinces of Alberta,
Saskatchewan, and Manitoba). In 1998, fewer than 50% of
farmers practiced herbicide rotation, even though awareness
was high (Beckie ci al. 1999). By 2003, 70 to 90% of farmers
in Saslatchewan and Manitoba, respectively, claimed to rotate
herbicides by site of action (Beckie 2007). It is the most
common herbicide resistance management practice cited by
farmer-s in survey questionnaires conducted in Canada (Beckie
2007) and Australia (Shaner et al. 1999). At present, over half
of the herbicide products sold in Canada have resistance
management labeling, which includes group identification
symbols on the label and guidelines for resistance manage-
ment practices in the use directions (M. Downs, PMRA,
personal communication). This labeling regulation in Canada,
which was first implemented in 1999, probably facilitated the
adoption of heiBicide rotation. However, the lack of suitable
herbicide options associated with crop rotation can be a
substantial deterrent to herbicide rotation (Bourgeois ct al.
1997; Legere et al. 2000).
Acceptance by farmers of herbicide mixtures for proactive
resistance management of broadleaf weeds has been aided by
cost-incentive programs from industry, formulated mixtures
DOi: 10.1614/WTJJ9-008.1
* Plant Sckniist, Agriculture and Agri-Food Canada, Saskatoon. Saskatchewan,
Canada S7N 0X2; Plant Scientist, INRA, Universite de Bourgogne. ENESAD,
Biologic ei Gesiion des Adveniices. Dijon Cedes, France. Corre^wnding author’s
E-mail; Hugh.Beckie@agr-gc.ca
(c.g., phenoxy plus an Al^ inhibitor), and the rapid evolution
of resistance in specific cases. A survey of 1,800 farmers in the
Canadian prairies from 2001 to 2003 indicated that a
majority of them intentionally or inadvertently tank-mix
herbicides to delay or manage ALS-inhibitor-resistant
broadleaf weeds (Beckie cc al. 2008b). For farmers dealing
with ALS-inhibitor resistance, the ALS-inhibitor partner may
provide relatively broad-spcctrum weed control while the non-
ALS-inhibitor partner controls the resistant broadleaf weed,
However, if mixing partners of different sites of action do not
meet the criteria of similar efficacy and persistence, plus
different propen-sity for selecting for resistance in target
species, the effectiveness of mixtures for delaying target-site
resistance will be reduced. Mixtures may inadverrcntly
accelerate the evolution of multiple resistances if they fail to
meet basic criteria for resistance management and arc applied
repeatedly (Rubin 1991). Moreover, mixtures to prevent or
delay metabolic resistance in grass weeds, where this
mechanism is most prevalent, may be cost-prohibitive unless
the mixed graminicides interact syncrgistically and can be
applied at lower rates. Obstacles to farmer adoption of
mixtures for herbicide resistance management indude in-
creased cost and availability of suitable mixing partners that
meet the criteria outlined above.
Herbicide rotations or mixtures generally have the greatest
effect in ddaytng resistance when the mechanism conferring
resistance is target site-based, the target weed species are
highly scif-pollinated, and seed spread is restricted (Beckie et
al. 2001). Based on a compounded resistance frequency
model, the probabilit)' of herbicide-resistant mutants W'ith
multiple mechanisms of resistance (target site-based) in an
unselectcd population is the product of the probabilities of
Beckie and Reboud: Selecting for weed resistance • 363
635
resistance to each affected herbicide site of action and thiK is
relatively rare (Wrubcl and Gressel 1994). Herbicide
mixtures, whose components arc equally effective against the
target weed species, are predicted through model simulations
to delay resistance longer than rotations (Diggle et al. 2003;
Fowled et al. 1997).
Evolution of herbicide resistance is often attributed to a
lack of herbicide rotations or mixtures; i.c., frequent or
repeated use of herbicides of the same site of action.
Nevertheless, there is epidemiological or anecdotal evidence
for the utility of herbicide rotations and mixtures in delaying
the evolution of target-site resistance (Bcckie 2006). However,
little research has quantified how these practices impact
herbicide resistance selection in weeds. Only one long-term
experiment has examined the effect of frequency of herbicide
use on the evolution of resistance. In a large-plot experiment
conducted in western Canada from 1979 to 1998, resistance
in wild oat {Avena fatua L.) to triallate occurred after 18 yr,
where the herbicide was applied annually in continuous spring
wheat, but not where it was applied 10 times in the wheat
phase of a wheat-fallow rotation over the same period (Beckie
and Jana 2000).
In this paper, we describe the results of a 4-yr field
experiment conducted at two sites in Saskatchewan that
examined the impact of herbicide rotation and mixture in
selecting for ALS-inhibiior resistance in a broadleaf weed
species. The model species chosen was field pcnnycress
(referred to as stinkweed in Canada). Field pennycrcss is a
diploid (2« = 14), .self-compatible, and readily autogamous
(ca. 3% outcrossing; Hume 1990) annual weed that is a
member of the Brassicaceae family (reviewed in Best and
McIntyre 1975; Warwick et al. 2002). The species has a
persistent seed bank of 10 to 20 yr (Van Acker 2009), high
fecundity, and the growth habit of a winter or summer
annual. Native to Eurasia, this crucifer is widely introduced
and naturalized in temperate regions around the world. The
species occurs in all the Canadian provinces and territories,
and is an economically important weed of field crops in the
Canadian prairies. Farmers spend almost $200 million
annually to control this weed (J. Lceson, unpublished data).
In weed surveys of annual crops in the early 2000s across the
prairies, field pennycress rank^ seventh in relative abundance
(Lecson et al. 2005). Resistance to ALS-inhibitor herbicides in
this species was first reponed globally in two populations from
Alberta in 2000 (Bcckie et al. 2007).
Materials and Methods
Sites. The experiment was conducted from 2004 to 2007 at
two sites in Saskatchewan, near Watrous and North Battle-
ford. The Watrous site is located in the .subhumid Aspen
Parkland ecoregion (defined by climate, natural vegetation,
and soils) at 51-4° N, 108.6° W; the North Batdeford site is
located in the subhumid Boreal Transition ecoregion at 52.0°
N, 105.2° W. The sites were located on permanent
pastureland owned by the Prairie Farm Rehabilitation.
Administration of Agriculture and Agri-Food Canada.
Because herbicide-resistant weed seed was used in the
experiment, a large isolation buffer between adjacent cropland
was desired. A 1-ha fenced area at each site had been cropped
annually since 1997. Observations of field pennycress
recruitment from 1997 to 2003 confirmed the absence of a
seed bank at each site. The soil at the Watrous site is an
Oxbow sandy loam (Udic Haploboroli) with 4.0% organic
matter (OM) and pH 7.3; soil at the North Battleford site is a
Meeting Lake loam (Boralfic Haploboroli) with 2.5% OM
and pH 7.0. All soils were nonsalinc. Precipitation and air
temperature during the growing season (May to August) were
recorded at weather stations nearest to the two sites (26 to
42-km distance).
E^^rimencal Design and Protocol. Fhc experiment was
arrar^ed in a randomized complete block design w’ith four
replications. Plot dimensions were 4 by 10 m. Treatments
consisted of the ALS inhibitor (group-2 herbicide; Mailory-
Smith and Retzinger 2003), ethametsulfuron, applied in
rotation with a bromoxynil/MCPA formulated herbicide
({280 g/L bromoxynil, a photosystem-II inhibitor] / [280 g/L
MCPA ester, a synthetic auxin]) at an ALS-inhibitor rotation
frequency of 0, 25. 50, 75, and 100% (i.e., zero to four
applications, respectively) over the 4-yr period (4 able 1).
Both herbicides generally have short soil residual activity
under western Canadian climatic conditions (Saskatchewan
Ministry of Agriculture 2008). However, the soil persistence
and activity of ethametsulfuron, a sulfonylurea herbicide,
depends upon soil OM and pH. Each phase of the herbicide
rotation was present each year. Thus, the 25% ALS-inhibitor
rotation frequency was represented by four treatments:
ethametsulfuron applied in yr 1, 2, 3, or 4 (“on” years) with
bromoxynil/MCPA applied in the “off’ years (Table 1). The
50% ALS-inhibitor rotation frequency was represented by six
treatments: ethametsulfuron applied in yr 1 and 2; I and 3; 1
and 4; 2 and 3; 2 and 4; and 3 and 4. The 75% ALS-inhibitor
rotation frequency was represented by foiu treatments:
ethametsulfuron applied in yr 1, 2, and 3; 1,2, and 4; 2, 3,
and 4; and 1, 3, and 4. The sole mixture treatment was
ethametsulfuron plus bromoxynil/MCPA applied each year
(Table 1). Additionally, a nontreated (weedy) control and a
weed-free control treatment were included.
Herbicides were applied using a hand-held boom equipped
with flat fan nozzle tips' that delivered a spray volume of
no L/ha at 275 kPa when the majority of weed seedlings
were in the two- to three-leaf stage. Commercial formulations
of the herbicides were applied at recommended rates
(Saskatchewan Ministry of Agriculture 2008). Ethametsul-
furon was applied at 22 g ai/ha, and the bromoxynil/MCPA
formulated herbicide at 550 g ai/ha. A nonionic surfactant"
was added to the ethametsulfuron spray solution at 0.25%
(v/v). Sparse populations of other broadleaf weeds were
control!^ by roguing as required. Wild oat was controlled In
all plots by fall-applied granular triallate.
Hard red spring wheat ('AC Barrie’) was seeded using a disc
drill with 20-cm row spacing in early to mid-May, depending
on soil moisture and temperature conditions. The crop was
seeded parallel to the short dimension of plots at 80 kg/ha at a
2.5 to 5-cm depth, depending on soil moisture conditions.
Fertilizer nitrogen (N), pho.sphorus (P), and sulphur (S) were
seed-placed or side-banded at races based on soil test
recommendations. Plots were tilled (8 to 10 cm deep)
364
Weed Technology 23, July-Scprember 2009
636
Table 1 . Experiment treatments: Acetolactate syntliase (ALS) inhibitor (ethametsutfiicon) in natation or mixture with bromoxynii/.MCPA.'’
2
ALS'inhibitor rotation iteatracnts;
3
4
5
(i
7
8
9
10
J1
12
13
!4
15
16
17
18
.Mixture treatment:
19
Nontreated (weedy) control
Weed-free control
0% frequency — no ALS inhibitor (bromoxyiMl/MCPA applied each year)
15% frequency — ALS inhibitor in jt 1 (btomos^il/MCPA yr 2, 3, 4)
25% frequency — ^ALS inhibiror in jt 2 (bromojcj-nil/MCPA yi U 3, 4)
25% freqi^ncy — ^ALS inhibitor in jt 3 {brorooxjTiil/MCPA yr I, 2, 4)
25% frequency — ALS inhibitor in jt 4 (bromoxynil/MCTA yr I, 2, 3)
50% frequency — ALS inhibitor in yr 1, 2 (brcmioxynil/MCPA jt 3, 4)
50% IrequerKy— ALS inhibitor in yr 1, 3 (bfwnoxynil/MCPA yr 2, 4)
50% frequency — ALS inhibitor in yr I, 4 (bromoJonil/MCPA yr 2. 3)
50% freqtiency — ^ALS inhibiror in yr 2, 3 (brotnoxynil/MCPA jt 1,4)
50% frequency— A15 inhiWror in jt 2, 4 (bromoxjTjil/MCPA w 1.3)
50% frequenej- — ALS inhibitor in yr 3, 4 (lwomoxynilA4CPA yr 1. 2)
75% frequency — ALS inhibitor in yr 1, 2, 3 (brotnoxynii/MCPA yr 4)
75% frequency — ALS inbilMtor in yr J, 2, 4 (bromoxynil/MCPA yr 3)
75% frequency — ALS inhibitor in jt 2, 3, 4 (bromoxynil/MCPA yr 1)
75% frequency — ALS inhibitor in yr !, 3. 4 (bromoxynil/MCPA yr 2)
100% frequenej’ — AI.S inhibited applied each y«r (no bromoxynii/MCPA)
ALS inhibitor + bromoxynil/MCPA eadi year
Orthogonal contrasts:
Treatment 3 vs. 19 {a!i measured variables)
Treatments 4-7 (avenged) vs. 19 (ail measured variables)
Treatment 1 vs. 3; 1 vs. 19 (% resistant seeds or seedlings in the seed bank)
' Ethamttsuifuron applied at 22 g ai/ha (plus nonionic surfactant at 0.25% v/v); bromoxynil/MCI’A formulated herbicide applied at 550 g ai/ha.
iength-vvise once immediately prior to .seeding using a field
cultivator with mounted harrows.
'I'hc field pennycress seed bank at both sites wtis established
in 2003, the year prior to initiation of the experiment. In late
autumn near freeze-up, a ratio of 5 ethametsulfuron-resistant
seed : 95 susceptible seed mixture of field pennycress was
drilled into the soil at a 2.5-cm maximum depth in the long
direction of plots (except for the weed-free control treatment)
at a rate of 75 germinable seeds/m^. The susceptible
population originated from central Saskatchewan and was
confirmed to contain no resistant individuals; the resistant
population, CAB, originated from central Alberta. Seeds from
both populations exhibited little dormancy; the germination
rate for the seed lots consistently exceeded 95%. 'I he resistant
biotype has been well characterized (Bcckic et al. 2007). fhe
biotype is highly resistant to ethametsulfuron, exhibits a low
level of resistance to mcrsuifliron and imazethapyr, but is not
resistant to fiorasulam, a triazolopyrimidine ALS inhibitor.
Resistance in the CAB population was attributed to a Proi^?
I.eu mutation, conferred by a single, dominant gene.
Data Collection. Crop and weed plant density were
measured 3 wk after emergence in four randomly placed
0.25-m^ quadrats per plot. At 3 wk after herbicide applica-
tion, weed seedling density was enumerated using the .same
procedure. Field pennycress aboveground biomass was
harvested at maturity. Shoot biomass from each of the four
quadrats from each plot was collected in a cotton bag and
subsequently dried in a forced-air drying room. Thereafter,
plants were threshed and seeds were weighed and counted.
Seeds w'ere subsequently stored at ambient room temperature.
Wheat grain yield was determined at crop maturity by
harvesting aboveground biomass in two 1-m^ quadrats per
plot using procedures similar to those u-sed for the weed
harvest. Grain weight was adjusted to 10% moisture content.
The crop that remained in each plot was harvested using a
small-plot combine, ensuring that residue was contained
within the plot area.
Each year in early spring after the preceding harvest, field
pennycress seeds from each plot were tested in the greenhouse
for resistance to ethametsulfuron. A total of 150 seeds from
each sample (one aggregate sample per plot) were screened.
Twenty-five seeds were planted in a potting mixture of soil,
peat, vermiculitc, and sand (3 : 2 : 2 : 2 by volume) plus a
slow-rcicasc fertilizer (150 g of 26-13-0 per 75 L potring
mixture) in trays (each tray considered a replicate) measuring
52 by 26 by 5 cm. Environmental conditions were a 20/16 C
day/night temperature regime with a 16-h phocopciiod
supplemented with 230 pmol/(m^-s) illumination. Flats were
watered daily to field capacity. Seedlings were treated with
ethametsulfuron at the two-leaf stage. The herbicide was
applied using a moving-nozzle cabinet sprayer equipped with
a flat-fan nozzle tip' calibrated to deliver 200 L/ha of spray
solution at 210 kPa in a single pass over the foliage. A
nonionic surftctani^ was added at 0.25% (v/v). Treatments
(and nontreated controls) were replicated three times in this
completely randomized experiment and the tests were
repeated. In early spring each year, any seeds not tested for
resistance were returned to plots in areas where they had been
harvested the previous year.
In mid-Aprii of 2008, the year after the experiment was
terminated, soil was sampled to determine the viable fraction
of the seed bank and percentage of seeds resistant to
ethametsulfuron. Twenty-five 5'Cm-diam by 10-cm-deep soil
cores, sampled in a “W’ pattern, were collected from each
plot. Cores from each plot were combined and the bulk
samples were frozen until late spring/summer of 2008, when
four growth periods were conducted in the greenhouse in trays
measuring 52 by 26 by 5 cm. Soil in trays was watered twice
Beckic and Reboud: Selecting for weed resistance
365
637
daily. A liquid N-P-S fertilizer was applied to eadi tray once
during each of the four growth periods. Field pennycress
seedlings were counted and then sprayed by the four-leaf stage
with ethametsulfuron at 22 g ai/ha using the proc»lur«
described previously. Three wk after spraying, survivors were
counted, removed, and the soil was remixed. The sample was
returned to the freezer for 3 wk in advance of the second
growth period. This procedure was repeated for the third and
fourth growth periods.
Data Analyses. Data were logarithmically or .square-root
transformed prior to ANOVA. Data were subjected to a
combined ANOVA using the Proc MIXED procedure in SAS
software (SAS 1999). Replicate, site, and year were considered
random effects, and herbicide treatment as a fixed effect.
Weed response to treatments (seedling denslt}', aboveground
biomass, seed production, percentage of seeds produced
annually resistant to cchametsuiftiron, percentage of viable
seeds in the seed bank at the end of the experiment resistant to
ethametsulfuron) was analyzed using curvilinear regression.
Data were averaged across phases for the 25, 50, or 75% ALS-
inhibitor rotation frequencies. Weed responses to ALS-
inhibitor rotation frcqucnc}' were best described by the
quadratic (2nd-order polynomial) or exponential models.
Regression aiialy.ses were performed on treatment means
averaged over replications as recommended by Gomez and
Gomez (1984). Coefficients of determination were
calculated as described by Kvaheth (1985) u.sing the residual
sum of squares value from the SAS output. Standard errors of
the parameter estimates were calculated. Planned orthogonal
contrasts (listed in Tabic 1) were performed to compare
specific treatment means when significant treatment effects
from ANOVA were indicated (P 5 0.05) (Bertram and
Pedersen 2004).
Results and Discussion
Weather Conditions. Total growing season precipitation was
above normal for two sice-years, and near-normal for six site-
years (data not shown). At the time of crop establishment in
May, less than 80% of the normal (30*yr mean) monthly
precipitation was received for three of the eight site-years.
Average growing season tcmperature.s were near normal for all
site-years.
Wheat Stand Establishment and Grain Yield. Satisfactory
crop plant densitie.s were realized in all years at both sites.
Wheat seedling density at 3 wk after emergence ranged from
136 ± 3 (SE) plants/m^ in 2007 to 241 ± 6 plants/m^ in
2004. Relatively low stand densities in 2007 were caused by
dry soil conditions at planting. Combined ANOVA results
indicated no significant effect (P > 0.05) of herbicide
treatment on wheat grain yield (data not shown). Wheat
yield loss by field pennycre.ss interference can vary widely,
depending on plant densities and relative time of emergence
(Warwick et al. 2002). Based on yield loss equations derived
from data from a 10-yr study in Saskatchewan from 1981 to
1990, field pennycress at a density of 52 plants/m^ would be
expected to result in only a 3% grain yield loss in spring wheat
(Hume 1993). In the spring of 2004 (first year of the
ALS inhibitor appiications
F^rc I . Response of field pennycress seedling density (“•’ denotes means. ' O ’
denotes p!ia.ses of an herbicide rotation; maximum low and high weed control SE
bars shown) to cthamcisuJfuron, an acetolactaie synthase (AI.S) inhibitor, applied
one (25% frequency), two (50% frequency), three (75% frequency), or four
(100% frequency) times during the 4-yi experiment (quadratic regression
equation with SE in bradeets: y = tfV + + c where a = the curvilinear
coefficient. 6 = the linear coefficient, c = the intercept, y — rhe dependent
variable, and x= the number of ALS-inhibiior applications; is significant (**)
at P < 0.01).
experiment) immediately prior to herbicide treatment, field
pennycress seedling densities across al! plots at the two sites
averaged 48.7 ±2.1 plants/m^.
Weed Seedling Density- Weed Control. The decline in field
pennycress control in wheat was curvilinear with increasing
number of ALS-inhibitor applications (Figure 1). Weed
control over 4 yr averaged 96% in plot,s treated annually
with bromoxynil/MCPA (0% ALS-inhibItor rotation fre-
quency). Similarly, weed control over 4 yr averaged 97% in
the herbicide mixture (ethametsulfuron + bromoxynil/
MCPA) treatment (nonsignificant contrast, P > 0.05) (Ta-
ble 2). Field pennycress is normally highly sensitive to
ethametsulfuron or bfomoxynil/MCPA. After one application
of ethametsulfuron (in yr 1, 2, 3, or 4), weed control declined
slightly (mean of 92%). Nonetheless, this level of control was
less than that of the mixture treatment (significant contrast,
P s 0.05). Maximum low and high weed control SE bans
shown in Figure 1 indicate the variability in weed control
among the phases of a given ALS-inhibitor rotation frequency.
Fidd pennycress seedling density was only suppressdl (i.e.,
< 80% efficacy) by two or more ALS-inhibitor applications.
After two applications of ethametsulfuron (in yr 2, 3, or 4),
weed control had declined to 62%; after three applications of
the ALS inhibitor (yr 3 or 4), weed control averaged 46%,
declining to 31% after four consecutive annual ALS-inhibitor
applications. Therefore, starting with a weed population
comprising 5% ALS-inhibitor-resistant individuals, weed
366 • Weed Technology 23, Juiy-September 2009
638
'['able 2. Field pennycress response averaged os'er 4 yr of the ei^riinent {s^ bank after 4 yr) for the 0 and 25% acetolaccaie synthase (ALS) inhibitor (ethametsulfuron)
rotation frequency treatments and mixture (ALS inhibitor plus brotnoxyiiil/MCPA) treatment.
Seedling density
Biomass at maturity
Seed production
Resistant seed'
Resistant seed baiik‘
% o>nciol
g/m^
ftumber/m'
%
%
0% Al5-inhibitor frequency (treatment 3, Table 1)
25% ALS-inhibiccir frequency (treatments 4—7 averaged.
96
0.3
135
2
4
Table i)
92
11.0
1210
59
29
Mixture (treatment 19, Table 1)
97
0.6
178
3
8
Contrast*’; 0% A1.S inhibitor vs. mix-tiire
Contrast: 25% ALS inhibitor vs. mixture
NS
NS
NS
NS
NS
‘ The percentage of seeds resistant to ethametsulfuron in the nontreaied control was 5% when averaged over 4 yr (annual .seed production) and in die seed bank at the
end of tlic experiment — not significantly different (P > 0.05) from the 0% ALS-inhibhor rotation frequency treatment or mixture treatment.
' significant at P £ 0,05; N.S, nonsignificant.
control would not noticeably decline after one application of
an Ai-S inhibitor, but would be unacceptable (i.e., < 80%
efficacy) after only two applications.
Weed Biomass and Seed Production. Both field pennycress
biomass at ntaturity and seed production responded similarly
as seedling density to increasing number of ALS-inhibitor
applications (Figures 2 and 3). Responses were best described
by the quadratic function. The greatest variation in biomass
and seed return responses among phases, similar to that of
weed seedling density, was obscn'cd in plots with the 50%
(two-appiication) ALS-inhibitor rotation frequency. After
four ALS-inhibitor applications, field pennycress plant
biomass exceeded 100 g/m“ (i.e.. 1,000 kg or 1.0 tonne/ha).
Whereas 155 secds/m^ were produced in plots with the 0%
ALS-inhibitor mtation frequency, 1,210, 5,770, 16,600, and
25,700 seeds/m^ were produced where ethametsulfuron was
applied one (25%), wo (50%), three (75%), and four times
(100%), respectiv'cly.
In field studies in Saskatchewan, Hume (1993) found that
spring-emerging field pennycress in wheat produced about
14,000 seeds per plant. Given its persistent seed bank, field
pennycrc.ss control by herbicides and crop competition is
essential to minimize seed production, a basic tenant of
herbicide-resistance management, Four-yr means of weed
biomass (0.6 g/m"^) and seed production (178 sceds/m")
responses for the herbicide mixture treatment were similar to
those for the 0% ALS-inhibitor rotation frequcnc)' treatment
(nonsignificant contrasts, P > 0.05), indicating control of
both resistant and susceptible field pennycress by bromoxynil/
MCPA, However, means for both plant variables were
significantly different between rhe 25% ALS-inhibitor
rotation frequency and the mixture treatment (Table 2).
Percentage Resistant Seeds. Greater than 95% of seeds
tested were viable (data not shown). In contrast to weed
density, biomass, and seed production, the percentage of seeds
resistant to ethametsulfuron as a function of its application
frequency was best described by an exponential (reciprocal)
model (Figure 4). The resistance percentage increased rapidly
from 2% (0% ALS-inhibitor rotation frequency) to nearly
60% after only one ALS-inhibitor application (25% rotation
frequency). After two applications, the resistance percentage
had increased to 92%, but changed little with one or two
additional applications over the 4-yr period. For the mixture
treatment, the percentage of seed resistant to the ALS
inhibitor averaged 3%, similar to that of the 0% ALS-
inhibitor rotation frequency treatment (nonsignificant con-
trast, P > 0.05). In the nontreated control treatment, a 4-yr
mean of 5% resistance was measured, unchanged from the
resistance frequency established at rhe beginning of the
experiment.
Tire rapid increase in resi.scance frequency of progeny of
surviving plants after only one ALS-inhibitor application heip.s
explain the frequent observations by farmers of good weed
control in one year hut failure the next, when lusing die same
herbicide or product with the same site of action. Weed
ALS inhibitor applications
Figure 2. Response of field pennycress biomiss at maturity (“•' denotes means,
‘O' denotes phases of an herbicide rotation; maximum low and high biomass SE
bars showa) to ethametsulfuron, an acetolactate synthase (ALS) inhibitor, applied
one (25% frequenc)-). wo (50% frequency), three (75% frequency), or four
(100% frequency) times during the 4-yr e.xperimenc (quadratic regression
equation widi SE in brackets: y “ r/x' fcc + c where i< the curvilinear
oxfFicient. i — the linear coefficient, c = the intercept, y — the dcpendcin
variable, artd x — the number of ALS-inhihitor applications; R~ is significant ('T
at P < O.Ol).
Beclde and Reboud: Seiecting for weed resistance • 367
639
ALS inhibitor applications
Figure 3. Response of field peimycress seed production ('•’ denotes means. ‘O’
denotes phases of an herbicide rotation: niaximum low and Si^h seed production
SE bars shown) to echamctsuifiiron, an acetolactaie synthase (AI5) inhibitor,
applied one (25% frequency), two (50% fretjucncy). three (75% frequenq'), or
four (100% frequency) times during the 4-yr experiment (quadratic regression
equation with SF. in brackets: y = rtx" +• ix + c where a = the airs-ilinear
coefficient, b ^ the linear coefficiein. c — die intercept, _y = the dependent
variable, and x ~ the number of ALS-inhibitor applications: R’ is significant (’*)
at P < 0.01),
populations in a field undergoing herbicide resistance
selection are typically a mixture of homozygous and
heterozygous individuals, with resistance alleles segregating
from one generation to the next. The high selection pressure
exerted by ethamecsulfuron on this mixed resistant/susceptible
field pennycress population, with resistant individuals pos*
sessing target-site mutation conferred by a single nuclear gene
with a high degree of dominance, are ideal conditions for the
rapid enrichment of resistance alleles with increasing number
of ALS-inhibitor applications.
Percenti^ Resistant Seedlings in the Seed Bank. I'he
buffering of enrichment of ALS-inhibitor resistance by
susceptible seed in the seed bank was apparent at the end of
the experiment (Figure 5). The level of resistance in the seed
bank in plots with 0% ALS-inhibitor rotation frequency was
4%; this level of resistance rose to 29% after one application,
54% after uvo applications, 71% after three applications, and
85% after four applications of ethamecsulfuron. In the
mixture treatment, the level of resistance was 8%; however,
orthogonal contrast indicated no significant difference
{P > 0.05) from either the nontreated control (5%) or the
0% ALS-inhibitor rotation frequency treatment (Tabic 2).
The percentage of recruited seedlings resistant to ethametsul-
ftiron was greater in plots treated with 25% ALS-inhibitor
rotation frequency than that of the mixture treatment
(Table 2).
I'he similar resistance frequency in the seed bank of the
nontreated control (5%), or the 0% ALS-inhibitor rotation
ALS inhibitor applications
Figure 4. Rciponic of perceniage resistance of field pennycress seeds ('•' denotes
means, ‘O’ denotes phases of an herbicide rotation; maximiiro low and high
resisuni seed percentage SE bars shown) to ethameistilftiron. an acciolaaate
synthase (AI.S) inhibitor, applied one (25% frequency), two (50% frequency),
three (75% frequency), or four (100% frequency) times during the 4-yr
o^icriment (exponential reciprocal regression equation with SE in brackets: y —
where c “ the intercept, be = the initial slope, y “ the dependent variable,
and * = the number of ALS-inhibitor applications; if is significant (**) at
1> < 0,01).
frequency (4%), as that of the initial seed bank established in
2003 suggests little fitness difference between these resistant
and susceptible field pennycress populations in the absence of
selection pressure. 'I'he similar percentage resistance in the
seed bank for the 0% AJ-S-inhibitor rotation frequency and
mixture treatments relative to that of the nontreated control
indicates essentially zero selection pressure (i.c., resistant and
susceptible genotypes controlled equally). Thus, Htde decline
would be expected in the proportion of resistant to susceptible
individuals in a field over time after use of the ALS inhibitor
was discontinued.
The relatively slow evolution of ALS-inhibitor resistance in
field pennycress populations in western Canada is partially
due to the longevity of seeds (10-20 yr) in the seed bank.
Nevertheless, after four ALS-inhibitor applications, over 80%
of seedling recruited from the seed bank were resistant. For
weed species such as kochia \Kochia scoparia (L.) Schrad.j with
a short-lived seed bank (1-2 yr; Fricsen et al. 2009), the seed
bank resistance response would probably be depicted by a
steeper curve than that observed in this experiment. Similarly,
less buffering of resistance evolution by the seed bank would
occur under a low soil disturbance no-cillagc environment
(Bcckic ct ai. 2008b). In the minimum tillage regime used in
this study — i.e., one spring tillage operation — partial weed
seed burial to tillage depth would favor seed dormancy and
persistence (Warwick et al. 2002).
368
Weed Technology 23, July-Sepcember 2009
640
ALS inhibitor-use frequency (%)
Figure 5. Response of percentage resistant field jwnnycrcss seedlings ('•’ denotes
means,, 'O' denotes phiises of an herbicide rotation; maximum low and high
resistant seedling percentage SE bars sliown) recruited from the seed bank to
ethameisulfuron, an acciolactatc synthase (AL^) inhibitor, applied one (25%
frequenq'), rwo (50% frequenq’), three (75% frcqtwiKy), or four (100%
freqiienq') times during the 4-yr experiment (quadratic regression equation with
SE in brackets; y = ax^ + bx f- c where a = the curvilinear cocfiicient. b ~ the
linear coefficient, c = the intercept, y — the dependent variable, and x — the
number of ALS-inhibitor applications: /?' is significant (**) at P < 0.0!).
The results of this study dramatically illustrate how rapidly
ALS-inhibitor resistance can evolve in sensitive weed species
with repeated ALS-inhibitor applications. The mo.si relevant
dau of this study is arguably that of the seed bank resistance
enrichment as impaacd by herbicide rotation and mixture.
The enrichment of resistant alleles is roughly proportional to
the number of ALS-inhibitor applications, although a decline
in the rate of increase in the level of resistance was apparent
after three applications (Figure 5). In the Canadian prairies,
the high relative abundance and long persistence of field
pennycress in the seed bank favors the ex!.stence of a mixed
population with some susceptible individuals, even under
intense ALS-inhibitor selection pressure. Moreover, some
un-sprayed seedlings (e.g., spray misses or near water bodies) or
those receiving a sub-lethal herbicide dose due to a myriad of
factors afFeciing retention and absorption will survive,
reproduce, and thus maintain susceptible genotypes in seed
banks, even under high ALS-inhibitor selection pressure.
Because ALS-inhibitor resistance can evolve in field weed
populations after fewer than five applications (Beckie 2006),
herbicide rotation as a tactic to delay such resistance is
probably short-term at best. Based on modeling simulations
and results presented herein, a mixture of an AI.5 inhibitor
with a photosysrcm-II inhibitor (site B, group 6; Mallory-
Smich and Retzinger 2003) or auxinic herbicide (group 4) or
both is a much more effective tactic than rotation to delay
ALS-inhibitor resistance. The unregistered mixture of etha-
mctsulfuron and bromoxynil/MCPA meet the criteria for
effective proactive resistance management of field pennycress.
If a former plans to use an ALS-inhibitor herbicide for
broadly weed control, we recommend it be tank-mixed with
a suitable partner whenever possible to slow the steadily
increasing number of ca.se.s of ALS-inhibitor resistance in
broadleaf weeds in the prairies.
Althoi^ small-plot studies are inadequate in assc.ssing the
risk of multiple resistance in weeds as a result of repeated use
of the same mixture, the rarity of ALS inhibitor plus auxinic
or photosysteni-ll inhibitor multiple resistance in broadleaf
weed species in the (Canadian prairies (only one ca.se
documented in 1996 by Hall ct al. 1998) is compelling
evidence that alleles resistant to these non-ALS inhibitors
introduced over 50 yr ago are present at extremely low
frequencies in populations. Indeed, there are few cases of weed
resismnee In w'estern Canada to synthetic auxins or photosys-
tem-II inhibitors, despite their intensive and widespread use
(Beckie et al. 2008a) .since the beginning of the agrichemical
era. An unusually low rate of mutation of the locus conferring
resistance, or alternatively few fit mutations, arc speculated to
contribute to the slow evoiurion of resistance to phenoxy and
some other low-risk herbicides (Jasieniuk et al. 1996).
The wide disparity in rate of herbicide resistance evolution
to ALS inhibitors vs. phenoxy herbicides or phocosystem-II
inhibitors is best exemplified in kochia. ALS-inhibitor
resistance in this species was first documented in the prairies
in 1988, 5 yr after introduction of herbicides with this site of
action (Friesen ct al. 2009). Twenty yr later, about 90% of
populations in the Canadian prairies exhibit some level of
ALS-inhibitor resistance (Beckie 2009), whereas resistance in
this species to non-ALS inhibitors has not been reported.
There are few alternative herbicide options to control ALS-
inhibitor-resistant kochia in annual legume crops, such as
field pea {Pisum sativum L) and lentil [Lens culimris L.)
grow'n on over 2 million ha in Canada in 2008 (Statistics
(Canada 2008). In these and other crops such as mustard
(Brassica juncea L. or Sinapis alba L.), farmers rely on ALS-
inhibitor herbicides to control broadleaf weeds. Although coo
late for kochia, w'e believe utilization of herbicide mixtures for
proactive resistance management of other broadleaf weeds
with a propensity' for ALS-inhibitor resisunce evolution will
be more cosr-cfFcaive and sustainable in the long-term than
ALS-inhibitor herbicides applied in rotation. The challenge
for industry is finding suitable non-ALS-inhibitor partners
with selectivity in our major dicot crops.
Sources of Materials
' Tecjei 8002VS nozzle tip, Spraying Systems Co., North Avenue
at Schmale Road. P.O. Box 7900, N^caton, 11. 60189-7900,
^ Agra! 90® surfectant, Norac Concepts Inc,, P.O. Box 62023,
Ottawa, ON nC 7H8.
Acknowledgments
We thank Scott Shirriff and Christopher Loztnski,
Saskatoon Research Centre, for their excellent technical
assistance.
Beckie and Reboud: Selecting for weed resistance • 369
641
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Received January 23, 2009, and approved April 15, 2009-
370
Weed Technology 23, July-.Seprefnber 2009
642
Herbicides used in combination can reduce
the probability of herbicide resistance
in finite weed populations
A J DIGGLE*, P B NEVEf & F P SMITHf
*CLlAfA, University of Western Australia. Crawley. WA, Australia, ^Western Australian Herbicide Resistance Initiative,
School of Plant Biology, University of Western Australia. Crawley, WA, Australia, and XCSIRO Sustainable Ecosystems, Wembley,
WA, Australia
Received 27 September 2002
Revised version accepted 7 July 2003
Summary
A simulation study was conducted to examine the effect of
pattern of herbicide use on development of resistance to
two herbicides with different modes of action in finite
weed populations. The effects of the size of the treatment
area (analogous to initial weed population), germination
fraction and degree of self-pollination in the weed were
investigated. The results indicate that the probability of
developing resistance to one or both herbicides decreases
as the size of the area/initiai population decreases. For
treatment areas of 100 ha or less with an initial weed
seedbank of 100 seeds m““ and initial frequencies of the
resistance genes of 10”^, development of resistance to both
herbicides (double-resistance) is uncommon within
50 years for all types of weeds if both herbicides are used
in all years (used in combination). If herbicides are used in
alternate years (rotated) double-resistance almost always
occursinlOO ha areas but is uncommon in areas of 1 ha or
less. The results suggest that adoption of practices that
limit moveni^nt :Gf weeds’^ i conjunction with;;using
herbicides in^ compilation rather than in rotation can
substantially delay development of herbicide resistance.
Keywords: simulation, modelling, mixtures, reduction,
herbicide resistance.
introduction
The development of herbicide resistance in weed popu-
lations under herbicide .selection is an evolutionary
phenomenon. Herbicides are very intense selective
agents and where genetic variability for herbicide
response exists in weed populations, evolution of herbi-
cide resistance can be rapid. ;The probability and rate of
herbicide resistance evolution depends on the interplay
sbetweettLtbegpopnlation dynamics and population gen-
etics of.:wee(lpopujatiGns<Maxwell.& Mortimer^ 1994;
Jasieniuk eJ'.a/:f-l996; D & Neve;v200l); Important
evolutionary factors include the intensity of selection
(degree of discrimination between genotypes); the fre-
quency of resistance traits in natural (unselected) pop-
ulations; the mode of inheritance of resistance; the
relative fitness of susceptible and resistant biotypes in
the presence and absence of herbicide; and gene flow
within and between populations. The intrinsic popula-
tion dynamics of weed populations is also important,
especially in the area of seedbank dynamics where it is
recognized that a persistent seedbank can act as a buifer
to evolution (Mortimer el al.„ 1993).
Several simulation models of the population genetics
and dynamics of herbicide resistance in weed populations
have been developed (Gressel & Segel, 1978; Maxwell
et al., 1990; Gardner et al.. 1998; Cavan et ai, 2000).
These models differ in their approaches, particularly in
relation to population genetics, and the applications and
limitations of the various methodologies have been
discussed by Diggle and Neve (2001). In particular, the
authors draw attention to the benefits of explicitly
accounting for each genotype in the population. The
common alternative approach of assuming Hardy-
Weinberg equilibrium between successive generations
may lead to erroneous conclusions about resistance
Correspondence: A J Diggle, Western Australian Department of Agriculture, 3 Baron Hay Court, South Perth, WA 6151, Australia. Tel: ( + 61)
8 9368 3669; Fax: (-^ 61) 8 9367 2625; E-mail: adiggle^'agTic.wa.gov.au
European Weed Research Society Weed Research 2003 43, 371-382
643
372 A J Diggle et al
evolution under conditions that violate the assumption
of random mating. Such conditions are common and
include incomplete germination, immigration and emi-
gration of seed and pollen (gene flow); staggered
flowering time; and any bias towards self-pollination.
These factors affect the rate of evolution of herbicide
resistance because they determine the frequency of the
hapiotypes that are involved in mating at any given time.
Where more than one resistance gene: -iS: b^g
considered, an assumption of ^nolypic- ^uUibrium
between successiver generatiofts is inappropriate,; .even
under conditions of completely random matings While
individual genes reach equilibrium in each generation,
equilibrium combinations of genes are only achieved
after many generations of random mating. For this
reason, simulation of the dynamics of more than one
gene in a population requires explicit accounting of each
genotype. The evolution of herbicide resistance in the
field typically involves simultaneous selection by herbi-
cides with more than one mode of action. Consequently,
consideration of two (or more) genes is of practical
significance.
Population size is also an important factor in the
rate of evolution of herbicide resistance. Where gene
flow between adjacent populations is zero, the prob-
ability of a resistant individual occurring in a popula-
tion is a function of population size (weed
density x population area) and the initial gene fre-
quency. While mutation rates and hence initial gene
frequencies are beyond the control of management,
weed population densities are not, Weed control
practices that maintain low weed densities can consid-
erably decrease the chance of resistance evolution by
reducing the number of resistance alleles in a popula-
tion (Chnstoffers, 1999).
A ptacticsil consequence of this principle, where more
than one: tesistance:: gene. is. presentTa popula-
tion, is that individuals with mtiltipie resistance are
extremely rare prior to herbicide selection (Gressel &
SegehT990). Hence, within any given local area, multi-
resistant individuals will, on balance of probabilities, be
absent in any one generation.
Rotations and mixtures of herbicides that have
discrete modes of action and that are not capable of
degradation by a common metabolic pathway (mode of
degradation) have long been proposed as a means to
prevent or delay resistance evolution (Gx^sel
1990, Wrubel & Gressd. 1994; mi).
Powics et al. (1997) modelled herbicide resistance evo-
lution in a weed population of infinite size when two
herbicides were rotated annually or used each year as a
mixture. In the absence of fitness penalties, (which
would cause selection against resistant alleles in ‘off
years) the rotation strategy did not increase the number
of applications before resistance for either herbicide.
When the herbicides were used in mixture, resistance
was delayed by approximately 4 years.
When an infinite population is assumed, no matter
how improbable, extremely rare double-resistant indi-
viduals will always be assumed to be present and
influencing the rate of evolution of resistance. By
explicitly simulating all genotypes in a finite population
a more realistic prediction of the dynamics of the
evolutionary process can be achieved. This capability is
particularly important when examining the implications
of patterns of herbicide use and may modify the relative
benefits of alternative herbicide use strategies.
The model described in this paper was developed to
investigate the influence of weed life history traits (seed
dormancy and plant mating system) and management
(population size and genetic isolation) on the rate of
resistance evolution under three contrasting herbicide
management regimes.
Model development
Overview
The model has been developed to simulate the evolu-
tion of herbicide resistance at two discrete, unlinked
nuclear gene loci in a weed of broad-area farming. In
accordance with most cases where the inheritance of
herbicide resistance has been documented (Darmency,
1994) resistance is assumed to be conferred by alleles at
a single gene locus. Mutant alleles at these two loci
confer resistance to different herbicide modes of action
so that evolution of resistance to two distinct herbicides
or herbicide modes of action can be tracked within a
single weed papulation (multiple resistance). It is
assumed that alleles at the two loci segregate inde-
pendently.
The herbicides to which resistance is being simulated
are hypothetical. Both allow selective post-emergence
control of the weed and both are effective enough so
that the weed is adequately controlled when either
herbicide is used on its own, resulting in ‘redundant
kiir [control of resistant survivors of one herbicide by a
second, chemically dissimilar, herbicide as defined by
Comins (1986)] when they are used in combination.
There is no capacity for resistance at one locus to
confer cross-resistance to other herbicide chemistries.
The majority of herbicide resistance traits are inherited
in a dominant or semi-dominant manner (Darmency,
1994). Resistance to both herbicides in this model is
assumed to be inherited in a completely dominant
manner at field-applied rates.
The model is constructed from a number of
submodels and is based on the life cycle of a
© European Weed Research Society Weed Research 2003 43, 371-382
644
Herbicides in combination reduce resistance 373
hypothetical annua! weed. The life cycle model simu-
lates the population biology and demographics of a
single population over successive generations. The
reference point for the life cycle is the soil seedbank.
Processes of germination, emergence, establishment,
growth and reproduction are regulated by intrinsic
population dynamics (density dependence and seed-
bank dynamics) and extrinsic environmental (climate)
and management factors. Population dynamics and
the efficacy of weed control strategies together govern
transition probabilities between life history stages
(Fig. 1).
The model was implemented in the Stella simulation
language (version 7) produced by High Performance
Systems, Inc., Hanover, NH, USA (http://www.
hps-inc-cora).
A crop (wheat, Triticum aestivum L.) is sown during
each year of the simulation. Crop seeding and germina-
tion rates and crop establishment characteristics are
defined. Competition between the crop and the weed is
simulated using a reparameterized version of the hyper-
bolic equation (see below) used by Firbank and
Watkinson (1986) to predict crop yields and weed seed
production.
Seed production
Fig. 1 Life cycle of the weed as represented in the model, illustrated for one genotype (i). Variables representing densities of plants in
particular life history stages are enclosed in rectangl«5. Variable representing transition probabilities between life history stages are enclosed
in continuous triangles. More complex relationships between stages are illustrated by broken triangles.
© European Weed Research Society Weed Research 2003 43, 371-382
645
374 A J Diggle et al.
A weed population genetics submodel tracks the fate
of herbicide-resistant and susceptible genotypes and
alleles within the population. Control efficacies and
population dynamics are defined individually for each of
the nine possible weed genotypes (see below). A stoch-
astic extinction routine is incorporated into the model to
account for the possibility that rare alleles may be totally
eradicated from the population.
During the reproductive stage, alleles at the two loci
segregate independently into gametes (pollen and ovules)
and recombine during completely random mating. The
rate of out-crossing may be varied. Following seed-set and
maturation, seeds are returned to the soil seedbank.
Weed life cycle
As with previous models of herbicide resistance, the life
cycle forms the central element of the model through
which changes in population density and the frequency
of individual genotypes are accounted. During each
generation, individuals of weed population (P) are
represented in a number of slates; viable seeds in the
seedbank (j), germinated seeds (g), established seedlings
(e), mature plants (m), seed produced on mature plants
(sp), seed removed from the seedbank other than by
germination (r), and seed added to the seedbank as a
contaminant al crop sowing (a). The starting point for
all simulations is the initial weed seedbank (/’5'iniiiai)
(seeds m"^). The number of mature plants of genotype /
in year n is defined by equation 1:
PiTtltn = {PiSt„ + PiOtn) Ps —* 0 Pg-*e Pi€—^m, (1)
where PiSi„ is the weed seedbank of genotype / in year n,
Ptat„ is weed seed of genotype i added to the seedbank as
part of the sowing operation in year n, Ps-^g is the
fraction of the weed seedbank which germinates, and
Pg~^e and Pfi-^m are transition probabilities for
individuals becoming established seedlings and mature
plants respectively.
Total seed production (Ap) is calculated in a separate
competition submodel (see below). The total amount of
seed of each genotype that is returned to the soil
seedbank at the end of the growing season {PfS^owt^ is
the product of total seed production of genotype i in
year n (P,sp/„) and the fraction of seed produced that
reaches the seedbank (i^sp^-^new)-
The weed seedbank at the start of the following year
{PiSt„ + i) is calculated as
PiStn^i {[1 -~Ps~'g{PiStn ^-P-,at„)]{\ -Ps-^r^jtva)
+ ^’j'Snew^n}(l ^ Ps ^rsummer)* (2)
where Fs'— >?win!er and P^-^rsunimer are the fractions of
ungerminated weed seeds lost from the seedbank during
winter and summer respectively.
Crop/weed competition submodel
Competition between crops and weeds is simulated using
a modified version of the hyperbolic function used by
Firbank and Watkinson (1986):
p PffI P sptnax ^ /-•,
"P 1 -f (/Vz + {Fmk P' A)' ^
where Pm is the number of mature weed plants, Fm is
the number of crop plants, Pspmax is the potential
maximum seed production of the weed per unit area, kP
is the weed plant size coefficient, the inverse of the weed
density (Pm) at which seed production is half of the
predicted maximum (Pgp is the crop plant size
coefficient and A is the interspecific antagonism of the
weed species by the crop.
Population genetics submodel
The mode! tracks the frequencies of herbicide-suscept-
ible and resistant alleles at two discrete, independently
segregating loci. The two loci confer resistance to two
hypothetical herbicides, designated Y and Z, with
different modes of action. Both loci arc diallelic with
the susceptible wild type alleles designated by lower case
letters (y and z) and the initially rare mutant resistant
alleles by upper case (Y and Z). Resistance alleles are
specified as dominant. The model accounts for the
frequency of nine genotypes within a single weed
population (/’yyZZ- PyYZ^.^ -^YYzz^ ^VyZZ. ^Yy?,z^ ^Vyzz.
PyyZZy ^yyZz Snd Pyyr^-
The initial weed population size is the product of the
initial seedbank density (/*5iniimi) and the area (m^). The
initial frequencies of resistant alleles Y and Z are defined
as /y and fz, respectively, and alleles, assumed initially
to be in Hardy-Weinberg equilibrium, are explicitly
accounted thereafter.
Extinction
To avoid anomalous results resulting from fractional
numbers of plants, the model represents small popula-
tions as integer values. Where less than 10 individuals of
any genotype are calculated to occur at any stage of the
life cycle, an integer number of individuals is derived
assuming that the calculated weed density is a probab-
ility of occurrence in a Poisson process (Vose, 2000).
Where 10 or more individuals are expected, the prob-
ability that an extinction event would occur in a Poisson
process is less than 1 in 20 000. If the populations of all
genotypes that contain any particular allele are resolved
to 0 at any time then that allele is considered extinct and
will remain extinct unless it is reintroduced as a con-
taminant during sowing. Random numbers conforming
© European Weed Research Society Weed Research 2003 43, 371-382
646
Herbicides in combination reduce resistance 375
to Poisson distributions were generated using the Stella
simulation software with sequences of random numbere
seeded using the system clock. Because the extinction
process is effectively random, repealed runs of the
model with identical parameters will produce different
outcomes.
Mating
Resistance alleles segregate independently. The fraction
of self-pollination in the weed species can vary between
1 (autogamous) and 0 (allogamous). The frequencies
of pollen haplotypes for each plant genotype are the
averages of the frequencies for that plant genotype and
the frequencies for the total plant population weighted
according to the self-pollination fraction. Ovules and
pollen are produced in direct proportion to predicted
seed yields and all gamete haplotypes have an equal
chance of reproductive success (pollination, embryo
development and seed maturation).
Pollen and ovule haplotypes recombine at random to
produce diploid zygotes that develop into mature seed.
The simplifying assumption of random recombination
within the weed population is common to existing
models that assume infinite populations, but it is
inaccurate because of uneven .spatial distribution of
genes within the population. This assumption of random
recombination becomes less realistic as the simulated
area becomes greater, and it will tend to result in an
overestimation of the rate that resistant alleles multiply
after multi-resistant individuals develop. However, once
resistance has developed it is reasonable to assume that
it will eventually spread throughout the population. The
randomness of recombination does not influence the
probability that rare alleles will be present in finite
populations and hence it should have minimal influence
on the probability that resistance will develop initially.
Parameter values
Weed management practices, together with intrinsic
population processes (mortality, loss of viability and
competition), act in conjunction to regulate weed
population dynamics and ultimately, weed densities in
the field. In the model, these processes are defined by the
paramelere that affect the probability of any individual
moving from one life history stage to the next (e.g. from
germinated seeds to established seedlings). These param-
eters have been adapted from those presented by Pannell
et al. (2003) to approximate conditions and manage-
ment typical of wheat grown in the cropping belt of
Western Australia.
All parameter values are constant for all genotypes of
the weed except for the probability that established
seedlings will become mature plants {Pje->m), which is
affected by application of post-emergence herbicides.
The values for all constant parameters are given in
Table 1. The probability that established seedlings will
become mature plants {PiC^m) is the product of the
probabilities that plants will survive application of
herbicides Y and Z and P/e^mz respectively).
The probabilities of genotypes surviving when herbicides
are applied arc presented in Table 2. Where herbicides
are not applied P/e-^m is I.
We have chosen not to include density-dependent
mortality of plants because we anticipate that plant
densities will typically be low while herbicides are still
effective. For this reason, density-dependent mortality is
unlikely to be an important factor in the dynamics
that affect initial development of herbicide resistance.
Table 1 Descriptions, variable names,
values and units for constant parameters
Parameter description
Variable name
Value
Unit
Density of crop plants
P'm
100
plants m"^
Initial weed seedbank
PSir^itia,
100
plants m“^
Initial frequency of allele for resistance
fy
10“®
to herbicide Y
Initial frequency of allele for resistance
$
10“®
to herbicide Z
Annual import of unseiected weed seed
Pair,
0,1
plants
Fraction of weed seedbank lost in winter
PS— iTwintor
0,1
Fraction of weed seedbank lost in summer
0,1
Fraction of germirtated seed that establishes
Pg->e
0,2
as seedlings
Fraction of seed produced on weeds that reaches
P sp-^Snew
1
the seedbank
Maximum viable weed seed production
Psp max
30000
plants m ^
Weed plant size coefficient
kP
0,04
plant"'’
Crop plant size coefficient
kP'
0,09
nf pisnr'
Crop/weed antagonism parameter
A
1.3
© European Weed Research Society Weed Research 2003 43, 371-382
647
376 A J Diggle e! al.
Table 2 Probabilities that plants of specified genotypes will survive
applications of herbicides Y and Z
Genotype for gene Y
YY
Yy
YY
Value of Pie-^mf when herbicide
Y is applied
0.05
1
1
Genotype for gene Z
zz
Zz
ZZ
Value of P;e-^mz when herbicide
Z is applied
0.05
1
1
Accuracy of the model is less important in circumstances
where herbicide resistance has already developed and
weeds have reached high densities. Such situations are
unlikely to occur in practice as farming would not be
profitable and farmers would alter their practices
accordingly.
Plant life history strategies
Four contrasting plant types were specified for the weed
population. These plant types were combinations of high
and low germination fraction (Ps-^g = 0.9 or 0.1) and
high and low self-pollination fraction (0.99 or 0). All
constant weed related parameters have been chosen to
approximate Lolium rigidum Gaud, (annual ryegrass),
which is cross-poilinated and has a high germination
fraction similar to that specified above.
Herbicides and herbicide use patterns
In all simulations two herbicides (Y and Z) were
available for post-emergence control of the weed pop-
ulation. Both herbicides achieve 95% control of sus-
ceptible individuals (see Table 2), they have distinct
modes of action and cannot be degraded by a common
metabolic pathway (there is no potential for evolved
cross-resistance to both herbicides). In the absence of
herbicide application there is no fitness penally associ-
ated with resistance to either herbicide. Fitness penalties
associated with target-.site resistance to the triazinc
herbicides have been documented in a number of weed
species. However, the results for resistance to all other
herbicide modes of action have been more equivocal
(Holt & Thill, 1994).
Three patterns of herbicide application were defined.
These w'ere:
Rotation strategy: Herbicides Y and Z were applied
in alternate years beginning with Y in the first year.
Threshold strategy: Herbicide Y was applied in all
years until the frequency of the Y resistance allele (Y)
exceeded a threshold value of 0.01, after w'hich point Z
was applied until the frequency of the Z resistance allele
(Z) exceeded the same threshold, whereafter whichever
herbicide had the lowest fraction of resistance was
applied. Please note that we are using this term in a non-
standard way to refer to thresholds of frequencies of
resistance alleles rather than thresholds of weed density.
Combination strategy: Both herbicide Y and Z were
applied in all years. There were no antagonistic or
synergistic interactions between the two herbicides. It is
important to note that this strategy involves application
of more herbicide than does either of the other two
strategies.
For each plant type in combination with each
herbicide application strategy 32 repeated 50-year
simulations were conducted for each of 19 treatment
areas ranging from 10^ to 10^ m^ on a log scale.
Results
Each model run results in a time series of populations of
the nine genotypes. For simplicity these can be identified
as four phenotypes: susceptible to both herbicides
(yy zz); resistant to Y only (yY zz and YY zz); resistant
to Z only (yy zZ and yy ZZ); resistant to both Y and Z
(yY zZ, YY zZ, yY ZZ and YY ZZ).
While each of the runs is unique due to stochastic
processes, runs that gave similar results can be grouped
according to the characteristic dynamics of the popula-
tions (seedbanks). For each of the 32 runs of the model
for each combination of plant type by herbicide strategy
at each treatment area, three outcomes were possible: no
resistance develops; resistance develops to a single
herbicide; resistance develops to both herbicides.
For example, the outcrossing high germination frac-
tion plant type produced eight typical patterns of
seedbank behaviour (Fig. 2). Where no resistance devel-
oped the population steadily declined (Fig. 2A and B).
This decline was typically more rapid where the herbi-
cides were used in combination (Fig. 2C).
Where herbicides were used in rotation and resistance
developed to either of the two herbicides, the population
of resistant plants increased exponentially and exceeded
the population of susceptible plants at around year 10
(Fig. 2D). From that time the population of resistant
plants increased rapidly until stabilizing al numbers in
excess of iO 000 seeds m“^. There was also a transient
increase in the population of susceptible plants as a
consequence of recombination amongst the progeny of
heterozygous resistant plants (i.e. yY or zZ). The
population of susceptible plants ultimately fell as the
frequency of the susceptible allele (i.e. y or z) declined.
In cases where a single resistance emerged under the
threshold strategy, control of the population was main-
tained by the use of the alternate herbicide, with the
population of resistant plants remaining below 10 plants
(Fig. 2E).
European Weed Research Society Weed Research 2003 43, 371-382
648
Herbicides in combination reduce resistance 377
Rotation
ThreshokJ
combination
No resistance
A 1000
800
600
400
200
0
r B
r C
No resistance
Y resistance
Z resistance
Double resistance
Single resistance
Double resistance
0 10 20 30 40 50 0 10 20 30 40 50
Time (years) Time (years)
0 10 20 30 40 50
Time (years)
Fig. 2 Selected examples of typical time series of seed pool size for the four phenotypes of the plant type with 0.9 germination fraction and
0 self-pollination fraction for the three classes of developed resistance (rows) for each of the patterns of herbicide use (columns). The
probabilities of these typical outcomes vary with treatment area (see Figs 4 and 5).
In all cases where double-resistance developed, the
population of double-resistant plants increased rapidly
from about year 10 (Fig. 2F-H). Transient increases in
the populations of the other three genotypes occurred in
response to the recombination effects as described for
single resistance (Fig. 2D).
Variations occurred in the timing of development of
resistance. In general, resistant populations increased
more slowly where the germination fraction was low
(0.1) (data not shown). For all types of resistance there
were examples where build up of resistance was
delayed. An example illustrating development of dou-
ble-resistance with delayed occurrence of Z resistance is
shown in Fig. 3. Delayed resistance of this sort
occurred where resistance genes in the initial popula-
tion became extinct but were reintroduced in contam-
inant seed.
All model runs were categorized according to the
highest resistance status attained by the population
during the simulated 50-year period, namely; no resist-
ance; Y resistance only; Z resistance only; and double-
resistance. The relative frequencies of these categories
© European Weed Research Society Weed Research ^)03 43, 371-382
649
378 A J Diggle et al.
Fig. 3 An example time series of seed pool size for the four
phenotypes of the plant type with 0.9 germination fraction and
0 self-pollination fraction illustrating development of double-
resistance where Z resistance is delayed. Herbicides were applied
in rotation with a 21.4 ha treatment area.
varied in response to the treatment area (= initial
population size).
For the cross-pollinatcd plant type with high germi-
nation fraction (0.9) for all herbicide use patterns,
development of resistance was rare in the smallest
treatment areas (Fig. 4). As the area increased, the
frequency of single resistances and, subsequently, dou-
ble-resistance increased. This trend occurred because the
probability of extinction of resistance genes decreases as
area (= initial population size) increases.
The relationship between probability that no resist-
ance would occur and area treated was very similar
where herbicides were applied in rotation or according
to the threshold strategy (Fig. 4A). In both cases
resistance always occurred in some form in treatment
areas larger than 20 ha. Where herbicides were used in
combination, resistance became frequent only in much
larger areas. A treatment area in the order of 100 times
larger was required to produce similar probabilities of
development of resistance (Fig. 4A).
Where herbicides were applied in combination, resist-
ance to either Y or Z alone did not occur because plants
with resistance to only one herbicide were adequately
controlled by the other herbicide. Consequently, only
populations of double-resistant plants were able to
increase. Resistance to herbicide Z alone did not occur
where the threshold strategy was used (Fig. 4B). This is
because according to this strategy herbicide Z was only
applied after resistance to herbicide Y had developed.
Where herbicides were applied in rotation, Y resist-
ance tended to occur more frequently than Z resistance
because Y was the first herbicide applied in the rotation
(Fig. 4B). Consequently the population initially treated
by Z was reduced, increasing the probability of extinc-
tion of the Z resistance allele.
The relationship between probability of occurrence of
resistance and treatment area was broadly similar for all
plant types, but the relative effect of using herbicides in
combination was larger for plant types with lower
germination fraction or higher fraction of self-pollin-
ation. For self-pollinaled weeds with a high germination
fraction, a treated area in the order of 1000 times larger
was required to produce similar probabilities of devel-
opment of resistance for herbicides used in combination
vis-a-vis the other strategies (Fig. 5A). This factor was
greater than 10 000 times for weeds with low germina-
tion fraction (Fig. 5D and G). In the case of
self-pollinated weeds with low germination fraction
A No resistance B Single resistance C Double resistance
10-2 10-1 10° 101 102 10° icyi
Treatment area (ha)
or
initial population (millions)
10-2 10-1 10 ° 101 102 103 101
Treatment area (ha)
«•
Inili^ population (millicHis)
10-2 10-1 IQO 101 102 103 104
Treatment area (ha)
or
Initial population (millions)
Fig. 4 Proportion of .simulation runs where no resistance occurred (A), where resistance to a single herbicide type occurred (B) or where
resistance to both herbicide types occurred (C) versus treatment area (= initial population size) for the plant type with 0.9 germination
fraction and 0 self-pollination fraction.
© European Weed Research Society Weed Research 2003 43, .371-381
650
Herbicides in combination reduce resistance 379
No resistance
Germination 0.9 seif pollination 0.99
Single i^sistance
Double resistance
/A
J
\
A
\\
■\
W
■\
X
Germination 0.1 seif pollination 0
D1.0| —
0.8
0.6
0.4
0.2
0.0
V-
V.
/\
/*A
./•• '. A .
Germination 0.1 seif pollination 0.99
Gl.O r
0.8
0.6
0.4
0.2
0.0
10-
Figures A,D,G;
Rotation
Threshold
Combined
Figures B.E.H:
Rotation Y only
• • • Rotation Z only
Threshold Y only
I \
I \
1 :": \
\
K-.,
^
\
Figures C,F,I;
Rotation
Threshold
— — Combined
_/
' 10 -’ 10 ° 10 ’ 102 103 10 “
Treatment area (ha)
or
fnitiai population (millions)
10-2 10 -’ 10 ^ 10 ’ 102 103 10 «
Treatment area (ha)
or
Initial population (millions)
10-2 10 -’ 10 ‘» 10 ’ 102 103 10 ^
Treatment area (ha)
or
Initial population (millions)
Fig. 5 Proportion of simulation runs where no resistance occurred (A. D and G). where resistanc-e to a single herbicide type occurred
(B, E and H) or where resistance to both herbicide types occurred (C, F and I) versus treatment area (= initial population size) for three plant
types (in rows).
herbicide resistance was never observed where herbicides
were used in combination (Fig. 5G).
Where herbicides were applied in rotation, germina-
tion fraction had an effect on the relative frequencies of
the two types of single resistance. Where germination
fraction was low a smaller fraction of the population
was exposed to Y in the first year, hence the probability
of extinction of the Z resistance allele was reduced and
the frequency of Z resistance was higher (Fig. 5E and H
versus Fig. 5B).
© European Weed Research Society Weed Research 2003 43, 371-382
For all plant types the transition from single resist-
ance to double-resistance occurred at marginally larger
treatment area under the threshold strategy than under
the rotation strategy (Figs 4C. 5C, F and I).
Under all strategies the transition to increased levels
of resistance occurred at marginally larger areas for self-
poUinating plant types than for outcrossing plant types
(Fig. 4A-C versus 5A-C and 5IY-F versus 5G-I). This is
due to the decreased incidence of heterozygous-resistant
individuals in populations of self-pollinated plants.
651
380 A J Diggle el al.
Germination 0.9, Seif pollination 0
A 50 r
40
to 30
a>
0}
E 20
H
10
Rota^on
Thresh<^
ComWn^
Germination 0.1, Self pollination 0
J
\
Germination 0.9, Self pollination 0.99
CSOr
E 20
F
Germination 0.1, Self pollination 0.99
D
i ;•
i
10-2 10-1 10 ° 10 ’ 102 102
Treatment area (ha)
or
Initial plant population (millions)
10^
10 ’
10 ° 10 ’ 102 102 10 *
Treatment area (ha)
or
Initial plant population (millions)
Fig. 6 Year of the time series where the average size of the weed seed pool for all replicate simulation runs exceeded 1000 seeds m“‘ versus
treatment area (= initial population size) for the three patterns of herbicide application for the four plant types in separate figures.
The timing of appearance of large populations
(indicating the development of resistance) differed
markedly between the plant types with high and low
germination fractions (Fig. 6). The time taken for the
seedbank to exceed 1000 seeds was approximately
three times greater in low germination fraction types
than in the high germination fraction types (Fig. 6A
versus 6B and 6C versus 6D). Where germination
fraction is lower a smaller proportion of the population
is exposed to herbicides in each year, effectively slowing
the rate of resistance evolution in those populations.
At small treatment areas, where resistance generally
did not develop, the mean populations never exceeded
1000 seeds The minimum treatment area where the
seed pool did exceed this value was lowest where
herbicides were used in rotation and highest where they
were used in combination.
For large treatment areas for all plant types the
increase in seedbank was equally rapid for the rotation
and threshold strategies. In the high germination frac-
tion populations the increase in plant population was
only marginally slower where herbicides were used in
combination (Fig. 6A and C). In low germination
fraction populations the mean seed pool generally did
not reach 1000 seeds under the combination
strategy (Fig. 6B and D).
Discussion
The importance of population size in relation
to rare genes
The first major conclusion from this study is that
minimizing the effective weed population size substan-
tially decreases the rate of evolution of herbicide
resistance. Clearly, the smaller a population is, the less
likely it is that rare resistance genes will be present in the
population. Even where resistance genes do occur at low
frequencies in small populations, stochastic demogra-
phic processes are more likely to result in the extinction
© European Weed Research Society Weed Research 2003 43, 371-382
652
Herbicides in combination reduce resistance 381
of these genes. When considering two resistance genes,
as we have simulated here, the probability of both genes
occurring in the same individual is orders of magnitude
smaller again. Management practices that effectively
segregate weed populations into smaller, genetically
isolated units will, therefore, result in a lower incidence
of herbicide resistance.
The degree to which weed populations can be
segregated and contained will depend in large part on
the movement of genes in pollen and seeds or propa-
gules. Gene flow in pollen is something over which land
managers have little or no control. However, Maxwell
(1992) showed that only 7% of pollination events
occurred at distances greater than 1 m in diclopfop-
methyl-resistant Lolium muitiftorum Lam. Rieger et al.
(2002) have shown that pollen-mediated gene flow from
herbicide-resistant to non-herbicide-resistant oilseed
rape {Brassica napus L.) crops does occur over consid-
erable distances, but only at very low frequencies. Where
a weed species has a high degree of outcrossing and
viable pollen can travel long distances from source
populations, the goal of genetic isolation may be
unattainable.
Gene flow by seed movement is a factor that land
managers can influence because for many agricultural
weeds farm management largely dictates mobility of the
seed. Through strict farm hygiene, land managers can
limit the importation of weed seed to a farm, the
movement of seed between fields on a farm and
movement of seed within fields. This may involve
improved screening of seed and fodder brought on to
the farm to ensure it is free of weeds; the cleaning of
machinery between segregated areas; and the catching of
weed seeds during the grain harvest so that they are not
redistributed. The situation is analogous in many ways
to that of a newly invading weed species, except that in
this case the ‘invading weed’ is not visually distinguish-
able from the existing weed population. Management
strategics that reduce rate of movement of the weed
would be expected to increase the lime until herbicide
resistance becomes a problem in areas where resistant
individuals were initially absent.
The importance of pattern of herbicide application
A second major conclusion is that rotation of herbicides,
commonly recommended as a strategy to delay the
development of herbicide resistance in weeds (Powles &
Shaner, 2001), is markedly inferior to the of
herbicides in combination, and is not superior to an
‘expend and swap’ approach typified by the threshold
strategy discussed here. This conclusion is contingent on
the validity of the first conclusion and on the assurap
tions made, i.e. that both herbicides achieve efficacy that
is high enough to ensure ‘redundant kill’ (are used at full
rates), are not subject to linkage disequilibrium, are not
^sociated W'ith fitness costs and have different modes of
action (no cross-resistance).
For large effective areas (population size) there is
very little effect of pattern of herbicide application.
However, for effective areas less than 100 ha, there was
a marked advantage in using the ‘combination’ strategy
in all scenarios tested here. The range of initial
populations for which the combination strategy was
superior varied markedly with germination fraction and
degree of self-pollination in the weed, but it is likely
that an effective initial population within this range is
achievable for most agricultural weeds, particularly
where initial population density is low and where the
weed is self-pollinated. The utility of pesticide mix-
tures as opposed to a threshold approach has been
similarly demonstrated for insecticide resistance man-
agement (Mani, 1985). However, Comins (1986) qual-
ifies this ‘redundant kill’ strategy by indicating that it
will only be effective where population size is small.
The results presented in this paper agree with these
conclusions.
It must be noted that the combination strategy has
disadvantages that should be considered before deciding
to use it in practice. Two of these disadvantages are the
cost and the possible ecological implications of using
more herbicide. Furthermore, the cost of using more
herbicide is immediate, while the returns from delayed
occurrence of herbicide resistance will be realized in the
future and hence, by classic economic theory, will be
reduced in terms of present value.
Another factor that must be considered is that the
combination .strategy requires farmers to apply two
herbicides to control a weed even when the density of
that weed is extremely low. Such a strategy could be
considered counter intuitive. However, in Western
Australia, where many farmers have first hand experi-
ence with herbicide resistance in weeds which are
difficult to control, a form of the combination strategy
is currently recommended to delay the occurrence of
glyphosate resistance (Neve et al., 2003).
Previous modelling of herbicide use strategies that
have assumed infinite population sizes (which are
analogous to the largest population sizes simulated
here) have considerably underestimated the benefits of
herbicide mixtures and sequences as management tools
to prevent or delay herbicide resistance. Such models
do not account for the strategically important possi-
bility of local extinction of rare alleles. While the
methodology we have used does not explicitly simulate
spatial processes, the results do indicate that a quan-
titative understanding of the spatial dynamics of resist-
ance genes is very important to a fuller understanding
European Weed Research Society IVeed Research 2003 43, 371-382
653
382 A J Diggle et al.
of evolution of herbicide resistance. Improved quanti-
tative understanding of the spatial dynamics could be
achieved by embedding a model similar to the one
presented here in a spatial framework such as that
presented by Richter et al. (2002) for the one gene ca^.
With the model presented here it appears highly likely
that the rate of development of herbicide resistance
can be limited by reducing movement. Furthermore,
where movement can be limited, a strategy that uses
herbicides in combination would be superior to rota-
tion of herbicides in terms of rate of evolution of
resistance.
Acknowledgements
We would like to thank Shirani Poogoda for her very
valuable technical assistance. This project was supported
in part by funds from the Grains Research and
Development Corporation, Australia.
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654
Divss
Weed Science Society of America
Predicting the Evolution and Dynamics of Herbicide Resistance in Weed Populations
Author(s): Bruce D. Maxwell, Mary Lynn Roush, Steven R. Radosevich
Source: Weed Technology, Vol. 4, No. i (Jan. - Mar., 1990), pp. 2-13
Published by: Weed Science Society of America and Allen Press
Stable URL; http://www.jstor.org/stable/3986^35
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655
Feature;
Predicting the Evolution and Dynamics of Herbicide
Resistance in Weed Populations*
BRUCE D. MAXWELL, MARY LYNN ROUSH, and STEVEN R. RADOSEVICH^
Abstract. Herbicide resistance jeopardizes the useniiness of valuable chemical tools and, therefore,
weed management in many crop systems. Models must be developed to evaluate management
tactics that prevent, delay, or reduce resistance. The complexity of biological processes involved in
herbicide resistance also requires models to focus research and to integrate experiments. A
population model was developed that improves upon previous attempts to predict herbicide
resistance dynamics. The model incorporates plant population demographics with the Hardy-
Weinberg concept for gene segregation. The model simulmes the evolution, spread, and subsequent
dynamics of resistance in the presence and absence of a herbicide. Analysis of model simulations
identified two sets of biological processes as key factors in the evolution and dynamics of
herbicide-resistant weed populations. These are processes that Influence ecological fitness and gene
flow. Several options are suggested as examples for the management of resistant weed populations.
Additional index words: Population model, resistance management, seed immigration, pollen im-
migration, population genetics.
INTRODUCTION
Herbicides are used extensively in agriculture be-
cause they are cost-effective tools to reduce weed abun-
d^ce and to improve crop yields. Recent trends in
herbicide development have produced extremely spe-
cific and selective chemicals that are used intensively
and routinely in cropping systems. The intensive and
widespread use of such herbicides has precipitated an
alarming increase in the evolution of resistance (9, 15,
28), which jeopardizes product usefulness, availability,
and longevity (15). Since the fint reported cases of
herbicide resistance (26, 27, 30), over 50 plant species
resistant to triazine herbicides have been reponed (25).
In addition, numerous weed species have developed
resistance to chemical classes of herbicides other than
triazines (13, 22, 33, 35).
The complexity of biological processes that influence
herbicide resist^ce dictates a research approach that
focuses on the interaction between life history pro-
cesses and population genetics. Models can serve such
a function and can provide a tool for evaluating man-
agement tactics. Review papers on the population biol-
ogy of pesticide resistance have indicated similar ap-
proaches for studying and managing resistance (7, 19,
^Received fw publication July 5, 1989. and in revised form Oci. 25. 1989.
^Res. Assa.. Res. Assoc., and Prof.. Dep. For. Sci.. Suic Univ., Cor-
vallis, OR 97331.
^Abbreviations: R. herbicide re«st^i', S, hetttcide susccpiibk.
29, 34, 36, 37). Gressel and Segel (10, 11) developed a
model that suggested important factors that influence
occurrence and evolution of herbicide resistance. How-
ever, their model did not include the gene flow pro-
cesses of immigration and important factors influencing
fitness that may improve prediction of local evolution,
spread, and subsequent dynamics of the R^ trait in a
population of weeds.
Population processes that determine the relative fit-
ness of phenotypes are survivorship (demography of
seeds, seedlings, and mature plants), fecundity (pollen
and seed production), and plant competition, ^^^en a
herbicide is used, its selection pressure (reduced survi-
vorship of susceptible individuals) overwhelmingly in-
creases the relative fitness of the resistant genotype
(10, 11). However, when herbicide selection pressure is
removed, population dynamics are determined by dif-
ferences in all processes that coniribuie to the fitness of
each biotype.
We have developed a population model that simu-
lates the evolution, spread, and dynamics of R and S
weed bioiypes (Figure 1 and Table 1). This model
improves upon the biological interpretations suggested
by Grojsel and Segel (10, 11) and provides a refined
approach for evaluating the importance of specific bio-
logical processes involved in the dynamics of herbicide
resistance. The model combines plant population demo-
graphics (18, 21) and the Hardy-Weinberg equation
(2, 3) to determine proportions of R and S genotypes in
successive generations.
2
Weed Technology. 1990. Volume 4:2-13
656
WEED TECHNOLOGY
Many herbicides inhibit a specific enzyme that can
coded for by a single gene; thus, use of the Hardy-
Weinberg inheritance model is a reasonable approach.
The model incorporates differential fitness (i.e., survi-
vorship, competitive ability, and fecundity) of R and S
genoty|K:s in die presence and absence of a herbicide
(selection pressure). Genotype proportions also are
modified by gene flow (i.e., immigration, seed bank
dynamics, inbreeding, and random genetic drift) and by
mutation.
Simulations using this model predict rapid early evo-
lution of resistance from repeated herbicide applications
in the absence of an adj^ent source population of the S
phenotype (Figure 2). After herbicide use is suspended,
the model forecasts a decline in resistance with return
to populations dominated by the S type. The rate of
decline in resistance depends on life-history processes,
immigration processes, mechanisms of inheritance, re-
productive mechanisms, and the relative fitness of the R
and S phenotypes.
model development
The model, like earlier herbicide resistance models
(8, 10, 11), is theoretical. It was developed to generate
hypotheses on the influence of demographic and inheri-
tance processes on resistance evolution and manage-
ment. The simulation model was constructed by linking
eight submodels representing life-history stages (seed
bank, seedling, mature plants, pollen producers, seed
yield), immigration, and inheritance (Figure 1). This
structure allows alternative submodels to be inserted
and tested as new information on particular processes
becomes available.
The current model assumes for mathematical sim-
plicity that the weed is a single-cohort (one germination
time) annual, that all parameters are held constant over
time unless indicated otherwise (Table I), and that
herbicide resistance is associated with a .single gene
locus. Thus, it is assumed that herbicide resistance is
determined by a single pair of alleles, where a denotes
the recessive allele and A the dominant allele. The
computer mcxlel allows the user to select (Figure 3) if
the genotype aa, the homozygous recessive, results in
the R phenotype and AA and As represent S phenotype
plants or if aa results in the S phenotype and AA and
Aa are R. Throughout this paper the aa genotype was
assumed to confer resistance. The model will allow for
different inheritance patterns by inserting a different
inheritance submodel. A separate description of each
submodel follows.
Seed bank submodel. The number of R and S weed
seed in the seedbank was assumed to be a function of
seed mortality and germination rates for each pheno-
type. This amount is supplemented by the number of
seed entering the seedbank from the treated population
and seed immigration.
The number of R and S seed in the seedbank before
germination (RSB and SSB, respectively) is expressed
as
RSB = RSBt4 -f Ryld,4 + RISD^; _ Rn.(RSBt_i) [2.1]
SSB = SSBi_i+ Syldt-i + SISD, - S„,(SSB,.i) [2.2]
Population Model Inheritance
Figure I. A reprcsentadoa of the mode! that follows life-hiaory sages of resis-
tant and susceptible biwypes and incorpesates the influences of fitness pro-
cesses and gene flow, Open arrows indicate the flow of information between the
population model and ite inheritance model. Slate variables are named ^ve
each box and processes are indicated in italics. Abbreviations are explained in
the (ext and Table 1.
Volume 4, Issxx 1 (January-Miuch), 1990
3
657
MAXWELL ET AL,; PREMCnNG IffiRBiCiDE RESISTANCE IN WEEDS
Table 1. Deliniticms used in
the dcveiqnneni of the herbicide resistance mode! (»e Figare t).
Parameter
Definition and default vaites
Equmiem
number
t
Cunait generation
immiiT^tion parameters
hd
The number of pollen-produced per unit area by the source populmion. as,: = TOT = model input value
Li
(Fi^ 5>.
The number of poilen-p^ucing plants per ifflit area r^Kesenting the tot^ amomt of pollen produced
x'
by the source population. Bp = a;,^0. S.l
The distance from dte center of the source population to the center of the treated population.
LI &5.1
Cs
The radius of the total source area <Figure 4).
1.1 &5.1
Co
The radius of the interior sotm:e population tha is equal to the treked radius (O.S) (Figure 4).
L1&5.1
The square root of the scaling factor [c = (c Jjfc *)* } (Figure 4).
bp
The deepness of the diffusion gradient for ptrilcn (1.7).
5.1
bsd
The steqiness of the diffusion ^adient for seed (7.4).
LI
Demo^aphk parmaeters
RSB
The number of R seed in the seed bank before gennination.
2.1
SSb
The number of S seed in the seed bank before germinaiicm.
2.2
The proportion of R seed that die over 1 generation in the seed bank (0.7).
2.1
Sm
The proportion of S seed that die ova 1 gener^itm hi the seed bank (0.7).
2.2
ISD
The lo^ number of seed added to the seed bwk througb immigration over 1 generation.
1.1
RISD
The number of immigrant seed that is R-phenotype.
2.1
SISD
The number of immigrant seed that is S-pbenotype.
2.2
The proportion of R seed Uiat germintue over 1 generation (0.3).
2.3
Sg
The prt^rtion of S seed that germinate over I generation (0 J).
2.4
RSDL
The number of R seedlings produced from seed geminating in the seed bank.
3.1
SSDL
The number ofS seedlings produced from seed genninaiing in the seed bank.
3.2
The proportion of R seedlings that die ove 1 geneaiion (0.75).
3.3
5in2
The {xoportion of S seedlings (hat die over 1 generation (0.75).
3.4
RFL
The number of R mature (flowering) plants.
4.1
SFL
The number of S mature (flowering} plants.
4.2
h
Herbicide efTicacy on seedlings (95%).
4,2
iP
The total number of pollen-producing ^ants represented by immigrant pollen.
5.1
RP
The number of R poHen-productng plants represemed by immigrant pollen..
6.1
SP
The number of S pollen-producing plants represoited by immigrant pollen.
6.2
TM
The total number of mating plants.
7.7
TMf
The number of mating plants that will produce R seed.
7.8
TMs
The number of mating plants that will ftfoduce S seed.
7.9
RY
The number of R seed produced per R plant.
8.1
SY
The number of S seed produced per S plant.
8.2
Ry!d
The R seed yield per unit area.
8.3
SyJd
The S seed yield per unit area.
8.4
Tyid
The seed yield per unit area with genotype Aa.
2.7
Inheritance parameters
Rsb
The i»oponion of the seed bank that is R-phenotype.
2.5
The proportion of the seed baidc that is Aa genotype.
2.7
The proportion of the seed bank ih^ is Aa genotype.
2.8
Ssb
The proportion of the seed baric that is S-phenotype.
2.6
Rsd{
The propwiion of seedlings that «e R-phenotype.
3.5
Tsd!
The {xoponion of seedlings that are Aa gcootype.
3.7
Usdl
The proportion of seedlings thiu are AA ^notype.
3.8
Ssdi
The proportion of seedlings that are S-pbenotype.
3.6
4
(continued)
VoluitMt 4, Issue 1 (January-March), 19%
658
WEED TECHNCWLOGY
Table I. {cofuinuedj Definitions used in die deveiopment of the herbicide repartee model (see Figure I).
Panuneier
E>enniticm wd default values
InlKrltaiKX paramHm
Rn
TH
un
sn
Rof
Sof
Rp
Sp
Tp
Up
p
kr
f
m
Ne
R
T
U
S
SYmax
ar
as
2*
Ni
br
The pre^jortion of mature (fkwerin^ I^ams th^ are R-phenotype.
The propcfftion of mature (flowoiBg) {4iU8s that are Aa genotype.
The pre^xmon of mature (nowaiag) jriaus that ate AA genotype.
The proportion of mature (flowcriog) pIsMs that are S-{^ienotype.
The pre^XHtion of R pcHlen-producing jdants ui the outside (source for iminigration} pqiulaiion.
The proportion of S pollen-producing }dms in the mdsde (source for imrnigrmion) population.
The pre^xxtion of pollen-producing plants widi Aa ^uxrtypc in the outside (source fex immigration)
pqtulatioa
The proportion of R pollen-producing plants in the treated population.
The propCHtion of S poilen-^xoducing plants in the treated population.
The proportion of pollen-producing plants with Aa genotype in the treked pc^lation.
The [Hoportioa of pollen-producing plants with AA genotype in the treated populaticm.
Ihe probability of an individual's dmaiing the a allde in a mating.
The fitness of the R pollen relative to the S pollen (0.9).
The inbreeding coefllcjem.
The forward mutation rate to resistance (IfT®).
The effective size of the populaiitm (related to the number of reproducing adults).
The pioponion of the total matings that will produce R seed.
The proportion of the total matings that will produce seed with Aa ^noiype.
The pre^wrtion of the total matings ih» will produce seed with AA genotype.
The proportion of the total matings that will produce S seed.
The maximum yield per R plant (900 sccds4>lant).
The maximum yield per S plant (1000 sceds^Iaot).
The area required to produce R Yfnt« (1).
The area required to produce SY„,„j (1).
The influence of S plant density on the seed yield of R plants (I).
The influence of R plant density on dte seed yield of S i^ams (I).
The influence of another weed or crop plant (i>dea^ty on the seed yield of R plants (1.2).
The influence of another weed or creq? plant density on the seed yield of S plants (I.l).
The density of the other weed or crq) (200 piantsMt^).
The coefficient which determines the form of the relationship between RY, and the total density (0.8).
bs
The coefilcient which detennines the form of the relanonship between SYj and the total density (0.8).
Equation
number
4.3
4.5
4.6
4.4
1.2
1.3
2.7
6.3
6.4
6.5
6.6
7.1
7.1
7.5
7.5
7.6
7.2
7.3
7.4
7.4
8.1
8.2
8.1
8.2
8.1
8.2
8.1
8.2
8.1 & 8.2
8.1
8.2
where Ryldt^ is the number of R seed produced per unit
area by the previous generation and Syldi_i is the num-
ber of S seed pnxiuced per unit area by the previous
generation in the treated population. The mortality rates
for R and S seed are Rn, and S^, respectively.
Seed immigration submodel. Immigration of genes
has two points of origin: seed and pollen from outside
the treated population. The immigration of seed from an
outside population is treated as an influx into the seed-
bank. Pollen immipation enters the model in the pollen
producer submodel. The proportions of genotypes im-
migrating from a source are assumed to be the same as
the proportions in the source (outside field) population.
Volume 4, Issue 1 (Januaiy-Mareh), 1990
Emigration was not included in the model.
Seed immigration is a function of dispersal which
involves several variables: a) heights and distance of
the seed source, b) concentration at the seed source, c)
dispersibility of the seed (e.g., weight, possession of
wings, plumes, etc.) and d) activity of distributing
agents (e.g., wind direction and velocity) (12). These
variables are generally species specific and require spe-
cific models. In the current model, seed immigration is
based on a diffusion gradient model used to predict a
plant disease gradient (24) and pollen dispersal (6).
ISD, = (a,^ (x' + c„ )^ ) (c,^ / cl ) [ 1 . 1 ]
5
659
MAXWELL ET AL.: PREDICTING HH?BIC!DE RESISTANCE IN WEEDS
Phonoiype Pfoponions
GGr>er8{ion (year)
Figure 2. Mode! smutadcms describing the evolution of resistance when the
herbicide is used in the sy^m and the subsequent dynamics of resistance in the
weed population afto- the herbicide has been removed. The sc^td arrows indi-
cate the years of continuous herbicide use.
Figure 3. The first ii^xtt screen for RSU4 (the intottetive computer program
versMMi of the model) used for selecting the mechanism of resistance inheri-
tance and the reproductive mechanism for a weed species of interest.
RISD, = ISDt(Rof) [1.2]
SISDt = ISDt(Sof) [1.3]
ISD is the total number of immigrant seed per unit area
entering the treated population seedbank from outside
populations (Figure 4). The parameter asd is the number
of seed produced per unit area at l-<o units of distance
from the center of the source, which is equivalent to the
total number of seed produced by the source when it is
equal in size to the treated population. Since the source
was assumed to be equal in size to the treated popula-
tion, it was also assumed that the source would produce
the same amount of seed as the treated population.
The x' parameter is the distance (in treated popula-
tion dimneters) from the center of the source population
to the center of the treated (receptor) population, and c©
is a truncation factor which approximates the radius of
a source population (23) in the center of the total source
that is equal in size to the treated population (Figure 4).
Setting all measures relative to the size of the treated
population allows for assessment of immigration at all
scales. The parameter bsd is the slope of a linear
regression of log(Isd) on log(x' + Cq). To accommodate
immigrant sources larger or smaller than the orated
population, a scaling factor (cV cj ) was added to the
immigration equation, where Cg is the total source (a set
of source populations) area radius in units of treated
population diameters.
The number of R and S seed reaching the treated
population as a result of immigration are RISD and
SISD, respectively. The proportions of each genotype in
the outside (source) population are Rof (genotype aa),
Tof (genotype Aa), and Uof (genotype AA). The pro-
portion of the susceptible phenotype in the source popu-
lation is Sof = Tof + Uof.
After germination the numbers of R and S seeds that
remain in the seedbank until the next generation are
RSB, = RSB - Rg(RSB) [2.3]
SSBt = SSB - Sg(SSB) [2.4]
where Rg and Sg are germination rates for R and S seed.
The proportion of each genotype (Rsb * aa. Tsb =
Aa, Usb = AA) in the seed bank at time t is calculated
by
r>-t. RSB
RSB + SSB
[2.5]
o-u ... SSB
RSB + SSB
[2.6]
Tsbi_, (RSB,_, + SSB,., ) + Tyld^, + ISD, (Tof)
RSB + SSB
[2.7]
6
Volume 4, Issue 1 (January-March), 1990
660
WEED TK^iNOLOGY
Distance to Source (x'}
The proportion of seedlings of each genotype at lime t
are then calculated by
Rsdlt =
Ssdii :
Tsdlt =
RSDL,
RSDL, + SSDL,
[3.5]
SSDL,
RSDL, + SSDL,
[3.6]
Tsb, (Ssdl, )
Ssb,
[3.7]
= Ssdit - Tsdi,
[3.8]
figure 4. Pollen and seed di^jeraal as a function of distance (in units of treated
populaticxt diconeter) to a source popul^ton.
Usbi = Ssbt - Tsb, (2.8)
Rsbt, Ssbj, and Usb^ are the proportions of R phenotype
(aa genotype), S phenotype, Aa genotype, and AA
genotype, respectively, m the seedbank of the current
generation. Tsb,.^ is the proportion of the heterozygous
(Aa) genotype in the seedbank during the previous
generation; Tyldi_i is the number of seed produced per
unit area by the treated population in the previous
generation that were the heterozygous (Aa) genotype.
Seedling submodel. The number of R and S seedlings
(RSDL and SSDL. respectively) in the treated popula-
tion at time t is calculated as follows:
RSDL = Rg(RSB)
[3.1]
The parameters are defined in Table 1.
The current model includes the influence of the
herbicide at the transition from the seedling to mature
plant life-history stage. The effect of the herbicide on
the weed population is based on its efficacy in S
populations. The herbicide efficacy (h) is equivalent to
the percent control relative to an untreated control plot
of a S population.
Mature plant submodel. The number of R and S
mature individuals in the population (RFL and SFL,
respectively) at time i is equal to the number of seed-
lings in the population after accounting for the effect of
the herbicide and R and S seedling mortality.
RFL^ = RSDL,
[4.1]
SFL, = SSDL, ~ h(SSDL,)
[4.2]
The proportions of each genotype at the mature stage
^ calculated as follows:
SSDL s Sg(SSB)
where Rg and Sg are gennination rates for R and S seed,
respectively.
Hie number of seedlings of R and S phenotype that
survive to become flowering plants is regulated by
seedling mortality rates for the R (Rni 2 ) and S ( 8012 )
phenotypes:
RSDL, = RSDL(Rn2)
[3.3]
SSDL, = SSDL(S^)
13.4]
RFL,
RFL, + SFL,
[4.3]
SFL,
RFL, + SFL,
[4.4]
Tsdl, (Sfi, )
Ssdl,
[4.5]
Sfl, - Tfl,
[4.6]
The parameters are defined in Table 1.
VoIiHBc 4, Issue 1 (January-Mardi), 1990
7
661
MAXWELL ET AL,: PREDICTING HHJBICIDE RESISTANCE IN WEEDS
Pollen immigration submodel. The same equation that
is used for seed immigration (Equation 1.1) is used for
predicting pollen immigration but with different coeffi-
cients and bp). The immigration submodel has b^n
adapted to predict the total number of pollen-producing
plants (IP) represented by pollen reaching ±e treated
populauon (Figure 4). It, therefore, is assumed that all
the plants in the source population produce the same
amount of pollen and that the proportions of immigrat-
ing R and S pollen are the same as the phenotype
proportions of individual plants in the outside source
population.
IP, = (a^ (s' + c„ ) (c^ / ) [51]
The ap parameter is the number of pollen-producing
plants per unit area at I-Cq units of distance from the
source popul^on. This value is equivalent to the total
number of pollen producers in the source population
which is assumed to be the number of seed produced in
the source population divided by a constant. The num-
ber of seed produced in the source is assumed to be
equal to that produced in the treated population of the
same size. The bp parameter is the slope of a linear
regression of log(Ip) on log(x" + Co). This parameter
controls the steepness of the diffusion gradient which is
a function of the pollen grain mass and shape as well as
air flow properties. The other parameters are described
in the seed immigration submodel (Equation 1.1) and in
Table 1.
Pollen producer submodel. The total number of pollen
producers for the treated population that are R (RP) and
S (SP) at time t are calculated as
RPt = Rflt(RFLt + SFLt - IPt) + RofrlPJ [6.1]
SPt « Sflt(RFLi + SFLt - IPt) + Sof(lP,) [6.2]
The proportions of pollen producers represented by
each genotype are
RP,
" RP, + SP,
(6.3)
SP.
" RP, + SP,
[6.4]
Tfl, (RP, + SP, ) - IP, ) + Tofdp, )
RP, + SPi
(6.5)
Upt = SPt - Tpt [6.6]
The parameters are defined in Table 1.
Inheritance submodel. The probability (p) of an indi-
vidual's donating the a allele in a mating is based on
the proportions of each genotype at the pollen produc-
tion stage. The fitness of the R pollen relative to the S
pollen (iq) is included in the equation.
0,5 Tpt
P "" k, R,» + + u,. [7.1]
The basic Hardy-Weinberg model is based on the
assumption that populations are infinitely large and
mating is random (panmictic). In populations of defined
size or breeding behavior that are not random, there is a
potential for inbreeding. The Hardy-Weinberg equation
may be modified by inclusion of an inbreeding coeffi-
cient (32, 38). The following equations result:
Rhi = + pCf) [7.2]
Tt*, == 2(I-p)(p)(l-f) [7.3]
{l-p)2Cl~f) + (l-p)(0 [7.4]
S,+i = Ti+i + Ut+i
1-2 m
“ 4 m-2m+i [7.5]
In this equation m is the mutation rate which is fixed in
the current model at Ifr^. which is in the range sug-
gested by Georghiou and Taylor (7). is the effective
size of the population which is related to the number of
reproducing adults and is calculated as follows when
there are differences in the number of male (Nem) and
female (Ncf) adults:
« 0.25(V Nrf + l/N^ ) [7.6]
It is assumed that the male part of a plant population
(pollen grains) far exceeds the number of female ov-
ules. Therefore, Nan approaches 0 and Ngf is approxi-
mated by the number of seed produced per unit area by
the treated population. The unit area thus defines the
finite population size.
8
Volume 4, Issue 1 (lanuary-March). 1990
662
WEED ITCHNOXXJY
TTie proportions of e^h genotype proceeding into
the next generation have been determined above. To
calculate the number of seed representing each geno-
type, the number of total plants involved in mating first
must be calculated; then the number of those matings
that will represent production of effi:h phenotype (R and
S) is determined.
TMt =
RFLj SFLj
[7.7]
TMt,
~ Ri4-i(TMi)
[7.8]
TMSe
= S^iCTMt)
[7.9]
TMt is the total number of mating plants in the current
generation. TMt^ and TMsi are the number of mating
plants that will produce seed with the R and S pheno-
types, respectively.
Seed yield submodel. A competition model proposed
by Firbank and Watkinson (5) was adapted to predict
the seed yield for individual R and S plants. Separate
equations for the R and S phenotypes account for
differential competitive abilities. TTie influence of a
crop and other weed species can be included in the
model in addition to intra- and inter-phenotype compe-
tition.
RY, = RY„„[1 + a,(Ra, + z^SFL, + [8,1]
sv, = SY„„(1 + a,(SFL, + z„RFL, + ZuN,))-*' [8.2]
RYnux ^d SYnux ^ maximum yield per plant that
can be attained by the R and S phenotypes, resp^tive-
ly. The areas required to attain Rnj„ and SY^ax are a,
and a,, respectively. The inter-phenotype competition
coefficient which expresses the influence of the S phe-
notype density on the R phenotype is Zsr- The inter-
phenotype competition coefficient that expresses the
influence of the R phenotype density on the S pheno-
type is z„. The inter-specific competition coefficients
that express the influence of the crop or other dominant
weed density on the R phenotype and the S phenotype
are Zjy and z^, respectively. Nj is the density of the crop
or other domin^t species in the system, and br and bs
are the coefficients which deteimine the forms of the
relationship between RYt and SY^ and the total density,
respectively.
The seed yields per unit area for the R (Ryid) and S
(Syld) phenotypes are calculated as follows:
Figure i. The second and third input screens for RSIM (the computer program
version of the resistance simulation mode)) used for entering the initid emdi*
tiOQS for starting a stmuJatioR and changing certain mode) parameter values.
Ryld, = RY,(TMJ [8.3]
Syld, = SY,(TMd [8.4]
Ryld and Syld become the inputs to the seedbank in the
next generation (t+1).
Simulations are conducted by inputting a set of ini-
tial conditions (Figure 5) and calculating in sequence
equations 1.1 through 8.4. The computer program ver-
sion of the resistance simulation model (RSIM) pro-
Volume 4, Issue 1 (January-March), 1990
9
663
MAXWELL ET AL.; PREDICTIW HERBICIDE RESISTANCE IN WEEDS
duces two types of output: a) Proportions of the R and
S phenotype once per generation at the flowering stage
before reproduction and b) numbers of individuals at
each life-history stage for each generation.
MODEL BEHAVIOR ANALYSIS
Sensitivity and elasticity analysis (18, 20) on the
complete simulation model identified two sets of life-
history processes that are important for understanding
and managing the dynamics of herbicide resistant^: a)
processes that influence fitness of the R phenotype
relative to the S phenotype and crop species and b)
processes that contribute to gene flow in space and
time.
Fitness. Fitness describes the evolutionary advantage of
a phenotype, which is based on its survival and repro-
ductive success (2, 31). Relative fimess of R and S
phenotypes has important consequences for the man-
agement of resistance. Reduced fitness in the R type
(1. 14) infers that R plantt will be replaced by S
individuals over time after herbicide use is abandoned.
Alternatively, if the fitness of the R type is not less than
the S type (35), resistance should decline slowly, if at
ail. Fitness also will be influenced by the presence of
other species. (i.e., crop or other weeds) in the system,
especially if they are strong competitors. These pre-
mises have not been examined experimentally, although
the alternatives lead to very different tactics for manag-
ing resistance (9).
Gene flow. Gene flow describes the processes that
influence the maintenance of a particular genotype in a
population. Gene flow processes directly alter the fre-
quencies of R and S alleles in plant populations (16).
Immigration of pollen and seed introduce genes into a
population, while inbreeding and genetic drift result
from limited gene flow. Seed dormancy conserves
genes widiin a plant population. Seed bank dynamics
include these gene flow proc^ses, as well as seed
survivorship (a fimess process).
Pollen and seed from outside populations are in-
volved in two important management scenarios: a) the
spread of resistance over the landscape and b) the use
of S-genotype sources (e.g., fence rows, untreated rows,
fields, addition of seed) to prevent or slow the evolution
of resistance. Attempts to manage herbicide resistance
are dominated by tactics to use other herbicides to
remove R plants from populations that have developed
resistance. Our model simulations suggest that manipu-
Propoftion Of Resistance tn Popuiat'on
Figure 6. The tniluence of herbicide efficacy on the maximum level of r^s-
tance achieved in a weed population that had S ccmiinuous years of h»bicide
applications.
lation of S-type gene flow is an alternative for resis-
tance management Such tactics could be more cost
effective than control measures that only reduce R-type
plants in already resistant fields.
MANAGEMENT SCENARIOS
Simulations. The model was used to assess the influ-
ence of gene flow and fimess processes on the evolu-
tion of resistance in a weed population. Each of these
assessments has management implications. In each
analysis, ail the parameters except for one were held
constant All the simulations were initiated with se-
lected proportions of each genotype in the treated weed
population and an adjacent (source for immigration)
population of the same species. Herbicide application
begins at Year 5 and is continued through Year 9 in the
simulations. All references to the herbicide in the first
three scenarios assume that there was a single herbicide
in the system and that resistance to that herbicide is a
single-gene, homozygous-recessive trait.
The relative fimess of the R and S phenotypes were
arbitrarily set equal except in their relative competitive
abilities with the crop (R = 1 = S = I and R = 0.7 that of
the crop, S = 0.8 that of the crop) and their abilities to
pollinate and fertilize (R = 0.9 that of S). The crop
density was arbitrarily fixed at 200 plants m-^. The
following discussion illustrates four scenarios where
model simulations were used to explore gene flow and
fimess processes and their management implications.
10
Volume 4. issue 1 (Jaauay-Mj«;h), 1990
664
WffiD TECHNOLOGY
Figure 7. The influHJCc of the size (relative to the treated pq)utauon) and dis-
tance (in units of treated populalioo diarocier) » (edge of som* to edge of
treated) a 100% susce{Hibic source pqpulatioo on Uie level of resistance
achieved after 5 continuous years of heiWcide aRtlicatioos.
Scenario 1. The influence of herbicide efficacy (h in
Equation 4.2) on the evolution of resistance was ex-
plored (Figure 6). The simulations were initialed with
no resistance in the treated populations, but resistance
was introduced in each generation (year) by immigrant
pollen from an adjacent (source) population. The model
is designed to remove (kill) a proportion of the S
individuals equivalent to the efficacy. The maximum
level of resistance achieved in the treated population
increased sharply when efficacy was about 80%.
The response to efficacy suggested from the simula-
tions has important management implications. Reducing
efficacy by intentionally leaving skips in the herbicide
application would provide for enough healthy S individ-
uals in the population to reduce the levels of resistance
through fitness and gene flow processes. Suscqilible
individuals also may escape treatment naturally by fol-
lowing a different phenology. The potential for estab-
lishing an efficacy threshold to maintain a low propor-
tion of resistance in a weed population is apparent
Competition and economic thresholds have been identi-
fied in many weed/crop systems (4) which indicate that
high efficacy is often associatai with “cosmetic” we«J
control rather than direct economic gain. Therefore,
reducing efficacy to discourage the evolution of resis-
tance may not r«luce crop yields.
Scenario 2 . This scenario examines the potential for
immigrating S pollen and seed to decrease the role of
evolution of resistance (Figure 7). The initial conditions
FVemortion of Rasistance In Population
Generation (year)
Fipire 8. The infiuesnee of relative competitive abiiilies of rcsistani and suscep-
tible phenotypes in the presence of the crop on evolution of and recovery from
resioance (Equations 8.1 and 8.2).
for the simulations assumed 1% resistance already in
the weed population followed by an increase to 90%
resistance at the end of 5 continuous years of herbicide
use. The influence of the size of a S source population
(relative to the size of the treated population) and
distance (in units of treated population diameter) to an
outside S source of the weed was assessed for its ability
to influence R levels in the treated population.
The simulations indicated that source areas equal to
or larger than the treated population can decrease the
maximum level of resistance (Figure 7). The manage-
ment tactic implied by these simulations is to leave
untreated adjacent rows or to maintain S populations of
the weed Aspersed through the treated population
within a distance of one treated-population diameter.
Scenario 3. This scenario addresses the influence of
competition on the evolution of and recovery from
resistance (Figure 8). Competitive abilities of the R and
S phenotypes relative to each other and the crop (Equa-
tions 8.1 and 8.2) were varied systematically in a set of
simulations. Relative competitive ability had little influ-
ence on the rate of resistance evolution. The levels of
resistance in the population over the first 3 yr of
herbicide use did not differ in the simulations. Howev-
er, the maximum level of resistance after 5 continuous
years of herbicide use was highest (95%) when the R
and S phenotype and the crop were assumed to have
equal competitive abilities. The maximum level of re-
sistance was reduced to 85% when the R phenotype
was assumed to be less competitive than both the crop
and the S phenotype of the weed.
Volume 4, Issue 1 (January-March), 1990
11
665
MAXWHX ET AL.; PREDICTING HERBiaDE RESISTANCE IN WEEDS
Figve 9. The use of a new herbicide (one that has 85% eflica:y on both R and S
individuals) and as S source populaticm for managing recovery fhun beriwide
resistance in a vreed population. Arrows in^cate the beginning and ending of
continuous new herbicide s^lications.
The model simulations indicate that the most signifi-
cant influence of relative competitive ability on resis-
tance dynamics occurs in the recovery period following
suspension of herbicide use (Figure 8). Three years
after stopping herbicide use, 30% resistance remained
in the population where competitive abilities were equal
for the R and S phenotypes and the crop. The propor-
tion of R plants was lower in the recovery period when
the relative competitive ability of the R phenotype was
decreased relative to the crop and the S phenotype.
The management tactic implied from manipulation of
relative competitive abilities is to use or rotate to a crop
with a greater competitive ability than the R phenotype.
Manipulating competitive pressure by increasing the
crop density is an equivalent management option.
Changing crop densities had little influence on early
evolution and maximum levels of resistance; however,
critical crop densities were identified which maximized
the rate of recovery to a susceptible weed population
following the suspension of herbicide use.
Scenario 4. The model was used to assess management
options for recovery after resistance is recognized in a
we^ population. The simulations were started with
50% resistance in the population. A new herbicide with
85% effic^y on R and S phenotypes was introduced at
Year 1 and continued for 8 yr, then all herbicide
application was suspended (Figure 9). The simulations
indicated that the presence of an adjacent (source)
population of S individuals decreased the time for re-
12
covery from resistance. Using a new herbicide without
a source of immigrant S pollen or seed was not as
effective at decreasing the level of R population as was
an adjacent population without the use of a new herbi-
cide.
The management implications suggested by these
simulations further supports the potential of managing
resistance by creating a source of the S phenotype to
augment the effect of a new herbicide which will
control both R ^d S weeds.
SUMMARY
The biological complexity and management implica-
tions of herbicide resistance can be explored with accu-
rate simulation models that include pertinent biological
processes. Gene flow and fitness were identified as
important processes influencing resistance dynamics.
These processes deserve further experiments to deter-
mine their potential for manipulation and management
of resistance.
The potential management of resistance suggested by
this m^el represents some alternative sinttegies and
titles with respect to other attempts to study herbicide
resistance. These tactics include methods to decrease
the R phenotype and to manipulate tiie S phenotype of
the weed population. Each approach is reasonable, al-
though greatest success should result from multiple
integrated tactics for manipulating both R- and S-type
weeds in a population.
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Wcsley Pub. Co., Reading. MA. p. 124-145.
33. Sianger, C. E.. and A P. Appleby. 1989. Italian ryegrass (loUum multi-
flonan) accessions icderaat to dicloft^. Weed Sci. 37:350-352.
34. Tabashnik, B. E. 1986. ResisUum managematt p. 194-206 in Pesticide
Resistance: Straiegus and Tactics for Management. Natl. Acad. Press,
Washii^ton. DC.
35. Valvcrde. B. E.. S, R. Radoscvich. and A. P. Appleby. 1988. Growth and
competitive ability of dinitroaniiine-heriricide resisiam and susceptible
goosegrass (Eleusine indica). ftoc. West. Soc. Weed Sci. 41:81.
36. Via, S. 1986. Pesticide resistance, p. 222-235 in Pesticide Resistmcc:
Strategics and Tactics fa Management Natl. Acad. Press, Washingtem,
DC.
37. Wolfe, M. S.. and J. A Barrett. 1986. Response irf plant pathogens to
fungicides, p. 24^256 in Pesticide Resistance: Strategies and Ttctics for
Management Natl. Acad, ftess, Washington. DC.
38. Wright S. 1 972. Coe^ients of inbreeding and relationship. Am. Nat. 56:
330-338.
— axBiw —
StHTUKAiTAS/A fOVsn.T.iVTS ,r//4/MV0, f.m
/SOI rVMA.AtAKA MBA.VCKOH lAAAA. rMAIl AW
TI.S : XI74 CKVm. TH VAX .
CONTRACT RESEARCH FOR CROP
PROTECTION TECHNOLOGY
IN RICE AND OTHER MAJOR CROPS.
AMERICAN OWNED AND OPERATED
SINCE 1985
FOR FURTHER INFORMATION CONTACT
DR. J.W. SOUTHERN
Volume 4, Issue 1 (January-MardS), 1990
13
667
© 2010 Piant Management N^oric.
Accepted for publication 13 August 2010. Published 20 September 2010.
Weed Control in Dicamba-Resistant Soybeans
Bill Johnson, Professor, PuixJue University, West Lafayette, IN
47907; Bryan Young, Professor, and Joe Matthews, Researcher,
Southern Illinois University, Carbondale, IL 62901; Paul Marquardt,
Research Associate, Purdue University, West Lafayette, IN 47907;
Charlie Slack, Research Specialist, University of Kentucky,
Lexington, KY 40546; Kevin Bradley, Associate Professor, University
of Missouri, Columbia, MO 65211; Alan York, William Neal Reynolds
Professor Emeritus, North Carolina State University, Raleigh, NC
27695; Stanley Culpepper, Associate Professor, University of
Georgia, Tifton, GA 31797; Aaron Hager, Associate Professor,
University of Illinois, Urbana, IL 61801; Kassim Al-Khatib,
Professor, Kansas State University, Manhattan, KS 66506;
Larry Steckei, Associate Professor, University of Tennessee,
Jackson, TN 38301; Mike Moechntg, Assistant Professor, South
Dakota State University, Brookings, SD 57007; Mark Loux,
Professor, Ohio State University, Columbus, OH 43210;
Mark Bernards, Assistant Professor, University of Nebraska, Lincoln,
NE 68583; and Reid Smeda, Associate Professor, University of
Missouri, Columbia, MO 65211
Corresponding author: Bill Johnson, wgj^purdue.edu
Johnson, B., Young, B., Matthews, Marquardt, P., Slack, C., Bradley, K., York,
A., Culpepper, S., Hager, A., Al-Khatib, K., Stecket, L, Moechnig, M., Loux, M., Bernards,
M., and Smeda, R. 2010. Weed control in dicamba-resistant soybeans. Online. Crop
Management doi:l0.1094/CM-2010-0920-01-RS.
Abstract
Field experiments were conducted in 11 states to evaluate broadleaf weed
management programs in dicamba-resistant soybeans which involved the use of
preemergence and postemergence dicamba. Preemergence (PRE) dicamba at 0.25
ib ae/acre provided less than 60% control of smooth pigweed, giant ragweed,
vefvetieaf, palmer amaranth, waterhemp, and morningglory spp,, but 97% control
of common lambsquarters and horseweed at 3 weeks after treatment (WAT).
Preemergence fiumioxazin plus chtorimuron or sulfentrazone plus cloransulam
provided 66 to 100% control of these weeds. Use of dicamba postemergence
(POST) improved uniformity of control of velvetleaf, smooth pigweed,
morningglory, and giyphosate-susceptible waterhemp. However, combining
dicamba at 0.25 Ib/acre with glyphosate resulted in 30% to 65% greater control
of giyphosate-resistant palmer amaranth, glyphosate-resistant common
waterhemp, glyphosate-resistant horseweed, and glyphosate-resistant giant
ragweed compared to sequentially applied glyphosate.
Introduction
Glyphosate-resistant soybean was commercialized in 1996 and as of 2007,
91% of soybean hectares in the United States were genetically engineered,
herbicide-resistant varieties (9). Soybean producers have changed management
practices during this time, relying more on conservation and no-tillage practices
and use of glyphosate for weed control (10). Use of gl^hosate in soybean
production from 1995, the year prior to the introduction of glyphosate-resistant
soybean when it was used as a bumdown herbicide before planting, to 2006, the
10th year of use as a preplant or postemergence herbicide, in soybean increased
by ten-fold in the United States (8) at the exclusion of other herbicide modes of
action (lo). As a result, several agronomically important broadleaf weeds have
evolved resistance to glyiihosate in the United States including: giant ragweed
{Ambrosia trifida), common ragweed {Ambrosia arfemisii/o/ia), waterhemp
{Amaranthas rudis), palmer amaranth {Amarantkus palmeri), horseweed
{Conyza canadensis) (4). Other species that are difficult to control with
glyphosate include mominggloiy species (Ipomoea spp.), common
Crop Management
20 September 20 1 0
668
lambsquarters iChenopodium album), and dandelion (Taraxacum officinale).
The aforementioned weed species have been identified by growers in several
recent surveys as being the most difficult to manage in current soybean
production systems (3,5,6).
Although, glyphosate-resistant com was introduced in 1997, many other
herbicides in addition to glyphosate are used for postemergence weed control.
Among those are plant growth regulators such as 2,4-D and dicamba. Dicamba
has been used for broadleaf weed control in corn for several decades. Dicamba
provides effective control of most of the common dicot weeds found in com
production (7) and to date, there are no weeds commonly found in com
production that have evolved resistance to dicamba (4). Dicamba-resistant
soybean is currently being developed to assist formers in controlling glyphosate-
resistant and hard-to-control broadleaf weeds. The dicamba tolerance trait {2)
will be stacked with glyphosate resistance and will provide the option of using
dicamba preemergence or postemergence in soybean for weed control. There is
little research published on dicamba use as a preplant bumdown herbicide
applied within 14 days of soybean planting, as a soil residual herbicide in
soybean, or as a postemergence tankmb( partner with glyphosate for control of
problematic weed species often faced by farmers in the United States.
The objective of this research was to evaluate control of several problematic
annual broadleaf weeds commonly found in soybean production in the United
States with dicamba and dicamba + glyphosate weed control programs.
Treatment programs consisted of preemergence or preplant application timings
alone and followed by single or sequential postemergence applications.
Evaluating Weed Management Programs in Dicamba-Resistant
Soybeans
Field experiments were conducted in Georgia, Kentucky, and Missouri in
2007 and in Georgia, Illinois, Indiana, Kansas, Kentucky. Missouri, Nebraska,
North Carolina, Ohio, South Dakota, and Tennessee 2008 and 2009. Locations,
soil types, and predominate broadleaf weeds at each site are shown in Table 1.
Standard field research techniques were used to establish the experiments and
apply preplant/preemergence and postemergence treatments. Treatments were
applied with backpack sprayers at carrier volumes ranging from 15 to 20
gal/acre (GPA). Preemergence/preplant treatments were applied within 4 days
before or after planting at 20 out of 23 site-years. Early postemergence
(EPOST), postemergence, and late postemergence (LPOST) treatments were
applied on weeds 3 to 5, 3 to 8, and 8 to 16 inches in height, respectively.
Two separate research trials were conducted. The first trial, hereafter
referred to as the “non-glyphosate trial" was conducted in Indiana and Ohio in
2008 and 2009 (4 site years). Treatments evaluated in this protocol are listed in
Table 2. The second trial, hereafter referred to as the “glyphosate trial,” was
conducted in all other states in 2007, 2008, and 2009 (19 site years) and
treatments are shown in Table 3. The main difference between the treatments in
the two trials is the fact that no glyphosate was applied postemergence with
treatments 2 through 10 in the non-glyphosate trial. The preemergence residual
herbicide used in the glyphosate trial was sulfentrazone plus cloransulam and
the one used in the non-glyphosate trial was flumioxazin plus chlorimuron.
Crop Management
20 September 2010
669
Table 1. Year, location, soil characteristics, tillage system, planting dates, and herbicide application dates
for dicamba-resistant soybean field trials.
Year
Location
Soil
class
Tiiiage
Planting
date
Herbicide application dates
Weeds
Preprfant
wpre-
emergfflice
fPRE)
Eariy post-
emei^ence
(HOST)
3-5 in(di
weeds
Mid post-
emergence
(MPOST)
3-8 inch
weeds
Late post-
emergence
(LPOST)
8-16 inch
weeds
2007
Fayette
Co., KY
Silty
clay
loam
Conven-
tional
Jun 18
Jun 18
Jul 9
Juf 13
Aug 3
Velvetleaf,
smooth
pigweed, giant
ragweed,
morningglory
species.
2007
Platte Co.,
MO
Silty
clay
loam
Min
3un 6
Jun 8
Jul 5
Jut 6
Jut 26
Glyphosate-
resistant
common
waterhemp
2007
Sandy
loam
None
Jun 22
Jun 22
Jid 13
Jul 16
Aug 1
Glyphosate-
resistant Palmer
amaranth
Fayette
Co., KY
Silty
clay
loam
Conven-
tional
lun 2
m
Jun 19
Jun 27
Jut 25
Velvetleaf,
smooth
pigweed
2008
Wayne Co.,
NC
Loamy
sand
Conven-
tional
May 9
May 13
May 30
Jun 5
Jun 25
Glyphosate-
resistant Palmer
amaranth
2008
St. Clair
Co., IL
Silty
loam
Min
Jun 18
Jun 18
Jul 4
Jul 11
Jul 25
Velvetleaf,
common
waterhemp,
morningglory
species
2008
Brown Co.,
IL
Clay
loam
None
Jun 18
Jun 20
Jul 16
Jut 23
Aug 1
Glyphosate-
resistant
common
waterhemp
2008
Riley Co.,
KS
Silty
loam
Conven-
tional
May 15
May 15
Jun 9
Jun 17
Jul 4
Velvetleaf,
Palmer
amaranth,
morning-glory,
ivyleaf
morningglory
2008
Callaway
Co., MO
Silty
clay
loam
Conven-
tional
May 29
May 5
Jun 24
Jun 26
Jul 15
Giyphosate-
resistant
common
waterhemp
2008
Silty
day
loam
None
Jun 2
Jun 3
Jun 23
Jun 30
Jul 14
Smooth
pigweed, pitted
morning-glory,
glyphosate-
resistant
horseweed
Brookings
Co., SD
Conven-
tional
May 28
May 28
Jun 20
Jul 15
Aug 8
Wild buckwheat
2008
Clark Co.,
OH
Silty
clay
loam
Min
May 25
May 25
Jun 17
Jun24
Ju!17
Giyphosate-
resistant giant
ragweed,
recdroot
pigweed,
velvetleaf
2008
Tippe-
canoe
Co., IN
Silt
loam
Conven-
tional
May 22
May 22
Jun 17
Jul 2
Jui 2
Common
lamfas-quarter,
giant ragweed,
velvetleaf
(continued)
Crop Management
20 September 2010
670
Table 1 (continued).
Year
Location
Soil
class
Tillage
Planting
date
Herbicide application dates
Weeds
Preplant
orpre-
emergwra
(PRE)
Early post-
emei^nce
(EPOST)
3-5 inch
weeds
Mid post-
emergence
(MPOST)
3-8 inch
weeds
Late post-
emergence
(LPOST)
8-16 inch
weeds
2009
Wayne Co.,
NC
None
May 20
May 20
Jun 3
Jun 11
Jun 22
Glyphosate-
resistant Palmer
amaranth
2009
Fine,
sandy
loam
None
May 19
May 4
May 29
Jun 1
Jun 20
Glyphosate-
resistant
horseweed,
common
waterhemp
2009
Fayette
Co., KY
Silty
ioam
Conven-
tionai
May 20
May 20
Jun 5
Jun 22
Jul 20
Smooth
pigweed
2009
■
Ciay
loam
None
May 22
May 22
Jun 22
Jun 29
Jul 14
Giyphosate-
reslstant
common
waterhemp
Riiey Co.,
KS
Silty
clay
ioam
None
3un 8
3un 8
Jun 26
jui 1
Jul 22
Palmer
amaranth, giant
ragweed
2009
Saunders
Co., NE
Loamy
sand
None
May 21
May 23
Jun 13
Jun 13
Jul 8
Common
waterhemp,
glyphosate-
resistant
horseweed
2009
Brookings,
Co., SD
Ciay
loam
Conven-
tional
May 22
May 21
Jun 23
Jul 2
Jul 10
Wild buckwheat
2009
Callaway
Co„ MO
Silty
clay
loam
None
Jun 30
Jun 30
Jul 16
Jul 16
Aug 18
Glyphosate-
resistant
common
waterhemp
2009
Pickaway
Co., OH
Silty
clay
loam
Min
May 5
May 5
Jun 2
Jun 16
Jun 30
Common
lambs-
quarter,
glyphosate
resistant giant
ragweed
2009
Tippe-
canoe
Co,. IN
Silt
ioam
Conven-
tional
Jun 9
Jun 9
Jun 23
Jun 30
Jul 16
Lambsquaiter,
giant ragweed,
redroot pigweed
Crop Management
20 September 2010
671
Table 2. Core treatments in the non-glyphosate trial which was conducted in Indiana and Ohio in 2008
and 2009 .
Treatment
number
Herbicide
Formulation
Rate
Application
timing
■
Roundup PowerMax
N-Pak AMS
Roundup PowerMax
N-Pak AMS
glyphosate
ammonium ^Ifate
glyphosate
ammonium sulfate
4.S lb a^gat
100%
4.S lb a^gai
100%
0.75 ib ae/acre
5 %v/v
0.75 Ib ae/acre
5 %v/v
EPOST
EPOST
LPOST
LPOST
Clarity
Clarity
dicamba
dtcamba
4 lb ae/gai
4 lb ae/aal
0.25 ib ae/acre
0.25 Ib ae/acre
EPOST
LPOST
3
Clarity
Clarity
dicamba
dicamba
4 lb ae/gal
4 lb ae/gal
0.25 ib ae/acre
0.25 Ib ae/acre
POST
LPOST
4
Clarity
Clarity
dicamba
dicamba
4 lb ae/gal
4 lb ae/gal
0.125 Ib ae/acre
0.25 Ib ae/acre
EPOST
LPOST
5
Clarity
Clarity
dicamba
dicamba
4 lb ae/gal
4 lb ae/aal
0.125 ib ae/acre
0.25 lb ae/acre
POST
LPOST
6
Clarity
dicamba
4 lb ae/gal
0.25 Ib ae/acre
PREPIANT/
PREEMERGENCE
Clarity
dicamba
4 lb ae/gal
0.25 Ib ae/acre
PREPLANT/
PREEMERGENCE
Clarity
dicamba
4 lb ae/gai
0.25 ib ae/acre
POST
S
Clarity
dtcamba
4 lb ae/gal
0.25 Ib ae/acre
PREPLANT/
PREEMERGENCE
Clarity
Clarity
dicamba
dicamba
4 lb ae/gai
4 lb ae/qai
0.25 Ib ae/acre
0.25 ib ae/acre
POST
LPOST
Clarity
Clarity
dicamba
dicamba
4 lb ae/gai
4 Ib ae/ga!
0.25 ib ae/acre
1.5 Ib ae/acre
PRE
LPOST
10
flumioxazin
chlorimuron-ethyl
dicamba
51%
25%
4 lb ae/gal
0.056 Ib at/acre
0.019 !b ai/acre
0,25 ib ae/acre
PREPLANT/
PREEMERGENCE
POST
Crop Management
20 September 2010
672
Table 3. Core treatment in the giyphosate trial which was conducted in Georgia, Illinois, Kansas,
Kentucky, Missouri, Nebraska, North Carolina, South Dakota, and Tennessee.
Treatment
number
Herbicide
Active ingredient
Formulation
Rate
Application
timing
Roundup PowerMax
giyphosate
4.5 lb ae/gal
0.75 lb ae/acre
POST
N-Pak AMS
ammonium sulfate
100%
5 %v/v
POST
Roundup PowerMax
giyphosate
4.5 lb ae/gat
0.75 Ib ae/acre
LPOST
N-Pak AMS
ammoruum
100%
5 %v/v
LPOST
Clarity
dicamba
4 lb ae/gal
0.25 lb ae/acre
EPOST
Roundup PowerMax
giyphosate
4.5 lb ae/gai
0.75 ib ae/acre
EPOST
N-Pak AMS
ammonium sutf^
100%
5 %v/v
EPOST
Clarity
dicamba
4 lb ae/gal
0.25 lb ae/acre
LPOST
Roundup PowerMax
giyphosate
4.5 lb ae/gal
0.75 Ib ae/acre
LPOST
N-Pak AMS
ammonium sulfate
100%
5 %v/v
LPOST
ISHHIi
Clarity
dicamba
4 ib ae/gai
0.25 Ib ae/acre
POST
Roundup PowerMax
glyph(^te
4.5 Ib ae/gal
0.75 Ib ae/acre
POST
N-Pak AMS
ammonium sul^te
100%
5 %v/v
POST
Clarity
dicamba
4 Ib ae/gal
0.25 ib ae/acre
LPOST
Roundup PowerMax
giyphosate
4.5 Ib ae/gal
0.75 ib ae/acre
LPOST
N-Pak AMS
ammonium sulfate
100%
5 %v/v
LPOST
Clarity
dicamba
4 Ib ae/gal
0.125 ib ae/acre
EPOST
Roundup PowerMax
giyphosate
4.5 lb ae/gal
0.75 Ib ae/acre
EPOST
M-Pak AMS
ammonium sulfate
100%
5 %v/v
EPOST
Clarity
dicamba
4 Ib ae/gal
0.25 Ib ae/acre
LPOST
Roundup PowerMax
giyphosate
4.5 ib ae/gal
0.75 Ib ae/acre
LPOST
N-Pak AMS
ammonium sulfate
100%
5 %v/v
LPOST
Gl^^M
Clarity
dicamba
4 lb ae/gai
0.125 Ib ae/acre
EPOST
Roundup PowerMax
giyphosate
4.5 Ib ae/gal
0.75 ib ae/acre
EPOST
M-Pak AMS
ammonium sulfate
100%
5 %v/v
EPOST
Clarity
dicamba
4 Ib ae/gal
0.25 Ib ae/acre
LPOST
Roundup PowerMax
giyphosate
4.5 Ib ae/gai
0.75 Ib ae/acre
LPOST
N-Pak AMS
ammonium sulfate
100%
5 %v/v
LPOST
Hi
Oarity
dicamba
4 Ib ae/gal
0.25 Ib ae/acre
PREPUNT/
PREEMERGENCE
Roundup PowerMax
giyphosate
4.5 ib ae/gal
0.75 Ib ae/acre
POST
N-Pak AMS
ammonium sulfate
100%
5 %v/v
POST
Roundup PowerMax
giyphosate
4.5 Ib ae/gal
0.75 Ib ae/acre
LPOST
N-Pak AMS
ammonium sulfate
100%
5 %v/v
LPOST
H
Clarity
dicamba
4 Ib ae/gal
0.25 ib ae/acre
PREPLANT/
PRSEMERGENCE
Clarity
dicamba
4 lb ae/gal
0.25 lb ae/acre
POST
Roundup PowerMax
giyphosate
4.5 Ib ae/gal
0.75 Ib ae/acre
POST
N-Pak AMS
ammonium sulfate
100%
5 %v/v
POST
Roundup PowerMax
giyphosate
4.5 Ib ae/gat
0.75 Ib ae/acre
LPOST
||||H|||Hb
N-Pak AMS
ammonium sulfate
100%
5 %v/v
LPOST
8
Clarity
dicamba
0.25 Ib ae/acre
PREPLANT/
PREEMERGENCE
Clarity
dicamba
4 lb ae/gal
0.25 Ib ae/acre
POST
Roundup PowerMax
giyphosate
4.5 Ib ae/gal
0.75 Ib ae/acre
POST
N-Pak AMS
ammonium sulfate
100%
POST
Clarity
dicamba
4 tb ae/gal 4.5
0.25 ib ae/acre
LPOST
Roundup PowerMax
giyphosate
lb ae/gal
0.75 ib ae/acre
LPOST
N-Pak AMS
ammonium sulfate
100%
5 %v/v
LPOST
Clarity
dicamba
4 lb ae/gal
0.25 ib ae/acre
PREPLANT/
PREEMERGENCe
Roundup PowerMax
giyphosate
4.5 Ib ae/gal
0.75 Ib ae/acre
POST
N-Pak AMS
ammonium sulfate
100%
5 %v/v
POST
Clarity
dicamba
4 Ib ae/gal
1.5 Ib ae/acre
LPOST
Roundup PowerMax
giyphosate
4.5 Ib ae/gal
1.5 Ib ae/acre
LPOST
N-Pak AMS
ammonium sulfate
100%
5 %v/v
LPOST
10
Authority First DF
sulfentrazone +
cloransulam-methyl
70%
0.141 Ib ai/acre
PREPLANT/
PREEMERGENCE
Clarity
dicamba
4 !b ae/gal
0.25 ib ae/acre
POST
Roundup PowerMax
giyphosate
4.5 Ib ae/gal
0,75 lb ae/acre
POST
N-Pak AMS
ammonium sulfate
100%
5%v/v
POST
Roundup PowerMax
giyphosate
4.5 Ib ae/gal
0.75 Ib ae/acre
LPOST
N-Pak AMS
ammonium sulfate
100%
5 %v/v
LPOST
Crop Management
20 September 2010
673
Visual evaluations of weed control were collected at 3 weeks after the PRE
residual treatment and 3 to 5 weeks after die LPOST treatment on a o to 100
scale, with o = no control and 100 = control or death of all plants in the plot.
Crop response and yield to the herbicide treatments were not collected for thi.s
research as the soybean cultivars used were not of commercial quality. Years
were treated as a random variable and data were subject to analysis of variance
using Proc Mixed in Data are presented as box and whisker plots and
means are separated with Fisher’s Protected LSD at the 0.05 level of
significance.
Residual Control of Broadleaf Weeds with Soil-Applied
Dicamba
Soil activitj’ of dicamba at 0.25 lbs ae/acre was variable depending on the
target weed species. In the non-glyphosate trial, flumioxazin + chlorimuron
resulted in 70% control of giant ragweed compared to less than 10% with
dicamba (Fig. 1). However, control of common lambsquarters was 98% with
dicamba, compared to ioo% control with flumioxazin + chlorimuron. In the
glyphosate trials, common lambsquarters control with dicamba PRE was
excellent and similar to suifentrazone + chloransulam (Fig. 3). In addition, PRE
activity of dicamba resulted in greater than 90% control of horseweed across
numerous states (Fig. 3). However, for a majority of the troublesome broadleaf
weeds in soybean, residual activity of dicamba compared to suifentrazone +
chloransulam was unacceptable. For velvetleaf, smooth pigweed, Palmer
amaranth, common waterhemp, giant ragweed, and morningglory, dicamba
activity was less than 60% control (Fig. 3). Comparatively, suifentrazone +
cloransulam controlled velvetleaf 94%, smooth pigweed 90%, palmer amaranth
85%, common waterhemp 82%, giant ragweed 95%, and morninggloiy spp.
80%. These results indicate that soil-applied dicamba at 0.25 lb ae/acre is
effective in suppressing horseweed and common lambsquarters, but is much
less effective than common industry standards at suppressing other widespread,
problematic weeds evaluated in this research.
Giant ragweed Common lambsquarters
b a
dicamba flumioxazin + chlorknurwi dicamba flisntoxazin + chforimuron
Fig. 1. Box and whisker plots of percent control with preplant dicamba (0.25 lb ae/acre) or flumioxazin (0.056 lb ai/acre) +
chlorimuron (0.019 lb ai/acre) at 3 WAT in the non-giyphosate trial conducted in Indiana and Ohio. Horizontal line in the box
denotes the mean value, upper edge (hinge) denotes 75th percentile, lower hinge denotes 25th percentile, vertical lines
extend to the highest and lowest values. Means followed by the same letters are not different at P - 0.05.
Crop Management
20 September 2010
674
Smooth pigweed Palmer amaranth
dtcamba stilfentrazone + dicamba
cloransulam-methyi
suifentrazone
doransulam-methyl
Giant ragweed Horseweed
dicamba sulfentrazone + dicamba suKentrazone +
doransulam-methyl doransul^-methyl
Crop Management
20 September 2010
675
Morningglory spp.
dtcamba sulfentrazone
cioransuiam-m^yi
Fig. 2. Box and whisker plots of percent control with preplant dicamba (0.25 lb ae/acre) or sulfentrazone + cloransuiam-
methyi (0.141 lb ai/acre) at 3 WAT in the glyphosate trial conducted in Georgia, Illinois, Kansas, Kentucky, Missouri,
Nebraska, North Carolina, South Dakota, and Tennessee. Horizontal line in the box denotes the mean value, upper edge
(hinge) denotes 75th percentile, lower hinge denotes 25th percentile, vertical lines extend to the highest and lowest values.
Means followed by same letters are not different at P = 0.05.
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20 September 2010
677
Redroot pigweed
aaaa a b aaab
Herbicide treatinent
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20 September 20 1 0
679
Common lambsquarters
aaaa aaba a b
Herbicide treatment
Fig. 3. Box and whisker plots of percent control with various postemergence treatments at 3 to 5 weeks after the last post
treatment in the non-glyphosate trial conducted in Indiana and Ohio. Abbreviations: gly = glyphosate; die = dicamba;
pre ■ preplant; ep = early post; p = post; ip = late post; fb « followed by. Horizontal line in the box denotes the mean
value, upper edge (hinge) denotes 75th percentile, lower hinge denotes 25th percentile, vertical lines extend to the highest
and lowest values. Means followed by the same letter are not different at P = 0.05.
Control of Broadleaf Weeds with Postemergence Dicamba
Alone Compared to Glyphosate Alone
In the non-glyphosate trial, control of velvetleaf with dicamba was rate
dependent (Fig. 3). Treatments which included dicamba at 0.125 lb ae/acre
resulted in up to 5% lower control than treatments which included 0.25 lb
ae/acre in the initial postemergence treatment, and more velvetleaf plants
survived with the lower POST rates of dicamba. Redroot pigweed and common
lambsquarters control was not as rate dependent as velvetleaf, but control was
timing dependent. EPOST followed by LPOST sequential treatments provided
slightly greater control (5 to 10%) than POST followed by LPOST sequential
treatments, irrespective of the dicamba rate. Control of glyphosate-resistant
giant ragweed was only 70% with glyphosate alone compared to 92% control of
the glyphosate-susceptible biotype (Fig. 3). Application of sequential treatments
of dicamba POST, irregardless of rate or timing, resulted in complete control of
both biotypes of giant ragweed.
Crop Management
20 September 201 0
680
Control of Broadleaf Weeds with Giyphosate + Dicamba vs.
Giyphosate Alone
In the giyphosate trial, control of wlvetleaf, smooth pigweed, giyphosate-
susceptible Palmer amaranth and waterhemp, giant ragweed, and wild
buckwheat was 95% or higher with all treatments (Fig. 4). Control of smooth
pigweed was timing dependent and treatments which include EPOST
application timings provided slightly less variable control than treatments
which were applied POST or LPOST, and the addition of dicamba improved
control over giyphosate alone. At sites with glyphosate-resistant plants,
inclusion of dicamba in the POST treatment greatly improved weed control
versus giyphosate alone. For Palmer amaranth, waterhemp, and horseweed,
control increased from 60 to 100%, 30 to 95%, and 85 to 98%, respectively.
Common waterhemp control was variable with giyphosate alone at both
glyphosate-resistant and -susceptible sit«. This would indicate that despite the
absence of glyphosate-resistant waterhemp at many sites, dicamba improved
the consistency of control. Treatments which included giyphosate applied
postemergence without dicamba provided lower levels of weed control than
treatments which included POST dicamba. Horseweed control was higher and
less variable in treatments that included dicamba or flumioxazin, suifentrazone,
chlorimuron, or doransuiam applied preemeigence than with treatments that
included only postemergence giyphosate or giyphosate + dicamba. With
momingglory, treatments which included giyphosate applied postemergence
without dicamba resulted in 90 to 93% control. This increased to 98 to 99%
control when dicamba was induded POST.
Crop Management
20 September 2010
681
Velvetleaf
Herbicide treatment
Crop Management
20 September 2010
682
Smooth pigweed
80
70 '
60
c —■
40 -
30 -
20
10
Herbicide treatment
Crop Management
20 September 2010
683
Glyphosate-Susceptible Palmer amararrth Glyphosate-Resistant Palmer amaranth
2 •
a a
T D
i
H I
b
v-b "•& %>. tjS; * %
b.’t V- a 'tv ’2^- '•vi’*?.
V
■»;% w
V C*' v
Herbicide treatment
Crop Management
20 September 2010
Percent control M
685
100
do
2 50
Giant ragweed
10
0
« *5-,
*5. % % %
X *?x
'•»%*? ‘s.%S
41 ^ ^
% C5L^<??
Herbicide treatment
Crop Management
20 September 2010
686
Glyphosate-Resistant Horseweed
Herbicide treatment
Crop Management
20 September 2010
687
Morningglory spp.
Herbicide treatment
Crop Management
20 September 2010
688
Wild buckwheat
Herbicide treabnent
Ffg. 4. Box and whisker plots of percent control with various postemergence treatments at 3 to 5 weeks after the last
postemergence treatment in the glyphosate trial conducted in Georgia, Illinois, Kansas, Kentucky, Missouri, Nebraska, North
Carolina, South Dakota, and Tennessee. Abbreviations: gly = glyphosate; die = dicamba; pre * prepiant; ep » early post;
p = post; Ip * late post; fb = followed by. Horizontal line in the box denotes the mean value, upper edge (hinge) denotes
75th percentile, lower hinge denotes 2Sth percentile, vertical lines extend to the highest and lowest values. Means followed
by the same letter are not different at P * 0.05.
Integration of new herbicide-tolerance traits such as dicamba results in the
addition of novel modes of herbicide action and improves the consistency of
POST broadleaf control programs versus glyphosate alone. Dicamba can also
reduce the selection pressure for glyphosate-resistant weeds, preserving the
technology of glyphosate-tolerant soybeans. In this research, residual activity of
dicamba appears sufficient for early season control of horseweed and common
lambsquartere. POST dicamba improved the control of the glyphosate-
susceptible weeds evaluated, but improved control was most notable for the
glyphosate-resistant weeds horseweed, giant ragweed. Palmer amaranth, and
common waterhemp. Dicamba also improved the consistency of control of
morninggloiy.
Crop Management
20 September 2010
689
Literature Cited
1. Delannay, X., Bauman, T. T., Beighi^, D. H., Buettner, M. J., Coble, H. D., DeFelice,
M. S., Derting, C. W., Diedriek, T. J., Grilfe, J. L., Hagood, E. S., Hancock, F. G.,
Hart, S. E., LaVallee, B. J., M. M., Lueschen, W. E., Matson, K. W., Moots,
C. K., Murdock, £., Nickell, A. D., Owen, M. D. K,, Paschal, E. H., II, Prochaska, L.
M., RajTTiond, P. J., Re>’nolds, D. B., Rhod^ W. K., Roeth, F. W., Sprankle, P. L.,
Tarochione, L. J., Tinius, C. N., Walker, R, H., Wax, L. M., Weigelt, H. D., and
Padgette, S. R. 1995. Yield evaluation of a glyphosate-tolerant soybean line after
treatment with glyphosate. Crop 35:1461-1467.
2. D'Ordine, R. L, Rydel, T. J., Storek, M. J., Sturman, E. J., Moshiri, F., Bartlett, R.
K., Brown, G. R., Filers, R. J., Dart, C., Qi, Y., Flasinski S., and Franklin, S. J.
2009. Dicamba monoojq^enase: structural insights into a djmamic rieske
oxj'genase that catalyzes an exocyxlic monooj^^enation. J. Moi. Biol. 392;48i-
497 -
3. Gibson, K. D., Johnson, W. G., and Hilger, D. 2005. Farmer perceptions of
problematic corn and soybean weedbs in Indiana. Weed Technol. 19:1065-1070.
4. Heap, I. M. 2010. International surv^' of herWcide resistant weeds. Online.
WeedScience.org, Con'allis, OR.
5. Johnson, B., Barnes, J., Gibson, K., and Weller, S. 2004. Late season weed escapes
in Indiana soybean fields. Online. Crop Management doi;i0.i094/CM-2004-
0923-01-BR.
6. Kruger, G. K., Johnson, W. G., Weller. S. C., Owen, M. D. K., Shaw, D. R., Wilcut, J.
W., Jordan, D. L., Wilson, R. G., Bernards, M. L., and Young, B. G. 2009. U.S.
grower views on problematic weeds and changes in weed pressure in gljphosate-
resistant corn, cotton, and soj’bean cropping ^tems. We^ Technol. 23:162-166.
7. Loux, M., Doohan, D., Dobbels, A. F., Johnson, W. G., Nice, G. R. W., Jordan, T. N.,
and Bauman, T. T. 2010. Weed Control Guide for Ohio and Indiana. Joint
publication, Ohio State Univ. C{»p, Ext. Bui. 789 and Purdue Univ. Coop. Pub.
WS16. Columbus, OH, and West Lafayette, IN.
8. USDA-NASS. 2009. Agricultural chemical use database. Online. NSF Center for
Integrated Pest Management, USDA Regional Pest Mgt. Centers Info. S>’stem,
Nat’l. Agric. Statistics Service (NASS), USDA, Washington, DC.
9. USDA-NASS. 2009. Acreage report, June 30, 2009. Agric. Statistics Board, Nat'l.
Agric. Statistics Service (NASS), USDA, Washington, DC.
10. Young, B. G. 2006. Changes in herbicide use patterns and production practices
resulting from glyphosate-resistant crops. Weed Technol. 20:301-307.
Crop Management
20 September 2010
EVOLUTION IN ACTION: GLYPHOSATE-RESISTANT WEEDS
THREATEN WORLD CROPS
Stephen B Powles.WA Herbicide Resistance Initiative, School of Plant Biology, University of Western Australia
spowles@plants.uwa.edu.au - outlines the development of glyphosate resistant weeds and the weed control
problems that are associated with it
Keyvnrds: gl^hosate. herbicide, retistance. GM crops, evokmon.
suscun;d>ili^
introduction
Glyphosate is by far the world’s most widely used and
important herbicide because it is efficacious, economical and
environmentally benign (Dill et al., 2008; Duke 8c Powles,
2008). Glyphosate dominates for non-selectivc weed control
in agricultural ecosystems, especially to remove weeds
between ro\^ in established perennial tree, nut, vine crops
and before seeding of annual crops. Globally, ^yphosate is
also the non-selective herbicide of choice in urban and
industrial areas, national parks and other amenity areas. In
these use patterns, there have been few instances of weeds
evolving glyphosate resistance. While there are documented
cases of giyphosate-resistant weed evolution in several
countries (Table 1, reviewed by Powles, 2008) given the long
term glyphosate usage, experience establishes that plants
cannot easily evolve resistance to this herbicide.
The common factor in those examples (Table 1) where
glyphosatc-rcsistant weeds have evolved is very persistent
glyphosate usage with little or no diversity in weed control
practices. Unsurprisingly, glyphosate resistance has evolved
most often in the resistance-prone genera Conyza and
Lolium. It is important to recognise, however, that
glyphosate continues to be effective globally in its traditional
use patterns for non-selective weed control where there is
sufficient diversity in control practices and not an extreme
over-reliance on glyphosate. However as discussed below,
this simation has dramatically changed now chat glyphosate
has become a selective herbicide in transgenic crops.
Glyphosate as a selective herbicide in
transgenic giyphosate resistant crops
From 1996 onwards, a landmark development occurred with
the commercialisation of transgenic (genetic modification
obtained through gene manipulation using recombinant
DNA technology) crops. By far the most important
development has been crops endowed with a bacterial gene
conferring resistance to giyphosate (Dill et al., 2008). In
transgenic glyphosaK-resistant crops (hereinaficr referred to
as GR crops), glyphosate is used as a selective herbicide to
remove weeds without crop damage, providing easy,
economical, efficient weed control along with other
agronomic advantages such as earlier seeding and reduced or
zero tillage. GR crops are a spectacular commercial success
(in those countries in which GM crops can be grown) with
95% of the more than 100 million hectares of currently
grown transgenic crops being GR crops (Figure 1; James,
2006). In the Americas, the speed and extent of GR crop
adoption has been phenomenal. GR soybean, cotton and
maize dominate USA cropping. In 2006 GR soybean
comprised 90%, cotton 91% and maize 60% of the entire
USA plantings of these crops (Figure 2, Dill et at., 2008). In
southern USA cropping regions, GR soybean, cotton and
maize are rotated on the same fields. In central and northern
USA cropping regions, GR soybeans arc almost universal and
are often in rotation with GR maize.
^ — I I . I p . . I .
tM0 1W1M1«W2OOO3Sn2aBiSQt»3OM2OO$2OC8
Ytar
F^re I : Global ^yphosate resistant crops.
In Argentina, the adoption of GR crops is even more
complete with almost the entire soybean crop being GR
(Figure 3). GR crops are also being rapidly adopted in
Brazil. The widespread adoption of GR crops and
consequent high glyphosate usage (Figures 1-3) is
understandable, as glyphosate is easy to use, economical and
provides excellent weed control. GR crops all contriburc to
256 Outlooks on Pest Management — December 2008 DOi: {0.i564/i9dec07
0 2008. Research Informaikm Ltd. All rights reserved
691
Cotton
So)^an
Maize
Year
Figure 2; Adoption of gl)^hos^e-resistant crops in USA.
widespread, high level adoption and therefore
unprecedented, often exclusive, use of glyphosate over very
large areas. While economically rational for growers and
industry (Gianessi, 2005), from an evolutionary persp«:tive
the "glyphosate landscape” is an ideal environment in which
any weedy plants that can survive glyphosate can thrive.
This is especially so because the adoption of GR crops and
intensive glyphosate usage often results in the cessation of
use of alternative herbicides (Shaner; 2000} and/or tillage,
and, therefore, there is no diversity in weed control
practices. This frirther adds to the selection pressure for
GtYFHOSA:r^>Hr;S^SlAr<r
Rgure 3: Adoption of GR soybean and seeding in
Argentina.
Year
R^re 4: Number of different herbicide active ingredients and
herbicide sites of action used on at least 1 0% of hectares from
I99S to 2005 in soybean in the USA.
plants that can survive glyphosate. The adoption of GR
soybean and glyphosate in the USA removed alternative
herbicide diversity, resulting in almost complete reliance on
glyphosate (Figure 4). This is also the case in A^entina and
Brazil.
It must be emphasised that glyphosate used repeatedly
and persistently post-emergent in GR crops across vast areas
is a more intense evolutionary selection pressure for
resistance than that which prevails for most traditional
glyphosate uses (outlined in the Introduction). In a GR crop,
any weed plants that survive glyphosate arc likely to flowei;
pollinate and produce seed. Thus, in GR crops grown on the
same fields for several years those weed species that have
some level of natural tolerance to glyphosate can come to
prominence in GR cropping systems (comprehensively
reviewed by Owen, 2008). As well as these widely-occurring
weed spectrum shifts, intense glyphosate use in GR crops
grown persistently in the same fields/landscapes is a strong
selection for resistance to evolve in previously glyphosate
susceptible weed species (Powles, 2003). Evolved
glyphosate-resistant weeds are a major risk for the continued
success of GR crops.
Outlooks on Pest Management ~ December 2008 257
ecos^mos IB major cropping regions of Nords and South
Ameria> more species will inevitably evolve glyphosate
msismBce.
Table 2 lists the currendy documented ca^s of evolved
giyphosaie-resistant weeds from usage of glyphosate as a
selective herbicide in GR crops.
It is in GR crop areas in the USA and Argentina that
glyphe^ate-resistant weed evolution is most direataiing.
Since the first report of glyphosate-resistant Cowyw
camJensis in a US GR soybean field in 2001, there are now
at It^st three million heemres of USA GR crops infested with
glyphosate-resistant Conyza. Even more worrbome are
glyphosate-resistant populations of far more economically
damaging weed species (Tabic 2). In some mid-western USA
states there arc now several known glyphosate-resistant
populations of the very vigorous, highly competitive and
economically damaging weeds Amhrosia artemisiifolia and
Ambrosia trifida, as well as Amaranthus rudis and
Amaranthus tubercuiatus. In the southern cotton-growing
states, there arc many reports of glyphosate-resistant
populations of Amaran^us pakneri, a very damaging weed
of cotton crops, Evolution of glyphosate resistance iii|
Ambrosia and Amaranthus populations is a looming threat
to GR crop productivity and sustainability in die USA.
As in the USA, GR soybean has been massively
adopud in Argentina. Almost the entire 16 million hectare
Aigentine soybean crop is GR, and nearly all of this is in
no-till producfion systems with little diversity in weed
control, and almost exclusive reliance on glyphosate.
Additiohally, GR maize is being adopted at a rapid rate.
Therefore, the selection pressure is intense for evolution of
glyphosate-resistant weeds. So far, the very damaging weed
Sorghum, hahpense has evolved glyphosate resist^cc
across a significant area of the GR soybean crop in die Salta
province (Vila-Aiub et al., 2008). Brazil did not
commercialise GR crops until well after Argentina, the USA
and Canada, with GR crop adoption occurring mainly since
2005, However, rapid adoption of GR soybean, maize and
cotton is now underway. Thus far, glyphosate-resistant
populations of Conyza and Euphorbia heterophyUa ha^re
evolved in Brazilian GR soybean areas (Table 2). Paraguay
and Uruguay are also adopting GR crops. Given the
dominance of GR crops in soybean, cotton and maize agro-
GR crop
It is tmtmoive to contrast the situation in Canada with that
in the VSA and Aigenrma. In die western Canadian giainbelt
la^vaw^ (Alberta, Manitoba, Saskatchewan), canola is the
mdy GR crqp present. In this agro-ecosystem, non-GR
wheat and barley dominate, with canola as an important
rotational crop. Additionally, not all the canola grown is
GR: in 2007, of the six million hectares of canola in Canada,
tmlf 70% was GR. Canadian growls also have transgenic
glufosinate-rcsistant canola, and mutagenesis-derived
inudazoUncme herbicide resistantcanola. Therefore, there is
the option for diversity in canola type and herbicide use,
Abo, it is important to recognise that as canola is a rotational
crop, it is ^own on a particular cropping field only every
third or fourth year. As the rotational cereal and any other
crops arc not GR, it is thus Kkeiy diat a GR crop is grown on
a particubr field only infrequently. Clearly, the glyphosate
selection intensity on weed species in this Qmadian canola-
cereal cropping agro-ecosystecn is much less than with GR
crops in dw USA or Argentina. Unsurprisingly, there are
currently no known cases of evolved glyphosate-resistant
weeds in Oinada. This is undoubtedly due to the diversity
(as it refers to herbicide use) evident in d«s Canadian
cropping system, relative to that in the GR soybean-maize-
cotton agro-ecosystems of the USA. Thus, GR caftola ishould
remain sustainable in Canada if this diversity is maintained.
Iherc arc important lessons to be learnt for other pares of the
world, from this sustainable use of a GR aop in Canada.
Conclusion
A ma|or {e.sson evident from more than three decades of non-
^ selft-tive glvp^osair tn bi!8''jn« •>! planr%
% worldwide is that where diversity in weed manag^nneot
'' systems is mamcauicd, then weed control &y gl^hosare can
be sustainable. Giy|diosate is a remarkably robust iMtrbkide
from a resistance evolution viewpoint. However, as reviewed
above, it is clear diat where there is very intense ^yphosate
selection without diversity, glyphosate-resistant weed
populations will evolve. Particularly, the evolunon of
glyphosate-resbtant weed populations is a major tlucat in
areas where tran^g^nic glypht^sate-rcsistant crops dominate
die landscape, and in which glyphosate selection is intense
and without diversity. As glyphosate usage continues to be
intensive in these areas (Forcsman 8c (Jlasgow, 2008), sc is
likely diat glyphosate-resistant weeds will become a major
problem. There is a strong likelihood that resismnee
evolution will eJiminare glyphosate as a wsed management
option in these important crop regions. This being so, the re-
tatroductiem and/or maintenance of dlversi^ in these agro-
ecosystems is essential. What spedficaily constitutes
“diversity* will vary according to r^ion, ecosystem,
^i^rises, economics and many odier faaors. However,
dii^sity will involve herbicide rotarions/sequen^, mixtures
2S8 Outlooks on Post Hanagoment - December 2008
693
of robust rates of herbicides with different modes of action,
and use of non-herbicidc weed control tools. Such diversity
must be introduced now in the GR cropping areas of dte
USA, Argentina and Brazil. Mixtures of glyphosate with
effective doses of different herbicides are already being
adopted, and transgenic crops with additional hcrf)icide-
resistance genes are in development (Behrens et al.^ 2007,
Green et al., 2008, Sammons et al., 2007). Alternative
herbicides and integration with non-herhicidal weed control
tools will be required.
For those regions of the world that have not yet adopted GR
crops and/or intensive glyphosate usage, there are lessons to
be learnt from the GR crop experience in the Americas. By
avoiding intense glyphosate reliance and through
maintenance of diversity, the longevity of this precious
herbicide resource and of excellent GR crop technologies can
be sustained for fumre harveste. Glyphosate is essential for
present and future world food production, and action to
secure its sustainability should be a global imperative.
References.
Behrens M.R., Mutlu N., Chakraborty S., Dumitru R., "Wen Z.J.,
LaVallcc B.j., Herman P.L. Clemente T.E. & Weeks D.P. (2007).
Dicamba resistance: Enlarging and preserving biotechnology-
based weed management strategics. Science 316: 1185-8^
Duke S.O. & Powics S.B. (2008). Glyphosate: A once-in-a century
herbicide. Pest Manag. Sci. 64: 319-23.
Dil! G.M., Jacob CA 8c Padgette S.R. (2008). Glyphosate resistant
crops: Adoption, use and future considerations. Pest Man .i J i
64: 326-31.
Foresman C. &C Glasgow L (2008). US grower perceptions and
experiences with glyphosate-resistant weeds. Pest Manag Set.
64: 388-91.
Gianessi LP. (2005). Economic and herbicide use impacts of
glyphosate-resistant crops. Pest Manag. Set. 61: 241-45.
GLYPHOS.^r;-’ v-- ■
Green J.M., Hazel C.B., Forney D.R. & Pugh L.M. (2008). New
multiple-herbicide crop resisunce and formulation technology to
augment the utility of glyphosate. Pest Manag. Set. 64: 332-39.
James, C. (2006). Global Status of Commercialized Biotech/GM
Crops: 2006. ISAAA Briefs No. 35. ISAAA: Ithaca, NY, USA.
Heap L (2008). hitcrnational survey of herbicide resistant weeds.
www.weedscience.orgftn.asp. {Accessed 25-08-2008)
Owen M.K., (2008). Weed species shifts in glyphosate-resistant
CTops. Pest Manag. Sci. 64: 377-87.
Powles S.B. (2003). My View: Will glyphosate continue to aid world
food production? Weed Science 51: 471.
Powles S.B. (2008). Evolved glyphosate-resistant weeds around the
world: lessons to be learnt. Pest Manag Sci. 64: 360-5.
Sammons R.D., Hccring D.G., Dinicola N., Click H. 8c Elmore
GA. (2007). Sustainability and stewardship of glyphosate and
^yphosate-resistant crops. Weed Science 21: 347-54.
Shancr D.L. (2000), The impact of giyphosate-toicrant crops on the
use of other herbicides and on resistance management. Pest
Manag. Set. 56: 320-6.
Trigo EJ.Sc Cap EJ. (2003) The impact of the introduction of
cran^eoic crops in Argentinean agriculture. AgB 'toForum 6: 87-
94.
Vila-Aiub M.M., Vidal R.A., Ealbi M.C., Gundel P.E., Trucco F. 8c
Ghersa CM. (2008), Glyphosate-resistant weeds of South
American cropping systems: An overview. Pest Manag. Sci. 64:
366-71.
StephuiPiMlet li a Protestor <• ) * xKc>>'<« ” *. c ^ kh
ofWuMmAimnliLHac^ MA
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••r rt •■‘s hi ippc'rcd in O'aioo^£ i Ppst Mqnogenent 'nclwde - ‘999 io(2) 52,
.01*^ I6r4) lb* ''I'l 17(6)246, 2007 18(5)213
Outlooks on Pest Management -■ December 2008 259
694
JOURNAL OF
AGRICULTURAL^
FOOD CHEMISTRY
J. Agrk Food Chem. XXXX, XXX. 000-000 A
D0l:10.1021/)f101286ll
Herbicide-Resistant Crops: Utilities and Limitations for
Herbicide-Resistant Weed Management^
Jerry M. Green*’* and Micheal D. K. Owen*
®Stinc-HaskcIl Research Center, Pioneer Hi-Bred Interaational, lac., Newark, Delaware 19714-0030, and
^’Department of Agronomy, Iowa State University, Ames, Iowa 5<K)1 1-101 1
Since 1996, geneticaBy moeSfied herbicide-re^stant (HR) crops, paiticulaily g^^tsate-r^istant (GR)
crops, have trartsfCHmed the ^ics that com, soybean, and cotton growers use to manage weeds. The
use of GR crops cemtinues to grow, but weeds are adapting to the common pr^ce of using or^ gly-
phosate to control weeds. Growers using only a sin^ mode of action tt> manage weeds need to diange
to a more diverse array of hetbictdal, mechanical, and cultural practices to maintain the effectiveness of
giyphosate. Unfortunately, the introduction GR crops and the high initial efficacy of glyphc^te often
leei to a dedtoe In the use of other herbicide options and less investment by industry to dieover new
hetHcide ettive ingiodients. some exceptions, most growers can still manage their weed pntotens
(Xirrentiy availat^e selective and HR crop-enetoled herbiddes. However, current crop management
systems are in jeqjardy given the pace at wNch weed peculations are evoMng giyphosate resistance.
New HR erre techrvjlogies vwll expand the utility of curr^ty available herbicides and enable new interim
sohitions f(H' growers to manage HR weeds, but ^ not replace the long-tem need to dtverdfy v^ed
management tactics and discover herbiddes witti new modes of action. This paper reviews the strengths
and weaknesses of anticipated weed management o^ns and the best management practices that
need to Impiemwit in HR crops to maximize the long-term benefits of current technologpes and
reduce weed shifts to difficult-to-control and HR weeds.
KEYWORDS: Com; Zaa mays; cotton; Qossyplum hlrsutunr, soybean; G/yofne max; crop; herbicide;
resistance; tolerance; weed mwiagement
INTRODUCTION
Herbicide-resistant (HR) crops, particularly giyphosate -resistant
(GR) crops, have transformed the way many growers manage
weeds. However, after three decades and billions of dollars invested
in research, only a few transgenic herbicide trails are commercially
available (J-3). Two transgenes code for a glyphosate-insensitivc
5-cnoiRTUvylshikimate-3-phosphate synthase (EPSPS; EC Z5. 1 . 19),
th e epsps gene from Agrobacterium tum^aciens strain CP4 and
the "Stated zm-2mepsps from com {Zea mays L), and three
transgenes code for metabolic inactivation. One gene from
Ochrobactrum anthropi strain LBAA encodes for giyphosate
oxidoreductase (GOX), and two homologous genes, and bar
from Streptomyces viridochromogenes and Streptomy<xs hygro^
scopicus, respectiwly, encode A'-acetyltransferases that inactivate
glufosinate. Today, HR traits are used on >80% of the estimated
134 million hectares of transgenic crops grown annuafly in 25
countries Q, 4) with a single trait, CP4 EPSPS, being by far the
most utilized (5).
Growers rapidly adopted the first GR crops because the
technology enabled a new weed control practice with giyphosate
^Pan of the Comparing Conventional and Biotcchnology-Based
Pest Management symposium.
•Corresponding author [phone (302) 366-5548; fax (302) 366-6120;
e-mail jerry.m.green@pionecr,com].
that was effective, easy-to-use, economical, safe, and novel. The
novel attribute of the gene technology was essen^ to get patents
that protected the large investment needed to develop the
technology, whereas growers touted the simplicity and conveni-
ence of the glyphosate-based crop systems (/-S). Initially,
giyphosate was exceedingly cfleclive in GR crops, and many
growers relied only on giyphosate to control weeds. Some
academic weed scientists were concerned about the sustainability
of this approach and predicted the evolution of resistance.
HoMwver, no cases of GR weeds had evolved after mwe than
tw<iii gcad K j>f ^ oadjis^i n noncrop situations. (6), and some
■^eed ^wTSstsandgrowereb^anto think that GR weeds would
never be a problem. Then the paradigm changed in 1 996 with the
discovery of GR rigid ryegrass {Lolium rigidmi Gaudin) in
Australia ^.5).
Today, all accept die evolution of GR weeds is threatening the
continued success of GR crojs and the sustainability of giypho-
sate. Nineteen weeds have evolved resistance to giyphosate; about
half evolved in GR crops ^). The basis for resistance has been
attributed to altered EPSK target site (/O), reduced franslocation
or cdlular transport to the plastid (//), seqttestration in the vac-
uote {12), and gene amplification [13). GR weeds increase the cost
of weed control and diminish the benefits of glyphosale-based
weed management s^tems. In retrospect, it was inevitable that
GR weeds would evolve. Giyphosate was a victim of its own
OXXXXAmsricsn Chemicai SociNy
pubs.acs.org/JAFC
695
B J. Agm, Food Chem., Vof. XXX. No. XX, XXXX Green and Owen
Table 1 . H^ticKte Types Commonly Used in Com. and CcWrn simS Hier MeStesj, Preemeigenc® (PRE) w Postemes^nse (POS1), wfith
Rg^jsd to Crop
hsHbidde type (gro^®)
cwn
cot^
SWjositeCSS
PRE Old POST
PRE rosT
PRE mi POST
POST
POST
msT
ALS Wiibi!of(B)
Pi^arrfPOST
PRE and POST
pm mi POST
syr^jsfe ausn (0)
PRE and POST
PRE and POST
PRE aid POST
HProi!^l^f(F2)
PRE and POST
PRE
PPOIr^torCE)
PRE and POST
PRE and POST
PRE and POST
ACX;^b*il5Ror(A)
POST
TOST
phdcsystsns nViMw (C)
PREarsiPCST
PRE am! POST
F^E ami POST
c^#fl'saantfMstorCK2)
PRE
PRE
PRE
phyt(^^ ds^me irMsilor (F3)
PRE
®Heibi^s groi4«d 8£cw*g to 8» Hest^de Resistawe <XsBi^e !%://«n¥W 4 ^afttpfOie^
sumss. No matter hQweff<x:d w a herbicide is, weed nmageiR«it
pro^ams (^not rdy so h^vily on one ta:ticor^eds wiB inti-
mately adapt and survi'ito sa large numbers.
In essence, GR crops created the “perfect stoim” for weds to
evolve resistance. Growers ai^Iied glyphosate alone qv& vast
cropping areas to control ^eticaDy variable aiaJ pf<^fic wads
year after year. M^y of th^e w eds had already evoh^ i^ tanoe
_ to other heri>icidemp^ofS!f^^roTS«cwsno^^lSrbidde
glypJrostrte (i^jrOTpirtiCTBS^OKlrtfie^sc ^the highly com-
j^MWatKTp^lic Palmer amaranth (Amarantims ^^meri S.
Wats,). The exploiaonofORPaimer amaranth populations in the
southeastern United States became knowm as the "pigweed dis-
aster” (/J). These GR populations are forcing growre tochwige
their production practioes and itKaca^ the costs for weed control,
ewsn to the extent of hand-wading. Because of thoe shortsighted
use practices, giyjAosate is not a.s cffecriw as it ujwd to be and
growers must suj^lement j^yphosate with other l«rbiddes.
Growers now need to diversify the herbicides they use to
mitigate the spread of GR weeds { 16 ). Unfortunately, the che-
mical industry has not commercialised a herbicide with a
new mode of action (MOA) for over two decades ( 17 ) . This is
partly because the number oFcRfeniciis that must be tested to
discover a new herbicide has increased from fewer than 1 000 in
1950 to more than 500,000 today and partly because compan-
ies are investing less money to discover new herbicides as the
wide^read use of GR crops has reduced the market opportunity.
To address the GR wad probtem, tlHS industry isjow de wtop ing
new neAiddS f ^Slancii irfeitsTltar^f ^oand the utilitvT of
jC^^^Iy^^^S^^ESS^einRoweveiTinsaWcallyin^or-
TanTIorecognize that these traits repraent interim solutions
for current weed problems and do not replace the long-term
need to discover herbicides with new modes of action and to
diversify weed management tactics.
UTItmeS AND LIMITATIONS OF CURRENT HERBICIDE
TECHNOtOSIES
Current Herbkide Use Practices. GR crops came at a time of
great socioeconomic cha.nge in agriculture. Farm sire was in-
creasing, and the number of growers wm declining; thus, powers
had to become more efficient. Furtbamore, weeds we rapidly
evolving resistance to various herbicides, and growm peroeived
wad management aj tddng too mswh time. Growers wanted new
weed management tactics, and GR crops enabled an eronoaueal,
efficient, and simple solution. Once growers started uang glypho-
sate, they overus^ it. The awsrage rate and munber of
tions of ^yphosate increased as its price declined, and the ua of
other herbiddes decreas«l ( 18 , 19 ). Competitors reactoJ by re-
dttdng the price of their herbidda, but those altemativa couW
not maintain their market presence ( 20 ).
In retrospect, GR crops could have bdped to inssease the diver-
si^ of hatdeides that growers used (Table 1), GR crops did not
reqmre that growers use only glyphosate and the add^ diverrity
of glyphosate combirted with other habiddes would have miti-
pted the evolution of HR weeds. However, the use of tank mix-
tures and sojuentiai application of different herbiddes declit^d.
la <me year, from 1997 to 1998, the use of glyphosate increased
81% in parallel with the increase of GR soybeans [Glycine max
0!-,) Merr.J from 13 to 36% (27). The number of hsrWdtk active
ingrcdiente used on at least 1 0% of the U.S. soybean area dahsed
from 1 1 in 1995 to only h ^yphosate, in 2002 (22). Even though
the chance of weeds evolving resistance to glyphosate in a par-
ticular loc ^ioa is sfctB predicted to lx; lower thala wtfh
h erbigde8.*weeos . uttn^ety QKlmivegl 5 ^hesaerestysncei is a
dii^ tBft iwreed
InteresUngly, HR weeds often do not decrease the amount of
hert^de used because growers make babidde derisions based
on weed complexes, not individual sjped^ or hiotypes. If a weed
evolves resistance to a herbicide, that herbicide has not lost ail of
its value as it stiH contrds other weeds, and growos often con-
tinue to use the herbicide in a program with another herbiddc to
control the resistam weed. Furthermore, growers do not “recog-
nize” the potentiai for iw«ds to evolve resistance to glyphosate
until the Iriotypes appear in their fields (25). Unfortunatriy, this
can lead to the practice of sequentially usang Iicrbiddes until they
are no longer ^ective, which is the latest way to evolve multiple
HR wads (/6). A combination of hglnekles. odtural and me c-
h anical t«:dc5 provides the latest protection from HR
^some weed species are particularly troublescHnc to contrd ami
in theft propensity to evolve resistance (Table 2). Problematic
weeds in gh^hosate-based production systtsms that have evolved
genetic mutations that confer glyphosate raistance include
Palma amaranth and waterliemp [Amermikus ixiherctdatus
(Moq.) Saua]. Other weeds such as wlyetleaf the^rasii
(L.) Medik.}, morningglories (Ipomoea spp.), Asiatic dayflower
(CommeUm commur^ L.), tropical spiderwort (ComimHm bm-
ghaiensis L), and field bindweed (Cmvolvuim arvenis L) oftm
survive because of naturally higher tolerance. Populations of
tolerant weed species increase vi?hen growers use l4s than fuJI-
i abeled rates (251 . Currently, at least seven GR weed'^m^'^
evolved resistance to multiple herbicide MOAs, with one popula-
tion of waterhemp in Illinois being resistant to four (27). The
rapid expansion of multiple HR weed populations threatens the
siBtaiaabiiity of current crop production systems (16).
Tlie best weed managesnenl strategy is to control prior to
the lo^ of crop yield potential and p roactiv'etv delay the cvolnrio n
of weed mlstencs - Fwtunately, most Selds do
wads S3lSrc is still time for many grow;i? to inclement
divase and proactive weed management practices (Table 3) (25).
696
Food Cfteffi..VoL XXX, No. XX, XXXX C
Articie
Tabte 2. Summary of Key Row Crop Weeds and Herbickte Efficacy
weedspedes*
control rating (0-
-10) aid resistance Satus"-'
oxnmonnaffle
screnii^c name
^y(^Kreate giuloanate
ALS
inhibitors
^thetic
au)^s
HPK)
rriidkirs
PPG
inhitxtore
AC^ase
inhibitors
common bmbsquarters
Cfi&iopa^m abum L
Dicotyledons
m
8
7R
9R
9
9
0
redroot pigweed
Amaranthus letroffexus L
9
8
9R
9
9
9
0
waiettienp
Amaran^ Uberculatus (Moq.) Sauer
9R
S
9R
8
9
9R
0
P^mer amaranlh
Ammnttnjs palmer? S. Wats.
9R
S
9R
9
9
9
0
velvelleaf
AbuSlon theofbiase Medik
8
8
8-9
8
9
8
0
common cocidebur
st/vmamm L
9
9
9R
9
8
8
0
common ragweed
AmhrtKsia arbmi^l^ L.
SR
9
8R
9
7
gR
0
giant regwe^
Aml^osiabiSdaL
7-8R
8
7~8R
9
8
8
0
horsew^
Conyza canadensis ^) Cronq.
7~8R
8
7R
8
8
8
0
momirigglories
Ipomoea sf^.
7
B
7
9
7
8
0
koeffia
KocNa scopmia Q..) Schrad.
9R
8
9R
gR
7
8
Q
ewamon simflowr
HelianbusannimL
9
9
9R
9
9
8
0
giwt fox^g
Se&ria iaberi H^im.
Monocotyledons
9
9
8R
0
S
7
9R
green foxtail
Se^a virkSs (L.) Beauv.
10
8
SR
0
4
5
9R
ydlow foxtml
Sebria pumafa (Par.) Roemer & J.A. Schultes
9
8
9R
0
6
7
9
johnson^ass
Sor^Hjm halapensa 0-) Pers.
9R
6
8R
0
0
8
9R
(rhizome)
^la^cane
SotglHffn ficotof (L) Mowch
10
9
10R
0
8
7
gR"
large crabgrass
Di^ria sangdnaSs (L.) Scop.
9
8
gR
0
7
6
9R
ban^rdgress
ctus-gaU il.) Beauv.
9
9
gR
0
7
6
9R
WCKlIfy ojp^s
Erkxi^ vyiosa (Thunb.) Kunth.
9
9
9
0
7
5
8
fall paniciM
Parrieum dlcbofomlribrum M'chx.
9
8
8
0
5
4
9R
It^an ryegr^s
LoBm mulWbtwn L
9R
8
8R
0
3
3
9R
feral com
Zea mays L.
9R
7R
8R
0
0
6
9R*
*Weed setection determined by a market nsearch survey of U.S. com, soybean, and cotton growers by Glk Kynetec, Irrc., St. louis, MO (used with permiKion). "Weed
control faSngs are summarized from U.S. exterts^ giAfes wim 0 beng dw lowest and 10 being the highest level of control. A ratir>9 of 27 indicates effective herbicide con^.
Weed ratings r^iesent the Nghest observed for any active in that dass. "An R next to hertndde efficacy mting indicates that this weed has dev^ped resistance to herbicide irxxle
of acticm (Heap 2010). ^ACCase resistance has been confirrrted but not flsted at Heap 2010- *ACCase trait currer^ly under developmenl and anbc^ated to be vr issue
in fer^ com after commerdalizatiort.
Qencraliy, the basic management tactics are the same for both t he
p iy'entlOOandCOntrolofHRwaeds thatic riivprsifirariATtnftacrj^
lot ^iige setectinn pressure imposed Specific herbicide s. The chal-
is to implement these practices under prevailing economic con-
straints when powers are not convinced resistance management
tactics will be effective or they believe industry will continue to deb-
vw iKW solutions to manage wroeds(?9). Many growers are reluctant
to diversify weed management because they p e ns ive alternative tac-
(ics as being less cost-effective de^te powing evidence that such
tactics can improve profit^ility as well as mitigate resistant weed
issues 00). More education will help overcome this perception as
wiU the expbsion of multiple HR weeds that emphatically per-
suades growers to diversify their weed management practices
now or face serious long-term consequences.
Current Herfucide Technologies. B^des glyphosate, most cur-
rent herbacidw used for weed management in com, soybean, and
cotton are selective and typically used in mixtures to control a
broad spectrum of weed species. The following section provides
an overview of the utilities and limitations for various herbicide
MOAs that have potential utility in HR crops.
Glyphosate. Glyphosate is a nonalective, broad-spectrum
foliar herbiedek: with no soil r^idual activity that has been used
for >30 yeai^ to manage annual, p«'ennial, and biennial hcrt>ac-
eous grass, sedge, and broadleaf \weds as well as unwant^ woody
brush and trees. Glyphosate is labeled to control over 300 wc^
sprats. Many glyphosate formulations and salts are commer-
cially available; the most common salts are the monopotassium
and isopropylamine. The type and amount of adjuvant included
in the various formulations differ ^atly and strongly influence
weed control. Glyphosate strcfflgiy competes with the substrate
phosphoenolpyruvate (PEP) at the EPSPS enzyme-binding site in
the chloroplasl, resulting in the inhibition of the shikimatc path-
way. Products of the shikimate pathway include the essential
aromatic amino acids tryptophan, tyrosine, and phenylalanine
and other important plant metabolic products 01). The relatively
slow MOA and physicodicmical characteristics result in glypho-
sate translocation throughout the plant and accumulation at the
vital growing points before phytotoxidty occurs.
Favorable physicochemical characteristics, low cost, tight soil
sorption, application flexibility, low mammalian toxicity, and
availability of GR crops have helped make glyphosate the most
widely used herbicide in the world (52). A key advantage for
glyphosate has been the conastent control of w^ds almost with-
out regard to size. However, the flexibility in glyphosate applica-
tion timing and lack of soil residual have often resulted in powers
delaying applications to help ensure that all of the weeds have
emerged. Unfortunately, such delay in application meara that the
weeds have begun to compete with the crop and thus red uced
potential yiel d. The increased use ofmixtUres with herbicides that
have soil residual activity will enaiuragc powers to make earlier
glyphosate applications and increase the likelihood that a single,
application gives season-long cons ol. OthCT commonly note d
.wealcne^sw w ith glyph^ate^re Hghcr ratesneede^ to control
the more tolerant broadleaf weeds, antagonism by hard water
and tank mixture partners, slow speed of action, and poor
rainfastness.
697
D J.Agria Food Cftem.,Vo!. XXX, No. XX, XXXX Green and Owen
Table 3. Assessment of Commonly Used Tactics f(»^ Hert^deltesistant Weed Management (Ada^ed ^ Reference 28)
tactic
benefits
t1^
potential imF»ct
n^'on
reduced setedon pressure,
cemtfol HR weeds
lack (tf (fifferet^ MOAs, pliytotoxidty, cost,
weed spec^ of altem;^tyes
excell^
mixtures
reduced selecSon pressure.
in^Hwed corrtroi,
broader weed spectrum
poor activity on W) w^ q»des, irvreased cost;
petenS^ phytotoxidty
excellent
vart^ appfication
bettercwjtiT^ of HR
species, more effident
herbo^use
tack herbidde reddual activ%, ftning may be too fate
to protect yield potential, more sppEcations
good to excellent
adjusted hert^dde
retes
beUar control target spedes
increased target-site selectirm (xessue with high^ rates,
increased nontaiget site witit lower rat^ (polygenic resistartce)
poatofair
prect»on hefbidde
appiic^on
deceased herbicide use. reduced
seiecion pressure
increased cost of appScalion, unar^t^ of weed
popufafion maps: poor underslandng of weed
seedwA dynamics; increased varis^Tity of contrd
poor
p{^ry Wage
decreased setecHoi pressure,
oxidstent efficacy;
depletion of weed seedbartk
increased time required, increased soi erosion,
increased costs, addiional tactics needed
good to excetter^
mechanic^ weed
cont'ol strategies
decreases sele^on pressure;
consistent efficacy,
reiativefy inexpensive
increased tine reqt^, Ngh level of management
ddl needed, additional tactics needed,
pr^enlial for crop injury
poor to fair
crap seiecdon/
rotatHKt
changes agro-ecosystem,
allows efi^rent
herbidde tactics,
reduced selecbon pressure
economk: risk of altemairve rotation crop, lack of adapted
rot^n crop, rotation crops am^ar ^ thus rnkumal impact
on the weed community, herbicides, required, lack of
reseaidt base, irtconsislent impact on HR weed populations
fairtogood
ad}i£ted time
erfpian^g
potential improved efficacy
on target weeds,
reduced selection pressure
requires atemative strategies (flage or herbickle),
potertfi^ for yield loss, rteed tor increased rotation cSversity
poortoteir
ac^tsled
seeding rate
reduced selection pressure,
improved competliive
ability lor the cr^
increased seed cost, potentialfy inoeased pest problems,
irwreased intrespe^ competition, reduced potently yields
fair
planting conjuration
irrproved competitive
ability for the crop,
reduced selection pressure
ur}avai^>8ity of mecharve^ stratef^s, emphasis on herbicides,
equipment Iknitations
good
COV9 crops, mulches,
intercrop sy^s
irr^roved competitive ablHty,
reduced selection pressure,
improved systems
diversity, allelapathy
inconsstent effect cn HR weeds, lack of under^andirtg about
systems, limited research base, petential crop yield loss,
need for herbicide fo manage ihe cover cit^.
lack of good cover crops
poor
seedbank
managemer^
re&jrred HR weed pressure,
reduced selection pressure
iad( of understanding about seeefoank dynamics,
teqisres aggres^e tiage,
emfi^sis on late hertxcide applications,
Ngh level of management sioll needed
teirtogood
ar^stmei^ of nu^t use
irt^roved competitive abiHty for
^ cn^, effident use of mitr^t
lad( of research tese,
foconsistent resi/ts. potentiai crop yi^ loss
poor
Glufosinate. Glufosinatc is a nonsclcctive, broad-spectrum
foliar herbicide with no soil residual soU activity that inhibits gluta-
mine synthetase [GS; EC 6.3.1.2], an erngme that catalyzes the
conversion of ^utamate plus ammonium to glutamine as part of
nitrogen nutabolism (?/). Glufc^inate is faster aoting and controls
key broadleaf weeds such as mortdngglories {Iptmoea spp.), iKrap
sesbania {Sesbmia herbacea (P. Mill.) MeV^gh), Pennsylvania
smartweed {Poly^mum pensylvamcum L.), and yellow nutsedge
{Cyperus escukntus L.) better than giyphosate. However, glufo-
sinate is used at higl^r rates and has historically been more
cjtpensivc than giyphosate. Cost and more restrictive application
timing relative to weed size are probably its greatest disadvanta^
compared to giyphosate. Because glufosinate behaves ^ a contact
h^bicide, it must be aj^lied to smaller plants than giyphosate and is
not as effective on perennials that require significant translocation
for complete control. Still, glufosinate is labeled to control >120
broadle^ weeds and grassy including key GR weeds. No vreeds
have been fonnally reported as glufrain^resistant yet ^).
Synthetic Auxins. Synthetic auxin herbicides act as auxin
agonists by mimicking the plant growth hormone indole-3-acetic
698
Artide
acid (lAA), disropting ^owth and development processes, and
eventually causing plant death, particularly in broadleaf spe-
cies (5/). Grovrers have used auxin herbiddes widely for over &D
yeara as selective herbiddes in monocotyledonous crops. Auxins
control a broad spectrum of broadleaf weeds, including key weeds
that have evolved resistance to glyphosate. Some synthetic auxins
such as dicamba have fair soil r^idual activity with a half-life
from 7 to 21 days. Relatively few \weds have evolved resistance to
auxin herbiddes, which is noteworthy considering their long-term
and widespread use. For example, only six weed spedes have
evolved resistance to dicamba a^r 50 years of widespread use in
cereal and noncrop environments (P).
The increased use of dicamba and other auxin heibiddes in
auxin-resistant crojK has the potential of injuring other broadleaf
crops and reducing biodiversity in field edges and nearby ntmaop
habitat if unmanaged (5i). Off-target movemrart of auxin herW-
ddes can occur via spray particle and vapor drift. Particle drift is
more problematic tlun vapor drift, but growers can manage with
modified application tcchniqiKS, drift control adjuvants, and co-
rrect decisions as to when, wl^re, and how to apply. Particulariy
troublesome for auxin herbicides would be any movement onto
highly sensitive crops such as soybeans, cotton {Gossypium
hirsutum L.), or grapes (Vitis vintfera L.). Interestin^y, 2,4-D is
safCT Umn (^camba on soybeans and dicamba is safer than 2,4-0 on
cotton (34). As little as 0.01 % of the labeled rate of dicamba can
injure soybeans 05), and 0.001 % of the labeled rate of 2,4-D butyl
ester formulation can injure tomatoes (Lycopersicon esculentum
Mill.) and tettuce (Lactuca saliva L.) (?d).
SoHKJ forms of dicamba and 2,4-D are highly volatile, especi-
ally at high temperatures. For example, the add form of dicamba
is more voktile Aan amine salt form^ations, and some amine salts
are more volatile than otl^. Considerable research is underway
to minimize volatilization with new salts and formulations. The
manufacturer can also reduce potential off-target movement with
application restrictions based on temperature, droplet size, humi-
dity, and wind speed. Because of their volatility and the sensilivity
of nontarget crops, growers will probably not use auxin herbi-
ddes on vast areas during warm weather as is currently done with
glyphosate,
HPPD Inhibitors. The enzyme 4-hydfoxyphenyl pyruvate di-
oxygenase [HPPD; EC 1.13.11.27] converts 4-hydroxypfaenyI
pyruvate to homogentisate, a key step in plastoqulnooe biosynthe-
sis. This is the most recently discovaed herbidde MOA, and active
analogue testing continues to generate new products 07). Inhibi-
tion of HPPD causes bleaching symptoms on new growth by
indirectly inhibiting carotenoid synthesis due to the requirement
of plastoquinone as cofactor of phytoene desaturase [PDS; EC
1. 14.99] 08). Visible injury depends on carotenoid turnover and
thus is slower to appear on older tissues than young leaves (31).
HH*D-mhibiting herbiddes control a ntunber of important we«l
spedes and may have soil residual aaivity, and no weeds have
been formally reported to be resistant to this MOA yd. Com is
naturally tolerant to key HPPD herWdrks, but soybeans and
cotton are generally sensitive.
ALS Inhibitors. Herbidde that inhiWt aretolactate synthase
{ALS; EC 2.2. 1.6), also known as acetohydroxyadd synthase
(AHAS), were discovered in the raid-1970s and are still widely
used 09, 40). The ALS enzyme is a key step in the biosynthesis of
the essential branched<hain amino adds valine, leudne, and iso-
Ididne. ALS is a nudear aicoded enzyme that moves to the dUo-
roplast via a tranat peptide. More than 50 different ALS-inhibiting
herbiddes from five diffM-ent chemical dasses (suifonylureas, imi-
dazolincmes, triazolopyrimidines, pyrimidinylthiobenzoates, and
suifonylamino-carbonyl-triazoiinones) are commercially avail-
able. The characteristics of ALS herttcidw vary in their soil
J.AgrfefbodChem.,Vo!.XXX,No.XX,XXXX E
residual properties, crop response, and types of weeds that are
effcdively controlled. ALS herbiddes can provide foliar and
seal residual ^ivity on important grass and broadleaf weeds at
low application rates. The tendency of weeds to evolve resis-
tance to ALS herbiddes limits thdr utility (9), and their use is now
mainly in mixtures with other types of herbidrtes.
PPO IrOiibitors. Protoporphyrino^ oxidase (PPO; EC 1 .3.3.4)
is an essential enzyme that catalyzes the last common step in the
bb^nthesis of heme and ultimately chlorophyll 1^ the oxidation
of protoporphyrinogen DC to protoporphyrin IX. PK)-mhiWting
herladtfcs cause the accumulation of protoporphyrinogen IX,
whidi is photoactive, and exposure to light causes the formation
of singlet oxygen and other oxidative chemicals that caute rapid
burning and desiccation of leaf ti^ue. The soil residual and fast
action characteristics of PPO herbicides complement the lack of
s<hI i^dual and the slow activity of glyphosate.
PPO enzyme mutations tend to reduce the enzymatic activity,
which helps explain the relatively slow evolution of resistant
weeds to this 40-year-old herbidde class 01). Companies cont-
inue to synthesize analogues and commerdalize new PPO-inhi-
biting herbiddes. For example, saHufenadl was introduced in
2010 and is labeled for use in a wide variety of crops, including
com, soybeans, and cotton 02). Its label describes bumdown ai«i
residual control of 70 broadleaf weeds including key troublesome
weeds in glyphosate-based systems such as common lambsquar-
ters (Chenopodiion album L.), horseweed [Conyza canadensis (L.)
Cronq.j, waterhemp, and common (Ambrosia artanisiifolia L.)
and giant (Ambrosia triflda L.) ragweeds.
ACCase Inhibitors. Acetyl coenzyme A carboxylase [ACCase;
EC 6.4. 1 .2] is the first step of fatty add synthesis and ca^yzes the
adenosine triphosphate (ATP)-dependent carboxylation of mal-
onyl-CoA to form acctyl-CoA in the cytoplasm, chloroplasts,
milodiondria, and po-oxisomes of cells 03). ACCase-inhibiting
herbiddes generally inhibit the ACCase adivity of monocot
spedes and not dicots. The three chemical classes of ACCase inhi-
bitors are cyclobexanediones (DIMs) (e.g., sethoxydim), aryloxy-
phenoxypropionates (FOPs) (e.g., quizalofop), and phenylpyr-
azolines (DENs) (e.g., pinoxaden). The abiilty to use ACCase
herbiddes selectively in com would be useful, but the tendency of
weeds to evolve resistance to this herbidde class would limit its
utility to being part of a weed management system (9).
Other Herbicide Types. Currently used selective and bum-
dovm herbicides wilt continue to play important roles in weed
management in HR crop systems (Table 1). In addition to the
herbidde types already discussed, photosystem IT (PSII) inhibi-
tors such as Iriazine and urea herbiddes, lipid synthesis inhibitors
such as 5-melolachlor, and phytoene desaturase (PDS) inhibitors
such as clomazone will continue to be used as crop-selective herbi-
ddes to provide soil residual adivity on key weeds. Paraquat is a
photosystem I (PSI) inhibiting herbidde typically used in conser-
vation and no-tillage production systems for nonsel«:tive burn-
down control of emerged weeds or as a directed spray with speda-
lized application equipment in crop. Paraquat controls a broad
spectrum of weeds, and the lack of soil r^idual allows rotational
crop flexibility similar to glyphosate and glufosinate. Paraquat
rapidly desiccates leaf tissue and thus does not translocate well
enough to control perennial weeds. Par^uat is relatiwiy in-
ejqjensi^te, but its hi^ mammalian toxidty imposes significant
use and handling restrictions.
UTiUTIES AND LIMITATIONS OF CURRENT AND FUTURE
HERBICIDE-RESISTANT CROP TECHNOLOGIES
Current HR Crop Technologies. A large number of transgenic
and nontransgenic HR crops have been commercialized (Table 0.
699
F J. Agric. Food Chem., Vol. XXX. No. XX. XXXX
Ti^ 4. Summaty Commerctai Herbidde-Resistant Crops in N<^
Amei^ (Adapted from Reference 44)
hetbidifetype
crop
yesyavaS^
bromox^
cotton
1995
canola
2000
ACC^lrMritor -seteoxydim
com
1996
sorghum
2011
canola
19%
com
1997
cotton
2004
^hosate
soybean
1996
canola
1996
cotton
1997
com
1996
^fa
2005
sug^ beets
WQ5
imidaroiinones
com
1993
carwla
1997
wheat
2002
fe»
2002
surAnwer
2003
specific ;»ifon)^rea$
so^an
1994
sunflower
2006
so^um
2011
trfezines
canda
1984
HR crops general^ eliminated all crop injury concerns and
allowed die grov>«r to select new herbicide options with improved
weed activior and environmental safely. Before the advait of GR
aops, most thought that the utility of HR crops would be limited
to comjrfementing selective hwbiddes (45-47). The full impact of
HR crops really started in 1996 with the sales of GR soybeans.
Since then, the speed at which growers adopted GR crops has been
unpreodented in com, soybeans, and cotton (4). Success came
despite an unpopular "grower contract” and strong objections by
biotechnology opponents to potential unknown effects on the
environment and human health and the ethical question of inter-
fering with the ratural wder.
Nontransgenic HR Crops. With the exception of Canada,
nontransgenro HR traiu are essentially unrelated. Scientists
have used a wide range of nontransgenic techniques to create
crops with resistance to a number of herbicide MO As (Table 5).
For example, the first commerdai ACCase-resistant crop was a
sethoxydim-resistMt (SR) com with an altered ACCase created
udng tissue culture selection (49). A second ACCase trait is in the
final stages of commercialization for use in sorghum. This trait
was transferred with traditional breeding methods from feral
sor^um (^ttercane, Sorghum bicolor L Moench) that had
evolved A(X^ herbidde resistance because of agronomic prao-
ti«s (50).
Creating HR crops for ALS-inhiHting herbiddes has been
quite successful usang tissie culture selection, pollen mutagenesis,
microspore selection, seed muta^nesis, and gene transfer from
close wedy relatives that had evolved herbidde resistance be-
caiBc of agronomic practice (pO-52). Today, at least seven dif-
ferent ALS-rcsislant crops are commercially available (55). In all
cases, resistance is due to an ALS mutation with three general
crop phenotypes: broad resistance to Al^ herlnddes; resistance
only to imid^linone and pyrimidinyithiobenzoate herl^d«;
and resistatKC only to sulfonylurea and triazolopyrimidine her-
bicide (J¥, 55).
Green and Owen
T^ts 5. Summaiy d Non^nsgenic Herdcide-Re^tEUit Cn^ (Adapted
fr«n Reference 48)
sdsdon method
herbidde^
crop
vdide plEUtt
triazine
canola
seed rmttageie^
terbtttryne
v^ieat
aJoni^Lsea
soybeai
Mfezdinone
wheat
rice
ti^ue ctiture
suttcmylurea
canola
a^rine
soybearr
imidazoRnone
com
sethmeycim
com
cel seieetton
Mdazoiicme
su^beet
polen mutagenesis
vnidaQjfincxie
com
microspore selection
imkfezoftione
canota
transfer from weedy relative
ALS inhibitor
sunflow^
sorghum
ACCase inhidtor
s(^um
Table 6. Summary of Currently A\^ilat^ Transgenic Kertadde-Resst^
Com, Soybeans, and Cottem
aoo resistsKe trah
trait gene trait de^^aticxr flrd sales
cdton glyphosate
cp4 epsps
MON1445
1996
two cp4 epsps
MC^488913
2006
zm-2mepsps
GHB814
2009
gMoanate
bar
lLCotton25
2005
com glyphosate
three modified
GA21
19%
two cp4 epsps
NK603
2001
^ufosinate
pat
T14,T25
1996
soybean glyphosate
cp4 epsps
GTS 40^2
1996
^epsps
MON89788
2009
gtufosinate
pat
A2704.12
2009
Glyphosate'Resistant Crops. Nontransgem'c HR crops were
only modestly successful; the big success with HR crops began
with transgenic GR soybeans in 1996 (Table 6). Growers perce-
ived glyphosate resistance as the ideal herbidde trait b^use
^yphosate controls over 300 annual and perennial weeds, has
flexible application timings, artd does not have any rotational
crop restrictions (56). GR crops allowed growers to use giypho-
sate as an in-crop selective herbidde and replace more expensive,
selective herbiddes that controlled a narrower weed spectrum and
had other issues (e.g., crop tolerance).
Within a decade after glyphosate became commerdally avaO-
ablc, the search began to find crop resistance to glyphosate.
Nontransgenic approaches were not successful, and transgenic
approaches were difficult and not initially sirccessful (57). Inititd
attempts to find any natural enzyma in crops that could meta-
bolically inactivate or were insensitive at the target site failed.
Eventually, a gene for a glyphosate insensitive EPSK with eniy-
matic chararteristics similar to plant EPSPS was isolated from a
common soil bacterium. Agrobacterium tumefaciens strain CP4,
which was surviving in a glyphosate manufacturing waste stream
in Luling, LA (57). This cp4 epsps has been used to devel-
op GR soybeans, cotton, com, canola, alfalfa (Medicago sativa
L.), bentgrass (Agrostis stolonifera L.), and sugar be^ (Beta
ndgaris L.) (5).
Glyphosate resistance became the most rapidly adopted tech-
nology in the history of a^cultme (5), but tte first GR crops
were not perfect. The timing, rate, and number of glyphosate
700
Ar^le
TaWe 7. PubPfdy Disciosed Noi>giyphosate Transgenic HeitiddeTtesistant
Traits Significant UWrly Ccm, Soybeans, and Cotton (Adapted fiom
Ref«ence4^
h^bidcte/hettHcicle dass
chai^K'sfics
reference
2,4-D
miQ'd>ial degradatiem en^e
£0
Al^ii^b(b}ra
radstant ALS from msiy source
61
ACXkse inh&ilors
microbi^, aryl 0 ) 5 a#®wate
62
and s^Tthetic ausdns
cXcamba
dioxygo)^
Pseudomoms mltopMia,
63
HPPD irtfta)itars
OdoneStylase
overaiqKession, idtemate pathway,
38
PPO inhibftois
pathway flux
resistant microbfa! and Arabktopss
41
muWpie hert^e
ittaSana PPO
^utathione Str^ferase,
64
desses
EsiAeik^iia co/r
PAM, Zea mays
65
applications had to be restricted to ensure crop resistance (5), and
th«e were reports of a “yield drag” ^5). A new generation of
h«bicide traits currently in devek^ment will be combined with cur-
j«il and new glyphosate traits to he^ coitfinuc to improve this tec-
hnology and extend the tran^enic weed managema\t revolution.
Glitfosinate-Resistant Crops. Glufosinate-resistant crops have
been commercially available as long as GR crops (Table but
have not been as successful for a number of reasons, particulariy
because of the higher cost of glufosinate and its more restrictive
application timing. Glufosinate resistance is widely available,
not only because of its utility as a herbicide trait but also because
it has often used as a marker for other traits, particularly
insect resistance traits. Resistance to glufosinate is due to meta-
bolic inactivation of the parent molecule by either of two homo-
logous enzymes, phosphinothridn AT-acetyltransferase (PAT) or
Irasta Af-acetyltransferase (BAR), that catalyze the acetylation
of gluforinate {59). Both genes were isolated from soil micro-
organisms, /wt from Streptomyces viridochromogenes and bar from
Streptomyces hygroscopicus. Cotton and soybean growers who
are troubled by difficult to control GR we«is such as Palmer
amaranth and waterhemp may rapidly adopt glufosinate-
resistant crops and the use of glufosinate. “Dual stack” crop
cultivara that include resistance to both glufosinate and glypho-
sate are now commercially available in cotton, soybeans, and
com and provide growers a choice between two broad-spectrum
herbicides as well as an array of naturally selective herbiddes to
diversify their weed management practices.
Fuftire HR Crop Techoologies. Whereas GR crops have been
very successful, the evolution of GR weeds was faster and more
wid»pread than many expected. This rapid evolution of GR
weeds and the lack of any new selective herbiddes with novel
MOAs is encouraging HR crop technology to evolve again. The
next wave of technologies will combine resistance to glyphosate
and other herbiddes to providUi growers with more herbidde
options with different MOAs as well as the possibility of using
herbid<tes with both foliar and soil residual activity. Sdentists
have discovered a plethora of herbidde traits that can be
combined with glyphosate resistance to m^e multiple HR crops
(Table 7). I f u^ correctly, multiple HR crops with these traits
can sustain the usefuto *^*’
Resistance to Synthetic Auxin Herbicides. Cora is relatively
tolerant to most synthetic auxin herbidde, but soybeans and
cotton are sensitive, and sdentists have long sought a transgene to
give these crops resistance and allow the use of auxin hcrls-
cides (dd). Auxin herbicictes control a broad spectrum of broad-
leaf weeds, iiKluding most known GR broadlcaf weeds. Because
auxin herbiddes act rapidly at multiple receptors and compete
J.Ag/ib. Food C/?em.,Vol. XXX, No. XX, XXXX G
with an essentia! plant hormone pathway, making crojK resistant
by modifying the site of auxin action is difficult. In addition, these
receptors respond differently to different auxin herddde classes,
fw example, phenoxyacetates (e.g., 2,4-D), pyridinyioxyacetates
(e.g., fluoroxypyr), tenzoates (e.g., dicamba), picolinates (e.g.,
I^oram), and quinolinecarboxylates (e.g., quinclorac) (57). So
far, metabolic inactivation has proven to be a more successful
strategy.
A gene encoding for dicamba monooxygenase (DM0), an
enzyme that deactivates dicamba, was clonal from a soil bacter-
ium, Stenotrophomonas maliophilla, and used to make dicamba-
resistant soybeans {63, 68). The DM0 enzyme encodes a
Rieske nonheme monooxygenase that metabolizes dicamba to
3,6-ciichlorosalicylic acid (I)CSA). The complete bacteria! dicamba
0-demcthylasc complex consists of the monooxygenase, a
reductase, and a ferredoxin. Electrons are shuttled from reduced
niajtioamide adeniire dinucieotide (NADH) through the reduc-
tase to the ferredoxin and finally to the terminal component
DM0. Researchers can successfully express DM0 in the cell nuc-
leus with or without a transit pepti^ as well as in thechloropksts
where the monooxygenase would have a source of electrons
prothiced by photosynthesis and where transgenic proteins can
often be expressed at hitter levels. Commercialization ofdicamba-
resistant soybean and cotton is anticipated mid-decole.
A family of aad genes that code for aryloxyalkanoate dioxy-
^ase provides resistance to certain auxin herbidde {69, 70). The
aad- 12 gene was isolated from Delftia acidovorans and codes for a
2-ketoglutarate-dependcnt dioxygenasc that inactivates phenoxy-
acetate auxins (e.g., 2,4-D) and pyridinyloxyacctate auxins (e.g.,
tridopyr and fluoroxypyr) {62). This trait, DHT2, is being develo-
ped in soybeans. A second gene known as aad-l was isolated
from Sphingomonas herbicideovarans and inactivates auxins and
ACCasc-inhibiting herbiddes in the class known as FOPs (e.g.,
fluazifop) (d2). This trait, DHTl , is being developed in corn. Both
traits are reported to provide resistaoce to high rates of 2,4-D with
no adverse agronomic effects.
The 2,4-D and dicamba resistance traits will always be used in
stacks with at least one other hcrbiddc-resistance trait (52, 7J).
The expected increased use of auxin herbiddes will increase the
potentiai for off-target movement and injury to sensitive broad-
leaf plants. Due to this potential environmental problem, the
herbidde and trait providers will likely introduce improved
herbidtte formulations with better use directions before the traits
are commercialized mid-decade {33 , 72). Ironically, this risk of
off-largct movement coiUd drive more rapid adoption of auxin
traits because growers will want to protect their soybean and cot-
ton crops from nearby applications of auxin herbiddes.
Resistance to HPPD Inhibitors. In some ways, HPPD-
i ^ib^ng herbiddes are ideal to comp^qit giyph<»ate. Many
flPPD herbiddes have soil residual acUvlty and control key
broadleaf weeds that have already evolved resistance to glypho-
sate. Increased resistance mechanisms for HPPD herbiddes inclu-
de a less sensitive target site, overexpreraion of the emeyme, alter-
nate pathway, increasing flux in the pathway, and metabolic
inactivation {38, 48). Crops resistant to HPPD herbiddes have
been in field development tests since 1999, but there have been no
technical disclosure of HPPD reistance traits under develop-
ments thus far. Bayw CropSdence in collaboration with Mertec
LLC (Adel, TA) and M.S. Technologies LLC (West Point, lA)
and Syngenta (Basel, Switzerknd) have indepaidently announ-
ced plans to develop HPPD-resistant crops. Bayer CropSdence
recently disclosed that they were developing soybeans resistant to
three herbidde types: glyphtwate, glufosinate, and HPPD her-
biddes (e.g., isoxaflutolc) {17). Isoxafiutole can provide pre-
emwgence (PRE) and postemergence (POST) control of a relatively
701
H J. Agric. Food Chem., Vd. XXX, No. XX, XXXX
broad spectrum of annual weeds with soil rwidual activity. The
“triple stack” offers the advaata^ of enabling the use of
herbicide MOAs to which weeds have not yet evolved resistance.
Resistance to Other Herbicide Types. Resistance to other
herbidtk types could also have significant utility. For example,
trans^c crops resistant to PPO-inhibiting herbiddes have b^n
(kveloped, and the technology even received the trade name
Acuron (¥7). The first PPO-resistant corn usai a double-mutant
PPO, PPO*!, from A. ihaliana. Similarly, PPO-resistant rice used
overexpression of the naturally rKistant Bacillus subtUis PPO
gene to confer resistance. Other appro^hes including increasing
gene copy number and tissue culture to select for overexpression
of wUd type PPO geoK have also be^ successful (41). The broad-
spectrum weed control and soil residual activity of PPO hcrd-
cides could be useful in com, soybeans, and cotton, bm the
existing wide^read resistance to this class among some Amar-
anthus spedes limits the value of the technolc^y.
A transonic DHTl trait also gives resistance to ACCase-
inhibiting herbiddes by degrading the aikanoate side drains to a
hydroxyl of the FOP class of ACCase herbidd^ (e.g., quixalo-
fop) (di). DHTl com reportedly tolerates postemcrgcnce aK>li-
cations of qidzalofop of up to 184 g/ha with no adverse agro-
nomic effecte. This trait has utility in com where commerdal
ACCase herbiddes are not naturally selective. In addition, the
spedficity of its inactivation could allow the use of other ACCase
herbiddte types for HR volunteer com management in rotational
crops.
Most hcrbidde traits only give resistance to herbiddes vrith orre
MO A. Metdjolic inactivation systems based on cytochrome P450
monooxygenases (P450) and ^utathionc transferase (GST) have
the potentid to inactivate a wide range of herbidde types
(Table 7). Fot example, native P450 enxymes can metabolicdly
inactivate acetanilid^, bentazon, dicamba, some ALS-inhibiting
herl^ddes, isoxazoles, and urea herbiddes (dd, 73). The chemical
spedfidty of this metabolic system may offer the unique potential
to allow growers to use herbiddes in the same MOA to control
weeds in one season and sbll manage any feral volunteers with a
herbidde in the same MOA in the next year.
Mult^le HR Crops. No single herbidde resistance trait will
be sustainable if the grower uses only the single herbidde type
that the trait enables recurrently. The weed problems and their
technology resolution must evolve together. Multiple HR
aoi» will help by allowing the use of new herbidde mixtures
with multiple modoi of action, but agriculture must manage
this technobgy objectively and pragmatically, balandng short-
term and long-term interests, so as not to create a "transgenic
treadmill” (75).
The la:k of soil readual activity has encouraged multiple in-
crop applications glyphosate, as many as four or more applica-
tions per growing season. Some of the new, multiple HR crop tec-
hnobgtes will enable herbidde applications with soil residual
activity and thus help growers to r^uce selection pressure on the
weed community by glyphosate(74). For example, the glyphosate
and ALS trait stack that has recently been deregulated in the
United States can allow the use of ALS-inhibiting herbiddes with
soil residual that are too phytotoxic to use on conventional crop
cultivars ^5). This stack consists of a metabolic system to
inactivate glyphosate based on an enhanced glyphosate acetyl-
ttansferare enzyme from the soil bacterium BaciUus licheniformis
(W dgmann) Chester (76) and a highly resistant ALS allele (HRA)
with two mutations, tryp5741eu and prol97aia {75).
A wide array of other combinations of current and new
herbidde itsistance traits is expected within the itext decade, If
iwed correctly, these multiple HR crops will provide new uses
for existing herbiddes to help growers better mana^ weeds and
Gi^n and Owen
hdp sustain the utility of glyphosate and glyphosate resistance
traits.
PATH FORWARD
Weed management dramaticaBy changed with the widespread
adoption of GR croi». Using glyphosate in GR crops ma^ weed
management too simple and convenient. Importantly, the high
initial efficacy of glyphosate declined with rq>eated use, and
current glyphosate-bascd weed management systems are in jeo-
pardy as evidenced by the speed at which weed populations are
evolving resistance. S till, glyphosate has not lost all utility; it
controls more weeds more effectively than other herbiddes, but it
C M no lon g er be applied alone anytime on any we ed anywhere.
hJe^t growers soil do not haw any GR weeds m their fields and
have time to implement proactive HR vreed management prac-
tices to help sustain glyphosate. However, ^\wrs need to act
now to diversify the herbteides and tactics tl^y use, the croi» they
plant, their cultural practices, and field hygiene measures. The
flexibility and range of alternative we^ management practices
will be narrow and require integration to replace glyphc^te.
■niese management practices will work better for the prevention
rather than the control of GR weeds. On(X present, GR weeds can
be managed but are difficult if not impossible to eradicate.
Growers need new weed management options now. Current
com, soybean, and cotton cropping systems are based on a heavy
reliance on glyphosate. Given the conges in weed populations
that are being reported, it is of paramount importance that other
weed management alternatives be identified and implemented
quickly (25, 77). It is likely that no new herbicide or trait tech-
nology will match the impact of glyphosate and the first GR crops
on agriculture. Growers will use these new technologies in
combinations to fill in efficacy gaps and diversify manage-
ment practices. Initially, it may look like an attempt to make
glyphosate look "as good as it used to be”. Srane traits such as
glufosinate resistance will enable a broad-spectium alternative
to glyphosate. Others will enable options with soil residual
activity or new MOAs to control key GR weeds. Some HR
crop technologies may benefit from incremental improvements
in efficacy and properties of herbiddes within long-standing
herbidde MOAs that companies are still commerdaliring
(.37,42).
jLhwr weed manage ment Practices
now (75). Th e more growers diversify, the less the risk that weeds
will evolve herbidde resistance. Diversification may make vreed
management more complex, but growers must not use new HR
crop systems in the same way that some used initial GR crops, as a
means to rely only on oite herbidde until it is no lon^r effective
and then switch herbiddes. If growers use the new HR crops and
the herbiddes that they enable properly, HR crops will expand
tlw utility of currently available herbiddbs and provide long-term
solutions to manage GR weeds.
HR crops will not replace the need for technical innovations,
particularly the discovery of herbiddes with new MOAs. Di-
versification will be much easier if growers can chose from
among multiple effective and economical weed management
options. In areas of the world that have not yet adopted GR
crops, growers can learn from the experience in North and
South America. Growers must not wait, but implement best
management practices as soon as new trait and herbidde
tedmologie arc available. B^ jjsing gverse weed manage ment
practices, growers wiB pre s erve tfaeu^ty oi herbiacie re^tane
traitrM'(if b<^icKie lecnnoiogtes and help maintain profitable
and enyironmentaily ^tamable crop production systems for
future ~
702
Article
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704
, press
PllMllJiW'WW--' ^ .. ^
Weed Science Society of America
Modelling the Effectiveness of Herbicide Rotations and Mixtures as Strategies to Delay or
Preclude Resistance
Author(s): Jonathan Gressel and Lee A. Segel
Source: Weed Technology, Voi. 4, No. 1 (Jan. - Mar., 1990), pp. 186"198
Published by: Weed Science Society of America and Alien Press
Stable URL: http://www.jstor.org/stable/!^986868
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705
Modelling the Effectiveness of Herbicide Rotations and Mixtures
as Strategies to Delay or Preclude Resistance*
JONATHAN GRESSEL and LEE A. SEGEL^
Abstract Herbicide-resistant populations have evolved only in monoculture and/or monoherbicide
conditions at predictable rates for each compound and weed. No populations of iriazine-resisiant
weeds have speared in com where rotations of crops and herbicides or herbicide mixtures were
used. This is due to tiie greatly reduced competitive fimess of the resistant individuals, which could
be expressed only during rotational cycles, and also to the greater sensitivity of resistant individuals
to other herbicides, pests, and control practices (“negative cross-resistance”). The model presented
here describes how an understanding of all of these factors can provide strategies to decrease the
frequency of the resistant individuals during rotation. Rotations or mixtures may not delay the rate
of appearance of resistance to inhibitors of acetolactate synthase (ALS), where the fitness of
resistant biotyp^ is claimed to be ne^ normal. The best way to delay resistance to ALS inhibitors
is to use those compounds with less persistence so that the selection pressure will be lowered. Too
little is known about the frequency of resistance to other herbicides with target-site resistance-to
dinitroanilines, to acetyl CoA carboxylase inhibitors, or to those situations where a single enzyme
system confer resistance to a broad spectrum of seemingly unrelated herbicictes. Nomenclature:
Com, Zea mays L.
Additional index words: Herbicide resistance, fitness, selection pressure, seedbank dynamics,
tiiazine resistance, metabolic cross resistance.
INTRODUCTION
Weeds are evolving i^istance to different herbicides
at different rares. Resistance can be avoided by under-
standing and analyzing the interacting factors involved
in changing a sensitive weed population into a resistant
one. These factors, described below, are inserted into
models so that the quantitative importance of each
factor can be evaluated. The model predictions favor-
ably compare with the case histories of resistance.
Newer models are described so that the effectiveness of
different weed control strategies can be predicted better.
Weeds in North America have evolv^ resistant pop-
ulations to herlMcides only where there was monocul-
ture with a single family of herbicides. The only Qxcep-
tions until recently have been where different
herbicides having the same site of action were used
(e.g., a rotation of photosystem-il inhibiting herbicides)
(17). Resistant-weed populations have evolved in wheat
{Triticum aestivum L.) monoculture in England and
Australia, wh^ high selection pressure herbicides with
different sites of tuition but the same putative mode of
^Received ftar pobticiRkm July 24. 1989, siid in revised form Dec. 15. 1989.
^Profe., Oep. risa Gcaet. and A|^. Mash., respectively. The Wetzmaan
Inst Sci., Rehovot IL-76100. Israel.
degradation are rotated (17, 19, 37, 41). Such metabolic
cross resistances likely will evolve elsewhere.
The appearance of resistance in monoculture and/or
mono-herbicide usage was described by a simple popu-
lation model (22, 23) that integrated the following: a)
the selection-pressure of the herbicide (based on the
rate used, its effectivity with particular weeds, and its
persistence); b) the germination dynamics of the weeds
(over the season and from the soil seedbank); c) the
initial frequency of resistant individuals deriving from
natural mutations in the susceptible population; d) the
fimess of the evolved resistant biotypes in competition
with the wild type under field conditions; and e) the
number of generations (seasons) the herbicide was
used. This model helps to understand why resistance
evolved in monoculture to the high selection pressure s-
triazines in com but not to herbicides exerting lower
selection pressure, such as the ihiocarbamates, chloro-
acetamides, and phenoxy herbicides, in similar weeds
growing in this crop (22, 23).
It is consistent with the model that populations of
weeds did not evolve that resist 2,4-D [(2,4-dichloro-
phenoxy)acetic acid] and MCPA [(4-chioro-2-methyl-
phenoxy)acetic acid] in wheat. The model predicts the
inevitably rapid ^pearance of weed biotypes resistant
to the high residu^ activity sulfonylureas, as well as to
chlorotoiuron [Ar-(3-chloro-4-methyiphcnyi)-A'iV-di-
186
Weed Technology. 1990. Volume 4:186-198
706
WEED TECHNOLOGY
methylurea], diclofop-methyl (methyl ester of (+)-
2'[4-{2,4-dichlorophenoxy)phenoxyl]propaiioic acid},
and mecoprop [(±)-2-(4-chioro-2-methylphenoxy)prop-
anoic acid)} in weeds of wheat.
Resistant biotypes evolved first in those weeds where
the herbicides exert the highest selection pressure. For
example, diclofop exerts a higher selection pressure on
ryegrass {Lolium sj^.) species than on wild oat {Avena
spp.) species. In agronomic terms, this herbicide is
more effective on ryegrasses, and ryegrasses indeed
have evolved resistance with greater rapidity (41).
Because of a lack of field ecology data, our early
model in^curately predicted evolution of resistance
where herbicide mixtures and rotations were used. Vast
areas of com have received herbicide rotations includ-
ing j-triazines for 30 yr, and resistant populations have
not appeared. Our early model did not adequately con-
sider the then unknown effects of the extreme lack of
fitness in many resistant biotyp« in the seasons that
triazines were not used. The previous model (22, 23)
correctly predicted th^ mixtures could delay considera-
bly the evolution of resistance, but the lack of field data
on selection pressure of mixtures left it to the reader to
insert the correct parameters into the equations and the
^companying figures.
A new model (24) considers what happens during the
“off” years when a given herbicide is not used and
predicts that some high selection pressure herbicides
can be used sparingly in rotadon, possibly even after
resistance has appeared. The data show the urgent need
for further research concerning the physiological ecol-
ogy of resistant weed populations.
MODELS
The original monocuinire model described different
possible rat^ of enrichment of resistant individuals in
populations, until the populations were predominantly
resistant (22, 23). Diff^ent constant proportions of
susceptible and resistant plants germinated and survived
to the end of the season, and susceptible and resistant
individuals had (different) constant seed yields. Resis-
tant individuals initially formed an exceedingly small
fraction of the population, certainly a well-warranted
^Letters foilowii^ the ^mboi # are a WSS A-^iprovcd Cffinputer code from
CcKnpositc List of Weeds, Revised 19^. Avaii^le from WSSA, 309 W. Clark
Sl, Chainpmg^. E. 618^.
assumption during tiie years of resistance enrichment,
until there were sufficient numbers of individuals for
resistance to be evident.
V^ous factore involved in evolution were found
(after certain simplifications) to satisfy a simple alge-
braic equation giving our early model (22, 23). Solving
this equation gives the ^quency of resistant individu-
als after n years of treatment.
The factors included in the original monoculture
moDoherbicide model equation are the following:
is the very low frequency of resistant individu-
als in the population before it is exposed to the herbi-
cide. Resistance is sustained in the population in the
absence of herbicide by a balance between new muta-
tions to resistance and depletion of a proportion of
r^isiant individuals by their lesser fitness in the ab-
sence of selection. This results in a resistance fraction
somewhat lower than the mutation frequency. Mutants
conferring more fitness than the wild type become the
wild type. Mutant fitness can be near neutrality, and the
mutants would be found in different proportions at
various geogr^hicai areas due to genetic “drift.”
is the proportion of resistance in the population after n
seasons of treatments.
/, the competitive reproductive fitness, measures the
compounded relative robustness of resistants in compe-
tition with susceptibles during germination, establish-
ment, growth, pollination, seed production, and surviv-
al. By definition, fitness always is measured with resis-
tant and susceptible plants in competition with each
other in the absence of herbicide. When they are grown
separately, the resistant individuals are often less “pro-
ductive,” but the competitive fitness differential is usu-
ally greater (Table 1)^.
a, the selection pressure, is the ratio of the fraction
of resistants that abound in the population after a herbi-
cide application during that season to the corresponding
fraction of susceptibles. TTius, early or late-germinating
susceptible individuals that produce seeds are consid-
ered in this “effective-kill”, in contrast with the initial
weed control usually measured by weed scientists. For
example, if the herbicide kills 90% of the susceptibles
and none of the resistants. then a = 10; if 99% of the
susceptibles arc controlled and none of the resistants,
then a = KX). The susceptible individuals would in-
Volume 4. Issue I (Jaouary-March), 1990
187
707
GRESSEL AND SEGEL: MODELUNO STOAlEGlES TO DELAY HERBICIDE RESISTANCE
Table I. Lower productivity and competitive fimcss of 5'-tri^iRe-rcH$tain
biesypes*.
Species^
Productivity
COTnpetitive
fitness (1:1)'
Reference
(Resstant
Susceptible)
SmooJh pigweed
0.90
0.18
1
Common groundsel
0.47
0.43
28
Common lambsquaners
0.75
0.08
52
Laicnowering goosefooj
1.00
1.78
52
Rapeseed
0.76
0.28
21
“lYoductivity is measured by growing resistant and susccpiibk Wotypes
separately; competitive fitness is measured by growing them in a mixture. In
both ca.scs. seed yield was mea.sured. where "seed" may include fruit or wdtolc
flower depending ai study cited.
^Smoodi pigweed (Amaranthas kybridus L. # AMACH); common ground-
sel {Senecio vulgaris L. # SENVU); common iambscpiarters (Chent^odium
album it CHEAL); lateflowering goosefocM IChenopodium strictum Roth. var.
glaucopkyllum (Aellcn) H. A. Wahl. # CHESGj; rapesecd {Brassica ruipus L.)
'Fitness of 1 :1 mixture.
elude those missed by sprays (in refuges) and “immi-
granis” due to seed and pollen influx.
The gene flow due to seeds and pollen usually is
minimal, in the range of meters per years when actually
measured (2, 30, 43). Immigration of resistant seed can
be a problem when there is strong selection pressure in
a field. One “pioneer” seed can form a large colony.
Immigrating susceptible seed will have little numerical
impact because of the larger reservoir of susceptible
seed already in the field during the first cycles of
selection for resistance.
n is the average number of years that a seed remains
viable in the seed bank.
The predicted rates of enrichment of resistance are
plotted from Equation [1] with different scenarios of
selection pressure, seedbank dynamics, fitness, and ini-
tial frequency in Figure 1. These various measures of
resistance change by a constant factor each year, giving
rise to an exponential increase in resistant individuals
(Figure 1). Estimated parameter values (that should
have come from experimentation) were inserted into the
equation to generate the scenarios. They were based on
a limited data base, mostly from corollary systems,
such as heavy metal tolerance. Research groups have
begun to accurately measure weed-herbicide interac-
tions for more precise estimates.
The frequency of resistance in the population starts
at a low value and increases by a constant factor each
year. In spite of the exponential increase, detecting
resistant individuals in a field will be hard until resis-
tance is at a level of 10 to 30% of the population.
0 15
Seasons : 2 on
Seosons : i on
Seasons ; ! on ; 2 off
Figure I Presumed elTects of herbicide rotations using die original model.
Overall average effect of scenarios with different seleciitai fffessures la = 10 =
90% effective kill (EK); a = 100 = 99% EK: a = 2.0 = 50% EK], seed bank
dynamics(n). the average seed duration in the soil. and/dilTercmia! fiincss. The
different scale.s give the different rotational scenarios from monohcrbicidc to
(MIC tfeauncni in three seasons. Calculated from equations in {22. 23). Modified
from (24).
Messages from the model, a) The importance of selec-
tion pressure. Selection pressure is the most influential
agronomic variable, with the largest effect on the evolu-
tion of resistance (Figure 1). For example, the atrazine
[6 -chloro -N* -(1 -methylethyl) -1,3.5 -tria2ine-2,4 -
diamine] and chlorsulfuron {2-chloro-jV-[l(4-methoxy-
6-melhy! -1,3,5 -iriazin -2 -yl)amino3carbonyl]benzene-
sulfonamide) levels required to kill different weeds
vary over more than an order of magnitude. The selec-
tion pressure of both herbicides is greatest on annual
broadleaf species requiring the lowest rates for weed
control. The selection pressure is least for those weeds
requiring the highest herbicide levels, i.e., usually the
grasses. At a given herbicide rate, both herbicides con-
trol broadleaf species better, i.e., selection pressure is
lower on grasses.
ITie first weeds to evolve atrazine-resisiant popula-
tions were common groundsel, pigweed species, and
lambsquarters species. The last to evolve resistance
were the grasses, as the model predicted. Various
broadleaf weeds already have evolved chlorsulfuron
resistance in the field, at the level of the target enzyme.
This occurred under repeated selection pressure of this
188
Volume 4. Issue i (January-March). 1990
708
Vk^ED TECHNCM-OGy
recently introduced and highly persistent herbicide. It
was also easy to select for resistance to this herbicide in
the laboratory (7, 26). If these two preferentially bro^-
leaf controlling herbicides were used in conjunction
with selective grass-controlling herbicides, their use
rates could be decreased and the selection pressure cm
broadleaf weeds lowered.
Single annual use of herbicides with the greatest
pereistence always will exert the highest selection pres-
sure (Figure 1). The triazines, dinitroanilines, and sulfo-
nylureas meet this criterion of persistence with season-
long control, and resistance has evolved to all these
groups (16). 2,4-D and other phenoxy herbicides and
ihiocarbamates have short biological persistence in the
soil, and resistance has not evolved to them. Resistance
i^ed not have evolved so r^dly. Thoe are less per-
sistent triazines than airazine (such as cyana-
zine) {2-[[4-chloro-6-(eihylanuno)-l,3,5-lriazin-2-
yl]amino|-2-methylpropane-nitriIel and far less persist-
ent sulfonylureas for wheat than chlorsulfuron and met-
sulfuron {2-[[[((4-methoxy-6-methy!-l,3,5-triazin-2-yI)-
aminojcarbonyljaminolsulfonyljbenzoic acid} (5). If
these less persistent analogs had been used, the selec-
tion pressure should have been lowered and the evolu-
tion of resistant populations delayed.
Paraquat {l,r-dimeihyl-4,4'-bipyridinium ion) resis-
tance has evolved and may seem to contradict the
theory’s emphasis on pereistence, as paraquat immedi-
ately loses biological activity upon reacting with soil
colloids. The lack of residual persistence was balanced
by farmer persistence. Paraquat resistance occurred
where this herbicide was used 5 to 10 times during each
season in monoherbicide usage.
b} Seedbank dynamics. The longer the life in the seed-
bank, the greater the buffering effect of susceptible seed
from previous yeare, decreasing the rate of evolution of
resistance. Common groundsel has evolved triazine re-
sistance in orchards, nurseries, and roadsides where
there was no mechanical cultivation but not in culti-
vated com fields. The groundsel seed is incorporated
into the soil seedbank in such com fields, where it is
viable for many years (54). All groundsel seed falling
on undisturbed soil on roadsides or orchards either
germinates or dies during the following season (42).
Resistance thus evolved where there was the lowest
average seed bank life time n as predicted. Such infor-
mation must be considered in formulating strategies for
resistance management. Many other species do not have
a seedbank under specific agronomic situations, i.e., in
minimum-till agriculture where n = /.
c) f, fitness of resistant individuals. The lack of fitness
of resistant individuals can have a strong dampening
effect on the evolution of resistance but only when it
can be expressed, i.e., when the herbicide is not present.
Thus, in monoherbicide culture, the lack of fitness can
have little influence with persistent herbicides but could
be effective with the less persistent herbicides. This is
another reason to avoid persistent compounds, espe-
cially in monoculture.
Resistance to herbicides with the same site of action.
The original model predicted that rotation or mixing of
herbicides wiUi the same site of action (and thus similar
mode of re.sistance) will have the same effect as using a
single herbicide. Tliis was expected on biochemical
grounds as well; plants resistant to atrazine had target-
site cross resistance to all triazines, some phenylureas,
uracils, etc., all at the same site in Pholosystem II. The
use of corn/soybean [Glycine max (L.)Merr.] or atra-
zine/metribuzin [4-ainin0'6-(l ,1 -dimethylethyl)-3'
{methylthio)-l,2.4-triazm'5-{4//)-one] or sulfonylurea/
imidazolinone rotations with various crops thus should
be contraindicated if the various herbicides are effective
on the same spectrum of weeds (17, 18, 23). For the
same reason, the genetic engineering of atrazine-resis-
lant soybean for use in monoherbicide culture would be
misdirected unless the atrazine usage in com were to be
replaced by other herbicides.
Cross resistances to herbicides due to degradation.
Metabolic cross resistances to insecticides and drugs
having vastly different modes of action are common
and are documented to the level of molecular biology
(16). Such cross resistances to herbicides with different
modes of action are a recent occurrence (17, 18, 27, 37.
41). Rigid ryegrass {Lolium rigidum L.), frequently
called annual ryegrass, that evolved resistance to diclo-
fop had cross resistance to chlorsulfuron as well as to
all other wheat-selective herbicides (27). Blackgrass
{Alopecurus myosuroides Huds. # ALOMY) that
evolved resistance to chlorotoluron was cross resistant
to chlorsulfuron, pendimethaiin [/^-(1-ethylpropyl)-
3,4-dimethyI-2,6-dinitrobenzenamine], and diclofop
(37).
Similar metabolic cross resistances to insecticides
and drugs often were traced to the evolution of higher
levels of nonspecific esterases, hydrolases, or monoox-
ygenases. The resistances in blackgrass and rigid rye-
grass can be abolished by adding specific monooxyge-
nase inhibitoR along with the herbicide (19, 20, 32.
41). Genetically engineering new modes of herbicide
Volume 4, Issue 1 (January-March). 1990
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709
CRJESSEL AND SEGEL: MODEUiNG SmtATSOIES TO DELAY HERBICIDE RESISTANCE
resistance into wheat also could alleviate the problem
(18, 19). SiK:h data, along with the knowledge that
wheat seems to have selective resistance to herbicides
by mono-oxidations, suggest that these weeds may have
evolved a biochemical mimicry, i.e., they have evolved
a system similar to wheat to degrade wheat-selective
herbicides <17, 18, 19).
MODELLING ROTATION
The model as shown in Figure 1 does not adequately
account for events in the “off years“ during rotations if
the competitive fitness of the resistant biotype is low.
Resistance is shown (Figure 1) to evolve at a fixed rate
as a function of the number of generations or seasons a
weed was treated with a particular herbicide. This
means that if it would take 6 yr for resistance to occur
in monoculture com with atrazine as the sole herbicide,
it either would take 9 yr in a com/com/wheat (or
soybean) rotation where atrazine is used for control 2 of
every 3 yn or 12 yr in a com/wheat (or soybean)
rotation whare atrazine is used every other year, or 18
yr in a com/wheat/soybean rotation where atrazine is
used once in 3 yr.
When the model was formulated a decade ago, tri-
azine resistance appeared in areas of the combelt where
such rotations were used, as there had been 6 to 10 yr
of atrazine us^e since it was introduced. Yet, resistant
populations only appeared in monoculture, monoher-
bicide com.
Mixtures. Few farmers in the center of the combelt
grow monoculture com, unlike areas to the east of the
combelt where triazine resistance appeared in com.
Combelt fanners use rotations and/or mixtures of tii-
azines with chloroacetamide herbicides, which allow
the use of less atrazine and thus lower the selection
pressure. The chloroacetamides also kill pigweeds (Am-
aranthus spp.) and lambsquarters {Chenopodium spp.)
as well as grass weeds. Mixtures substantially delay
resistance, both according to the model (22) and from
field data, although the magnitude of this effect is yet
unclear.
The reason for the efficacy of mixtures to delay
resistance can be manyfold. The frequency of resistance
is lowered to the compounded frequency for each com-
ponent. If the frequency of resistance to one component
is Iff"’ and die other 1(H, the conqxmnded frequency is
The lower rates of each component used de-
creases the selection pressure for each, adding to the
delay in resistance. Tbe fitoess to each component is
also compounded, which should give low fitness for the
individual resistant to both compounds in a mixture.
Simulations of this are illustrated in (22, 23). Certain
mixtures are not “mixtures” in the sense of delaying
resistance: those that act at die same site (e.g., two
photosystem II inhibitors) and those that are degraded
by the same enzyme system (e.g.. possibly all the
herbicides used in wheat that are degraded by monoox-
ygenases).
The models for mixtures are described in greater
detail, with figures showing scenarios, in (23). Herbi-
cide rotation may be die only strategy remaining to
delay the evolution of triazine resistance in com as the
chloroacetamide herbicides used in mixtures for com
are under attack for environmental reasons, and their
use is restricted in many areas and forbidden in others.
We have incorporated better data into an updated
model, to show how rotation has been a better strategy
than previously predicted. The newer data and model
emphasize the highly reduced fimesses of the resistant
biotypes, which are of greater magnitude and impor-
tance than had initially been expected.
Lack of fitness of resistant weeds - a major consider-
ation. The initial model used an average fitness differ-
ential for all generations treated (Figure 1). The fitness
differential between resistant and susceptible individu-
als essentially never can become apparent with herbi-
cides such as triazines that give season-long control, as
there is no time when the herbicide is not present for
this differential to be expressed. Only the resistant
biotyjjes can survive when the herbicide is present.
Thus, the fimess differential is unimportant with tri-
azines in monoherbicide culture but seems to be an
important factor in delaying resistance to other herbi-
cides with more ephemeral action.
The fitness differential is important when herbicide
usage is stopped for a season or more. Resistant bio-
types are often more susceptible to some of the herbi-
cides and cultivation procedures used in the rotational
years (negative cross resistance). We have modified the
model to consider what happens to resistant individuals
in the “off’ years when the herbicide in question is not
used (24).
The resistant individuals, initially present at very low
frequencies in the field, must compete with the crop
and with resistant members of other weed species.
When the herbicide is not present, they must compete
with susceptible members of the same and other species
190
Volume 4. Issue 1 (Janujay-March), 1990
710
WEED raC»«aDGY
that genninate throughout the year. During the evolu-
tion of resistant populations, only intraspecific competi-
tion has been considered, except for one study (53).
More data are needed from the ^o-ecologists on the
important of interspecific competition, including that
with crops and weeds.
The first studies on competitive fitness were per-
formed by pregemunating s^dlings of resistant and
susceptible individuals, interplanting them at fixed dis-
tances, and allowing them to grow to maturity (9). The
yields of the resistant and susceptible biotypes were
measured. In almost all cases where this was done, the
susceptible individuals outyielded the resistant ones
(Table 1).
Most competition expCTiments have not been made
with material that has nuclear isogenicity where resis-
tant and susceptible alleles are in otherwise identical
nuclear backgrounds. Nuclear isogenicity is easy to
achieve by using reciprocal hybrids when dealing with
cytopiasmically inherited triazine resistance. An other-
wise identical plastome in such crosses cannot be guar-
anteed. Tliis eventually may change when plastomes arc
engineered by site-directed mutagenesis. Repeatedly
backcrossed material also provides near-nuclear isogen-
icity with a large differential in competitive fimess (21)
(Table 1). 'Hiere seems to be no fitness difference
between resistant and susceptible individuals of late-
flowering goosefool (53). Laieflowering goosefoot is a
slow-growing species, and photosynthetic electron
transport probably does not limit its growth.
A few triazinc-resistant grasses have been reported to
be more productive and competitively fit than the wild
type (56). but this must be checked under more rigorous
conditions. In general, one must be wary of reports of
evolved fitnesses th^ are better than the wild type.
Considering the long periods that species have evolved,
the wild type in any given location should have evolved
to optimal fitness. Spurious reports of high fitness may
result form various interrelated functions: a) fimess was
not measured from gemination on; b) density depend-
ent functions were not considered; c) reactions to envi-
ronmental conditions may have differed; d) germination
char^tesrs and seed bank dormancies may have dif-
fered; and e) fitness was not measured under field
conditions.
Some mutations to resistance may engender larger
losses of fimess than others. Triazine resistance may
lead to an extreme case of fitness loss that could be due
to many other linked mutations in the chloroplast ge-
nmne. Triazine resistance may evolve in populations
containing a plastome-mutator gene (3). This could
explain some of the unfitness of triazine-resistant plants
as well as the variabilities of plastid fitness. Any plant
with triazine-resistant plastids should have other muta-
tions in its plastids. Deleterious nuclear mutations can
be bred or selected out of populations because of chro-
mosomal segregation along with somatic and meiotic
recombination (crossing over). This is not as e^y with
chloroplasts, where recombinations are negligible.
TTius, the unfimess in atrazine-resistant plants may not
be due to the psbA gene mutation, as has been argued
on biophysical grounds (31, 34, 47, 49).
Target site mutations or gene amplifications in en-
zymes present in low quantities may not exert such
strong effects on resistance as was found with triazine
resistance. Fimess measurements must be performed
carefully with resistant weeds as soon as resistant popu-
lations appear.
The measurement of fitn^. As we consider fitness a
major factor in delaying resistance, the measurement of
fitness is described in detail below.
a) Measurement from germination. Weeds produce hun-
dreds to thousands of seeds to replace one plant. Most
perish before maturity, many during overwintering,
early germination, and establishment. Tlie competition
before establishment is probably the fiercest. Competi-
tive fimess smdies should be measured at this stage, but
this usually has not been done. The simplest way to do
this is to plant mixtures of resistant and susceptible
seed and to ascertain which plants are resistant and
susceptible by a nondestructive test or by using leaf
pieces. The seeding should be done at various depths
and densities and preferably under field conditions to
best mimic the natural environment As seeds from
resistant plants are often smaller than those from sensi-
tive plants, there surely should be a definite competitive
disadvantage to resistance when the selecting herbicide
is not present
b) Density dependence of fitness. Density dependence
of fitness has not been measured adequately. For exam-
ple. it is not clear why annual bluegrass {Poa annua L.
# POAAN) biotypes resistant to triazines evolved only
in genotypes that were prostrate and not in those that
are erect (10). The lack of competition in triazine-
treaicd fields possibly allowed the prostrate types to
Spread. There are variations in the density dependence
of diclofbp-resistanl rigid ryegrass (27). The resistant
plants were more fit than the sensitive ones under
Volume 4, Issue 1 (January-Man^), 1990
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711
GRESSEL AND SK5EL: MODELUNG SIHATEGIS TO DELAY HERBICIDE RESISTANCE
sparse than under dense spacing. The fitness also varies
at different ratios of resistant to suscqptible individuals
in competition. Only the data from a 1:1 mixture aie
given in Table 1. The originai data show that the
resistant biotyp^ are even less fit than the 1:1 mixbire
when they are in a lower proportion in the populations.
The data suggest th^ fitness should be measured at
various densities and ratios of sensitive to resistant
individuals, especially those that more closely £^proxi-
mate the initial low hequenci^ of resistant individuals
in the field.
c) Environment and fitness, A lower€^ optimal temper-
ature for growth and photosynthesis for resistant bio-
types is one of the common (12) but not universal (51)
pleiotropic effects found with triazine resistance. Inter-
pretation of these findings can be complicated. The
earlier germination and ‘*he£ui start’* can be highly ad-
vantageous uniter many ^eenhouse conditions; but in
the field, it can be devastating. A late frost will decim-
ate the earli^ germinating resistant population and
leave the later germinating susceptible population. This
demonstrates why fimess must be measur^ under field
conditions to indicate what happens in the field.
d) Changing seedbank dynamics. Repeated and strong
selection for resistent weeds under monoculture easily
can abolish the “spaced out” germination typical of
weeds during the season and over many seasons. This
higher immediate germination of resistant individuals
versus the susceptible in many fitness tests (e.g., 36)
may give real but misleading results that do not approx-
imate fitness properties under tield conditions.
e) Narrow genetic base. Isozyme electrophoresis stud-
ies of resistant populations always have shown that
resistant biotypes at least initially possess a much nar-
rower genetic base than adjacent susceptible popula-
tions (10, 11, 14, 53). This is due to the “founder
effect” of mutants in diveree populations measured
soon after evolution. In genetic evolutionary terms, this
suggests that under certain narrow conditions the resis-
tant populations may be more fit than the wild type; but
under broad and varying environmental conditions they
will be less fit.
In many cases, this might mean that the fimess will
increase slowly due to “nuclear compensation” from
^ouza-Macbado, V. 1987. ctxnmumcaiion. Univ. Guel{^
Gu^h. Ont, CjBMd*.
%itter. R. 1988. Personal coEomunicatirai. Univ. hm.. College Paric, MD.
repeated crossing with the wild type susceptible popula-
tion. The fimdamental biochemical lesion caused by
triazine resistance prob^ly will prevent fimess from
impDving in that case. One can increase the yield of
triazine-resistant species by intercrossing. Still the re-
ciprocal intercrosses with the sensitive biotype as fe-
male parent always outyielded the resistant offspring in
such crosses (4). The effect of interbreeding on increas-
ing fimess will have to be checked with other types of
herbicide resistance.
The importance of negative cross resistance. Resis-
tant pests often are controlled more effectively than the
wild type by a variety of agents. This phenomenon,
known as “negative cross resistance,” has been reported
with antibiotic-resistant bacteria in medicine and in
ftingicide-resistant pathogens and insecticide-resistant
arthropods (16).
Similar data can be found for weeds (Table 2), which
indicates that the phenomenon should be explored as a
pan of resistance management procedures. Triazine-
resistant individuals were often less fit under the agro-
nomic procedures used during the “off’ years when
triazincs were not used and procedures with negative
cross resistance were used. We have no accurate counts
of the decay of resistance in populations when triazine
usage was stopped due to high resistance levels.
Negative cross resistance has been found with many
weed control and biological factors:
a) Standard mechanical cultivations of mixed resis-
tant and sensitive common groundsel populations re-
diteed the resistant individuals more than the suscepti-
ble ones (54).
b) The differential lack of fimess often can be due to
other biotic factors. It was found that triazine-resistant
rutabagas {Brassica napobrassica L.), which nominally
produced yields as high as the near iso-nuclear suscep-
tible biotype, were totally and selectively decimated by
a viral infection^. Triazine-resistant smooth pigweed
was selectively eaten by beetle larvae, and triazine-
resistant common lambsquarters was more susceptible
to fungal disease than the wild types^.
c) Many herbicides are more toxic to resistant indi-
viduals than to susceptible ones (Table 2). Table 2 only
contains data for negative cross resistances, but these
are not the preponderant cases and are not uruversal.
Still, they can be elucidated and incorporated into strat-
egies for managing resistant weeds, both before and
after populations become preponderantly resistant.
The negative cross resistances in atrazine-resistani
weeds include herbicides that act at or near the same
192
Volume 4, Issue I (January-March). 1990
712
WEED TECHNCHXXJY
Table!. Neg^ive cross resisumce of herbicide-resistant biotypes.
Primarv resistance
Species*
Negative
cross
resistance^
Pamneter
measured*^
150*^
Rys
Ref.
Triazines
Rcufroot pigweed
Dinoseb
FW
0.27
13
Fluomcturon
Hiylakoids
0.22
39
DNOC
Thylakoids
0.5
39
Cannm lambsquarters
Dinoseb
FW
0.27
13
Rapeseed
Dinoseb
FW
0.66
13
Cemunon grmmdsel
Dinoseb
FW
0.21
13
Horseweed
DNOC
Thylakoids
0.1
33
Kochia
2,4-D
FW
d
44
Amerk:an willowberb
Oxyfluorfen
FW
d
8
Paraquat
FW
d
8
Pyriduc
FW
d
8
(^or(m^ham
FW
0.46
6
Diaitroaniluies
Goosegrass
OdonH^ani
d
50
Mecoprt^
Commoi chickweed
Benazolin
FW
0Ji3
35
MSMA-DSMA
Ctmuncm cocklebur
Paraquat
FW
0.50
25
Bentazem
FW
0.65
25
OdOTSiUiiron
Jimsonweed
Imazaquin
FW
0.03
45
Pafaquu
Horseweed
*Glufosinate
PS
0.26
40
^Species not defined previously: hwseweed [Conyta canadensis (L.)CiDiiq.
# ERiCA]; kochia [Kochia scoparia (L.)Schrad. # KCHSC}: american wii-
iowherb (^pllobium ciUatum Raiia » E. adenocauhn Hausskn # EPIAC);
goosegrass [Eleusint indica (L.)GaotB. # QJEIN]: comoion chickweed ISiel-
laria media (L.)VilL # STEMS]; conunoD cocklebur {Xanthium sirumarium L.
# XANST); jimscaweed (Datura irmoxia MiJI. # DATIN).
**Chemtcals sot defined previously: diooseb [2-<!-me(hyipr«^l)-4.6-dini-
trophoid}: fluom^uron {A/,Af-dinie^l-A'*(3-(trifIu(tftuneihyl)pheayl)urea];
DNOC (4,6-duiiln>'0-cTe3ol); oxynuorfea [2<hioro- 1 •{3<tboxy-4'nitrt^4teii-
oxy)-4-(trifliHmMnethyl)beBzene]; pyridate {0-(6<hloro*3-phenyl-4-pyridaz-
iiiyl)-5-ci^yl carbcniothioaie); chlorjMOfAam (l-a]ethyIedtyl-3-chloro(dKayl-
caitamate); benazolin (A-ctilOfo-2-oxo-3(2//>benzodiiazole-ace(ic acid);
benuzoa (3-<l-metbyleihy])-(l/0-<2.l,3-be£izothiadiazio-4-(3/f'One 2^-iUox-
idej; imazaquin {2*(43-d&ydro4>metbyl-4-(l-methylethyl)'5-oxo-l//-i{nida*
zol-2-yl]-3-quioo!ii)ecarboxylic acid}; glufosiaate (ammonium (3-amiit(v3-
carboxypropyDmobyipbosphioate}; MSMA (monosodium salt of methylar-
sonic Kid); DMSA (d^odium salt of tneihySarsotuc Kid).
*^FW s fresh weight: PS s photosynthetic CO2 fixation; thylakoids »
photosystem II aciivfry of isolated thylakoids.
‘hlie 150 is (he coocencraiion lowering the parameter measured by 50%; R s
resisiani; S « susceptible. Where no [30 R/S ratio is given, there was a large
degree of negative cross resistance at a single berbteity rate.
site in photosystem II (DNOC and dinoseb) as well as
herbicides acting on other photosystems (paraquat) or at
totally different sites. There was negative cross resis-
tance to other tubulin-binding heiticides in dinitroanii-
ine-resisiant goosegrass (Table 2) but not to six com-
^pecki, J. l^S. Personal communicaiion. Adadenaii Rotoiczej W. Lub-
linie, SL-Leszczy^ltie^ 7, LuUin, Pdand.
mercial herbicides on this weed (38). The negative
cross resistance to imaz^uin (Table 2) occurred in only
one of 21 chlorsulfiiron-resistani mutants. The other
mutants had varying levels of co-resistance to imaza-
quin.
Resistant biotypes sometimes grow better in the pres-
ence of the herbicide than without the herbicide. For
instance, Lipecki^ found that a triazine-resisiant biotype
of smooth pigweed grown with 5 kg ha*^ simazine (6-
chioro-A^,y-dielhyI-l,3,5-tria2ine-2,4-diamme) had
double the dry weight per plant than without the herbi-
cifte. This lower resistant-biotype productivity when the
herbicide is not present results in a stronger lack of
compeniive fitness in die “off’ years.
MODIFIED MODEL FOR ROTATIONS
The long-term effect of rotational strategies is easier
to calculate by deriving new equations that better con-
sider the rotational perturbations. We have modified
Equation [1] to give a new basic equation
= [X + 6iafan- HP [1 - 6(1 - foff)r [2]
where:
H is the overall enrichment factor giving the increase
in resistance following a period of p “on" seasons of
herbicide application and q “off’ seasons without herbi-
cide;
6, the fraction of seeds leaving the seedbank each
year, replaces n, the average residence time as the
factor describing seed bank characters.
The derivation of Equation [2] and the simplifica-
tions, approximations, and assumptions involved are
detailed elsewhere (24). Equation [2] can be rearranged
to solve for various parameters to predict the effects of
different agricultural scenarios. The p “on" years and
the q “off’ years can occur In any order during the p +
q year period that is under study.
There is little added effect of a small “off" fitness
0-3), as there is a significant loss of resistant
seeds during the off years due to the decimation of
these seeds in the seedbank by natural causes (rotting,
insects, etc.). This loss wiU not be replaced by the small
addition that emanates from less fit resistant seeds.
Note that the “off” factor is simply foff in the absence of
a seedbank (6 = 1), as the only factor affecting seed
number will be seed deposition, however small. If 6 -
1, then a strong influence of fog can be expected.
Volume 4, Issue 1 (January-Mardi), 1990
193
713
GRESSEL AND SEGEL; MODELUNG STRATEGIES TO DELAY HERBICIDE RESISTANCE
V^ous applications of this newer model are plotted
in Figures 2 to 5, showing examples of how this model
can be used U> predict what mi^t happen in real field
situations, when different herbicide treatments are used
in various rotations.
The effects of various rotations on the rate of evolu-
tion of resistance are plotted using Equation [2] to show
the effects of fitness during the season when the herbi-
cide was used and a different (constant) fitness for
seasons when not used (Figure 2). There is hardly any
real ^ded delay due to ratation on resistance when the
resistant individuals have near-normal fimess (Figures 2
D to F). Actually, Figure 1 and Figures 2 D to F do not
differ agronomically if the lines in Figure 2 are
smoothed. This high fitness may be the situation with
the weeds having resistance at the level of acetolactate
synthase (based on productivity, not competition exper-
iments). Thus, in such cases, with high fimess, the
model states that rotation is of little assistance in truly
delaying resistance. The only delay will be for the
number of generations the particular herbicide is not
used. In such cases, only lowering the selection pres-
sure will delay resistance. Obviously, the model must
be validated by agro-ecological experimentation.
When there is a large fimess differential between
resistant and susceptible individuals (as with triazine-
resistant weeds), there will be a delaying effect due to
fimess (Figures 2 A to C), and the effect is greatest
when selection pressure is lowest. The plots describe
the reduction of the proportion of resistant individuals
in the off years. There are even some situations at low
selection pressure where resistant individuals disappear
in “off’ years more rapidly than they are enriched for in
“on” years. Thus, rotation can be advantageous. When
there is negative cross resistance, the fitness differential
is even greater, and the results can be considered by
using the effects of a lower fimess value / for this
period.
Scenarios with a slow rate of overall enrichment,
showing that it will take many years for resistant popu-
lations to become a major problem, are summarized in
Table 3. The (log) factor of enrichments at the end of
9- and 15-yr periods are given. When this factor is
compared wife the initial frequency of resistance (N<,),
it can be estimated whether resistant populations should
have evolved. If No is lO-^o (a guess for fee Nf, of
triazine resistance), fimess is 0.3 or less, and selection
pressure is low, i.e., the effective kill is less than 95%,
then we see that resistant populations will not evolve
Herbicide Rotation
2 on :1 off ton: toff Ion; 2 off
Yeor (Generotion) ^ on.cu off
Figure 2. The effect of herbicide rotation on the rate of resistance enrichment.
Tltfee rotational scenarios are shown for herbicides with different selecticm
pressures expressed as effective kill. “On" refers to the year the herijicidc in
queaim is used and “off" dtc year it is not used. The two fitnesses are those
thought to represent triazine resistance (Table 1) (A to C; f « 0.3) and those
thought to represent sulfonylurea/ ALS resistance (7) (D to F;/s 0.9). The/a„ »
). The weed seeds in the seedbank are presumed to have a 2'>yr resi^nce tune.
Calculated from equations in (24).
under any of feese scenarios. Triazine resistance would
only appear in 15 yr in monoherbicide culture where
the effective kill is 99% (Log H = 22.3, which makes
up for the resistance frequency of 10-^9).
With chlorsulfuron. N,, should be 1(H to l(k* (7, 26,
45, 48) versus the estimates of 10-^9 for triazine resis-
tance. This high initial frequency explains why chlor-
sulfuron resistance evolved so rapidly. It is not clear
that one need actually consider whether mutations to
resistance are dominant or recessive; there may be only
a small frequency difference between the two types in
diploid organisms (55). This is because recombination
(crossing over) can increase homozygous recessive fre-
quencies in populations considerably. The selection
pressure of 2,4-D is so low that no resistant populations
occurred in 35 yr of monoculture wheat (29) as would
be expected from Table 3.
The important predictive uses of this model are two-
fold:
194
Volume 4, Isaic 1 (January-March), 1990
714
WEED TECHNCaXXJY
Table 3. (L<^) Enrichmau of resisam individuals in v«cd populaticms over 9- ^ IS-yr periods under differem herbicide roations*.
Rotation
araiegy
Effective
kill*’
9-yr period
15-yr period
Fitness in
"ofl” years
Fitness ii
a “off’ years
a9
03
0.3
0.9
03
0.3
No
50
1.0
IX)
1.0
1.7
1.7
1.7
rot^<Hi
90
5.1
5.1
5.1
8.5
8.5
8.5
95
7.4
7.4
7.4
12.4
12.4
12.4
99
13.4
13.4
13.4
22.3
22.3
22.3
2 on;
50
0.6
03
0.4
1.1
0.8
0.6
I off
90
3.4
32
3.1
5.6
5.3
5.2
95
4.9
4.7
4.6
8.2
7.9
7.8
99
8.9
8.7
8.6
14.3
14.5
14,4
! or;
50
0.5
0.3
0.2
0.8
0.4
0.2
loff
90
2.8
2.6
2.4
4.4
4.0
3-8
95
4.1
3.8
3.7
6.5
6,1
5.9
99
7.4
7.1
7.0
n.g
11.4
11,2
Irai:
50
0.3
-0.1
-0.3
0.4
-0.1
-0.4
2 off
90
1.6
U
I.l
2.7
2.1
1.8
95
2.4
2.0
1.9
4.0
3.4
3.1
99
4.4
4.0
3.8
7.3
6.7
6.4
*The t^e is best used to compare expected muiatton frequencies (or resistance and to see whether resistance would be expected with different managemem
regimes. Examples of such frequotcies would be ca lO*^ for a domlnaDt mon^enic trait, ca for recessive monogenic mutants if unproven theory is accepted,
OT ca i(r^ if experimenta! data frotn another biolo^cal system (SS) is accepted. A miruis sign indicates a negative enrichment for resiaance. It is presumed that the
TtUiess of uiazine-res^taiu weeds 0.3 to 03 and die fitness of ALS level sulfonylurea resistance is ca. 0.9. Calculated from equaiicms in (24).
^^The effective kiU (the percent control over the whole season) ofSO. 90. 95. and 99% are equivalent to a= 2, 10,20, lOO.respectively inEquaUons [1] andi21. A
seed bank release of 5 » 03 (half-life in seedbank of 2 yr) and of 1.0 were assumed.
a) to design rotational and mixture scenarios to delay
resistance as much as possible yet still to obtain cost-
effective we«3 control using herbicides such as chlor-
sulfuron and atrazine, which are among the least expen-
sive and most active selective herbicides for wheat and
com» respectively;
b) once resistance has occurred, to design strategies
whereby herbicide usage is stopped for a number of
years, until the level of resistance is below a certain
proportion, and then resume limited use, during a cer-
tain proportion of the rotation cycle. Such strategies
have been designed for insecticides where there already
arc predominantly resistant populations. These popula-
tions b^ome diluted because of fitness and the migra-
tion of susceptible individuals into the area (16). The
treatment strategies are designed so the maximum pro-
portion of resistant individuals does not exceed a cer-
tain limit percentage.
With this newer model, a kill percentage can be
calculated that will give any (within reason) desired
degree of resistance enrichment after p “on” years and
q “off’ years. This was done to calculate various types
of enriclunent for both minimum tillage and other situa-
tions where the seed bank can be negligible. It also can
be used for tillage and other bank situations under
conditions where various acceptable levels of enrich-
ment were allowed or to stasis where no net increase in
the frequency of resistance occurs. To achieve such
stasis would be nirvana. There are theoretical situations,
perhaps even field situations, where stasis might be
achieved. Different treatment regimes with low selec-
tion pressures giving stasis without a seedbank are
shown in Figure 3. Given this information, weed con-
trol of strategies can be designed where resistant indi-
viduals will not be enriched. One cannot obtain stasis
with continuous use of a herbicide under conditions
giving adequate weed control. One still can ensure that
the rate of enrichment is low.
The model is plotted so selection pressures that pro-
vide resistance stasis as a function of the duration of
seed remaining in the seedbank are shown in Figure 4
for various fitnesses. Three possible rotation strategies
are examined. Some cases can have no enrichment at
all for resistance. If the effective kill by 2,4-D in wheat
is only 50 to 60% due to late weed germination, then
under low fitness and a 1:1 rotation there is no enrich-
ment Stasis can even be obtained with selection pres-
sures above 90% if there is a 2- or more yr interval
between the treatments with the herbicide. Stasis is
impossible with high seltrction pressure herbicides in
Volume 4, Issue I (January-Marcb), 1990
195
715
GRESSEL AND SEGEL; MODELUNG STRATEGIES TO DELAY HERBICIDE RESISTANCE
Figure 3. Resistaoce stasis for situatkHis wbne thore is no seedbank buffering
as actually occurs in nunimum-tUl agricukure. Values of seleaios pressure (a)
and ftiness (0 ut years that vrill allow no enridunent for resistance (stasis).
when/(M = i (24). Tbe e^tive kilts are based upcn total lack of ho-bicidal
effect CHI the resistau mdividuais. (Collated from etjuatioos in (24).
Figure 4. Conditttxts leading to a resistance stasis under various seieclicm pres-
sures (aX and with diffnent rotation stnuegies or with din'erent v^ed seed
dynamics in the seedbank. The selortion pressme dso is diown as “effective
kUr* (the percent reduction In sensitive ^t^aguies over a whole seastm) with
the assumption that the rare reststant individuals are totally unaffected by the
herbicide. Here/o„ = 1 while/^udres areiaiiveiy low value in (A) and a hi^er
value is (B) and (C). 1^6/^010.2 and 0-S in A and B approximate those found
with triazine resistance, and die /^ of 0.9 in (C) af^ximaics the target site
resistant mutants to acetoiactate synthase inhiinuirs. the seedbank dynamics
are given as S. the fraction remaining in the stwl at the end of a season, and tos.
the half-life of seeds in the seedbank. Cakulafed from equ^ons in (24).
usual rotational sequences. Long duration of resistant
seed in the seedbank is a deterrent to stasis, as resistant
seeds as a buffer for longer periods.
While stasis may be hard to achieve, a doubling of
the frequency of resistant individuals every 3 yr would
be acceptable. Selection pressures are depicted in Fig-
ure 5 that will just double the frequency of resistant
individuals in the population in 3 yr with the “1-on: 2-
off” strategy. At an intermediate duration of seed resi-
dence in the seed bank, the doubling of resistance
occurs ^ the lowest selection pressures. This means
that if the frequency of resistance is liH, then it will
take almost 60 yr for resistant populations to predomi-
nate.
CONCLUDING REMARKS
The model depicted from Equation [2] in Table 3
and Figures 2 to 5 describes the emichment for resistant
individuals in the population but only when they are
still a minuscule proportion of the total population and
not when a population actually nears resistance. As the
resistant population becomes large, some of the simpli-
fications that are valid only at lower resistant frequen-
cies cannot be used. The complex equations from which
Equation [2] was derived (24) must be used. These cast
light on the new considerations that are needed for
resistance management once there is a preponderance of
resistant individuals. The consideration of the lower
fitness in the “off’ years can be refined further when
actual data are available on fitness in different field
situations with di^erent species as well as more infor-
mation on the dimunition of resistant populations under
various agronomic and herbicide treatments.
Information on fitness also will be needed for many
types of herbicide resistance to allow more accurate
design of management strategies. What is clear is that
ail resistances so far have occurred in monoherbicide/
monoculture or in equivalent situations that have the
same effect. Weed species either receiving the same
number of treatments, as in monoculture but over a
longer period in rotational situations, or receiving mix-
tures that control the species have not evolved resistant
populations.
Many resistant individuals are less fit (Table 1)
because of the nature of the target site mutation confer-
ring resistance or due to the high levels of gene prod-
ucts required to detoxify the herbicide. In other cases,
resistant individuals may not be too unfit; or because of
their nuclear inherited nature, many of the deleterious
co-mutations may be lost Chlorsuiftiron-resistant mu-
tants may not have lower productivity (7), but the
competitive fitness of these plants has not been mea-
196
Volume 4, Issue ! (Januaiy-Warch), 1990
716
WEED mahKXXXlY
10 54 3 2 I VgCyrs)
Figure 5. Scleclioo prtsstf^ that cause a dot^Iing of the prc^rUm of resistant
isdividuais in the pqMlalkm every 3 yr. The data are given for a 1 on: 2 off
rotatknai strategy, with diflerem fitness in the years » 1 ) and diffeieni
seed bank dynamics. The seedbank dynamics are ^ven as 5, the fraction le-
mauiing in the soit at the end of a season, and t. 5 , the baif-Ufe of seeds in the
seedbank. Calcidated from equations in (24).
sured. There are theoretical reasons, based on the site of
the mutation on the gene, to assume that these sulfonyl-
urea-mutants need not be very unfit (46). Thus, rotating
chlorsulfuron with other herbicides may not delay resis-
tance beyond the number of “off’ years, as it has with
atrazine and trifluralin [2,6-dinitro-^,A/-dipropyl-4-(tri-
fluoromelhyObenzenamine]. The added value of rota-
tion will be only where the fitness is low in the off
season.
Both the models and the limited field data suggest
that the l^st tactics to prevent or to delay the appear-
ance of resistant populations are:
a) to use herbicide treatments with the minimum
selection pressure giving cost-effective weed control.
Such treatments will not give near total weed control
but leave behind enough susceptible seeds each year to
dilute out resistant seeds;
b) to use herbicide mixtures of compounds acting at
different sites of action and having different modes of
degradation, preferably with herbicides having strong
negative cross resistances;
c) to use rotations of herbicides having different sites
of action and different modes of degradation, preferably
where the weeds have neg^ve cross resistance to the
h^bicides; and
d) to employ mechanical cultivations in the rotations,
specially if Aey preferentially control unfit resistant
biotypes.
TTiese criteria are haiti to meet with some monocul-
tures, especially wheat Wheat probably has only a
single mode of degradation (19). In such situations, it is
necessary either a) to rotate crops to allow herbicide
rotation; b) to rotate with herbicides having a placement
selectivity (e.g. 15) that is not related to herbicide
metabolism in wheat; (c) to find syneipsts that prefer-
entially inhibit herbicide degrading enzymes in the
weeds of wheat (20).
TTiose high-selection-pressure herbicides having re-
sistant mutants that are fit will be problems. The only
alternative is to replace these with less persistent herbi-
cides of the same group having less selection pressure
and thus partially offseuing the lack of fitness.
ACKNOWLEDGMENTS
Eva Yegcr assisted with calculsiiag the tables and figures. S. Cresse! has
the Gilben de Booo C3iair of nant Sciences and L. A. Segel has the Hetuy
and Bertha Benson Chair of Mathemaucs.
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198
Volume 4, Isaie I (Jaiuiary-Mach), 1990
718
Weed Science Society of America
Are Herbicide Mixtures Useful for Delaying the Rapid Evolution of Resistance? A Case Study
Author(s): Roger P. Wrubel and Jonathan Gressel
Source: Weed Technology, Vol. 8, No. 3 ^Jul. - Sep., 1994), pp. 635-648
Published by: Weed Science Society of America and Allen Press
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719
Review/ Analysis
Are Herbicide Mixtures Useful For Delaying the Rapid Evolution
of Resistance? A Case Study'
ROGER P. WRUBEL and JONATHAN GRESSEU
Abstract. Mixtures of herbicides have been proposed as strategies to prevent or delay the evolution of
resistance to the resistance-prone sulfonylurea and imidazolinone herbicides that inhibit acetolactate
synthase. These herbicides have become or aie becoming widely used in soybean, wheat, rice, and other
major crops. For a mixture to te efficacious in preventing resistance, the less resistance-prone compo-
nent(s) should have the following traits compared to the vulnerable herbicide: a) control the same spectra
of weeds; b) have the same persistence; c) have a different target site; d) be degraded in a different manner;
and e) preferably exert negative cross-resistance. We compared the proposed mixing partner for use
with several widely used acetolactate synthase inhibiting herbicides to these criteria and found that: a)
all have somewhat different weed spectra; e.g. none control common cocklebur as well as imazaquin or
imazeihapyr in soybean, or kochia as well as chlorsulfuron in winter wheat; b) all are far less persistent
than these vulnerable herbicides. Less persistent sulfonylureas are now on the market but are in limited
use. Late in the season, the mixing partner is not present while the vulnerable herbicide remains active;
c) most have different target sites; d) in soybean most mixing partners are degraded differently than
vulnerable herbicides. In wheat virtually all herbicides used without safeners are degraded by monooxy-
genases, thus it is impossible to meet this criterion in this crop; e) none of the mixing partners exert
negative cross-resistance. The present mixtures may have superior or more cost-effective weed control
properties than the acetolactate synthase inhibitors used alone, but they do not meet all the criteria for
resistance management. Not meeting the key criteria of identical control spectra and equal persistence
aggravates future resistance problems, as has happened with insecticides. Nomenclature: Chlorsulfuron,
2-chloro-iV-[{(4-methoxy-6-methyl- 1 .3,5-triazin-2-yl)amino]carbonyl}benzenesulfonamide; imaza-
quin, 2-[4,5-dihydro-4-methyl-4-( 1 -methylethyl)-5-oxo- 1 W-imida2ol-2-yl]'3-quinolinecarboxylic acid;
imazethapyr, 2-l4,5-dihydro-4-methyl-4-( 1 -methylethyl)-5-oxo- 1 //-imidazol-2-yl]-5-ethyl-3-pyridine-
carboxylic acid; cocklebur, Xanthium strumarium L. P XANST; kochia, Kochia scoparia (L.) Schrad.
# KCHSC; com, Zea mays L.; rice, Oryza saliva L.; soybean. Glycine max (L.) Merr.; winter wheat,
Triticum aestivum L.
Additional index words: Imidazolinone resistance, sulfonylurea resistance; ALS-inhibilor resistance.
INTRODUCTION
The extensive and continuous use of heibicides over the
last four decades has resulted in the evolution of weeds
resistant to normally phytoloxic chemicals. Since the first
reports of triazine-resistant weeds in the mid-1960s (19,
36), well over 100 weed species have been identified that
have evolved biotypes with resistance to at least one and
'Received for publication Dec. 1, 1993, and in revised fcwm May 16, 1994.
‘Asst. Res. Prof,, Dcp. Urban and Environ. Poiicy.TuftsUniv., Medford, MA
02155, and Prof., Dep. Plsuit Genet., Weizmann Inst. Sd. Rchovot IL76100,
Israel.
^Letters following this symbol are a WSSA-approved compute code from
Composite List of Weeds. Revised 1989. Available from WSSA, 1508 West
University Ave.. Champaign, IL 61 821 -3 133.
occasionally more than one herbicide type (46, 47, 53, 54,
55). Reports of evolution of newly re.slsiant biotypes con-
tinue to increase steadily (46, 47), although many cases
probably go unreported. Several disturbing trends have
been recognized. Herbicide resistance seems to be appear-
ing after fewer years of exposure to newer herbicides than
to the older inhibitors of photosystem II; many weeds have
shown a capacity to evolve resistance; and some of the
resistant biotypes may have similar reproductive fitness to
that of susceptible biotypes (1, 2, 45, 53, 55, 58). These
trends indicate that resistance problems are accelerating
and that management of weeds could become more diffi-
cult in the future due to herbicide resistance.
Several strategies have been proposed to prevent or
635
Weed Technology. 1994. Volume
720
WRUBEL AND GRESSB-: ARE HERBICIDE MIXTURES USEFUL FOR DELAYING EVOLUTION OF RESISTANCE?
delay the evolution of resistant weed populations. Ani<»ig
them are rotation of crops, rotation of herbicides with
different modes of action, use of combinations of herbi-
cides with different modes of action, and conservation of
susceptible weeds (37, 38, 39, 47, 59, 69, 70). These
strategies aim to reduce the selection pressure favoring
weed biotypes that have evolved herbicide negating
mechanisms.
Groups of structurally dissimilar heihicides inhibiting
acetolactate synthase (ALS)^ including sulfonylureas,
imidazoiinones, and triazolopyrimidines, are especially
prone to losing efficacy due to the rapid evolution of
resistant weeds (55). While some weeds have evolved
resistance to single chemical groups, other populations of
the same species have evolved target site cross-resistance
to ALS inhibitors of other chemical groups, even though
they were subjected to only one (29, 4 1 , 65, 72, 73, 75, 83).
Herbicide manufacturers acknowledge that there is se-
rious potential for ALS-inhibitor resistance problems in
weeds (4, 6, 13, 61) and have founded the ALS/AHAS'*
Inhibitor Resistance Working Group within their Herbicide
Resistance Action Committee. Member companies of the
working group have devised strategies that they believe
will prevent or severely delay evolution of resistance in
weeds. The core of the strategies is to use mixtures of
herbicides with different modes of action to combat resis-
tance. Their approaches also involve recommendations to
growers to use weed surveys and weed thresholds to deter-
mine the actual need for herbicide use before spraying, to
combine cultivation with herbicide treatment, and to rotate
crops (13). The producers of the ALS inhibiting herbicides
are promoting these strategies based on the continued use
of their herbicides in combination with herbicides having
different modes of action (4, 6, ’ The continued use
of imidazolinone herbicides in combination with other
heibicides is even recommended to treat fields where
imidazolinone-resistant weeds have been identified.* Still,
the ALS/AHAS Resistance Working Group formed by
industry has provided only general recommendations and
no binding specific recommendations, due in part to the
different economic interests of its member companies.
^Abbreviations: ALS. acetdactate synthase (AHAS, acetohydroxyacid syn-
thase is an often used synonym).
*Shaner. D. 1993. Personal communication, American Cyanamid Company.
Princeton, NJ 08543.
^Dahrner, M. 1993. Persona! communication, American Cyanamid Co.,
Princeton, NJ 08543.
’Sekely.K. 1993, Personal ctsnmunication.AmericanCyanamidCo.. Wayne.
NJ 07470.
The primary objective of this paper is to examine the
herbicide mixtures being recommended to determine if
they can be potentially effective resistance management
tools. We first discuss the characteristics of the herbicides
of interest and then the theoretical considerations related
to using herbicide mixtures for managing herbicide resis-
tance. We then describe the characteristics required of a
competent mixing partner. Finally, we analyze the likeli-
hood of present recommendations for use of heibicide
mixtures with imidazoiinones in com/soybean and with
sulfonylureas in wheat cropping systems to meet the crite-
ria delineated for effective herbicide resistance manage-
ment.
CHARACTERISTICS OF ALS-INHIBITING
HERBICIDES
The ALS inhibitors are relatively new classes of herbi-
cides. The imidazoiinones were developed and first mar-
keted by the American Cyanamid Company in 1986. The
sulfonylureas originally developed by E. I. Du Pont de
Nemours and Company were first introduced in 1982 and
are now manufactured by several companies. The tria-
zolopyrimidines were developed by Dow-Elanco Corpo-
ration and are just now appearing on the market. These
three chemistries of herbicides all inhibit acetolactate syn-
thase, the first enzyme in the synthesis pathway leading to
branched-chain amino acids (31, 52. 66, 71, 79, 80). In
sensitive plants, the synthesis of valine, leucine, and
isoleucine is curtailed. Most naturally resistant crops rap-
idly metabolize these herbicides and render them ineffec-
tive (73). The ALS inhibitors have a number of favorable
characteristics from weed control and environmental per-
spectives. Most of these herbicides are highly efficacious
for control of a broad spectrum of dicot weeds, and to a
lesser extent monocois, as well as many perennials (Table
1). They are applied at relatively low rates, have very low
mammalian toxicity, and are not mutagenic in the Ames
test (86). Unfortunately, the ALS inhibitors are among the
herbicides considered to be at highest risk for the evolution
of resistance in weeds because they have a single target
site, are effective against a wide spectrum of weeds, and
many are relatively persistent, often providing season-long
control of germinating weed seeds (55). Also, the various
sites of mutations for resistance are not near the active site
of the enzyme and thus there is no fitness loss due to a lower
affinity for the normal substrates (77).
The incidence of herbicide resistance to ALS inhibitors.
636
Volume 8, Issue 3 (July-September) 1994
721
WEHSTKHNOLOGY
Table I. Efficacy of itnidazolinone herbicides (imazaquin or imazeth^jyr)* for
dicoJ and monocot weed control in soybeans.
Dicrt weeds {efficacy 5 75%)
Cockicbur
Jimsonweed {Daiura stramonium L # DATS!)
Common lambsquaxters
Pigweeds
Stack nightshade {Solanum nigrum L. # SOLNl)
Common ragweed (Ambrosia artemisiifolia L. # AMBEL)
Smartweeds
Wild sunflower (Helianthus annuus L, # HELAN)
Velvetlcaf
Burcucumber (Sicyos angulatus L. # SIYAN)
Monocot weeds (efficacy > 55%)
Crabgra.ss (Digitaria sanguinalis (L.) Scop. # DIGSA)
Fait panicum (Panicum dichoiomiflorum Michx, # PANDI)
Giant foxtail (Setaria faberi Herrm. # SETFA)
Shattercane (Sorghum bicolor {L.) Moench H SORVU)
(Volunteer) com
Bamyardgrass (Echinochloa crus-galli (L.) Beauv, # ECHCG)
Yellow foxtail (Setaria glauca (L.) Beauv. # SETLU)
Woolly cupgrass (Eriochloa vitlosa (Thunb.) Kunth # ERBV!)
Yellow nutsedge (Cyperus esculentus 1-. # CYPES)
®Data adapted from (1 1 ).
particularly sulfonylureas, is increasing. Since the first
discovery of prickly lettuce {Lactuca serriola L. # LACSE)
resistant to the sulfonylurea herbicide chlorsulfuron, in
1 987 (57), 1 3 other weed species with ALS-resistani popu-
lations have been confirmed with expanding geographic
areas l^ing affected (73). Cross-resistance of weed bio-
types to other ALS-inhibitors augments the potential prob-
lem. Patterns of cross-resistance of weeds to ALS-inhibilor
herbicides within and among the chemical families are
highly variable and unpredictable. Weed biotypes resistant
to one ALS-inhibitor herbicide exhibit varying levels of
cross-resistance to other ALS inhibitors (24, 29, 30, 4 1 , 57,
65, 72. 75,76, 78,81).
CRITERIA FOR EFFECTIVE MIXTURES FOR
RESISTANCE MANAGEMENT
Herbicide mixtures have been discussed and modeled
as a means of preventing or delaying the evolution of
resistance in weeds (33, 38, 39, 59). There is also extensive
theoretical and experimental literature on the use of insec-
ticide and fungicide mixtures (26, 28, 49, 50, 56, 70. 74,
82). We know of no field studies specifically designed to
examine the effectiveness of herbicide mixtures compared
to other methods of weed resistance management, but there
are “epidemiological” data. Extensive areas of monocul-
ture corn have been treated continuously with triaz-
ine/chloroacetamide mixtures over 20 yr. Two broadleaf
weed groups (Chenopodium spp. and Amaranthus spp.)
that have often evolved triazine resistance when triazines
were used alone, have never been reported to evolve resis-
tance where these mixtures- were used. The chlo-
roacetamides have some limited activity on these two
genera.
It has been posited that the use of herbicide mixtures
combining different modes of action will substantially
delay or preclude evolution of resistance to the more
vulnerable or at-risk herbicides (4, 6, bl).^-’^-’ This is be-
cause weeds resistant to the vulnerable herbicide will be
destroyed by the mixing partner, or at least be rendered
relatively unfit compared to the wild type. For our discus-
sion we will assume that two herbicides are used in rmxture
although more are possible. We refer to “mixtures” as only
those combinations of herbicides where the partners both
affect the same target weed (Table 2, sp. A). Often mixtures
are used where each member affects different weed spec-
tra, e.g., mixtures of grass and broadleaf herbicides (spp.
B and C in Table 2). These latter mixtures, which increase
weed control benefits, have no influence in delaying evo-
lution of resistance in weeds they do not affect. They might
even exacerbate resistance by controlling competing
weeds, creating a more open niche for resistant biotypes.
It is hard to assess, without experimentation, what the
effect on the rate of evolution will be when the mixing
partner has a moderate effect on a species excellently
controlled by the vulnerable herbicide (Table 2, sp. D).
Evolution of target-site resistance to both the vulnerable
and the partner herbicides is possible when mixtures are
used, but should be much delayed compared to the appear-
ance of resistant biotypes where each herbicide is used
separately. The following reasoning, based on a com-
pounded resistance frequency model, has been used to
theoretically support this supposition: If the frequency of
individuals resistant to each component of a pesticide in a
mixture is independent in the susceptible species, then
the joint probability of evolution of co-resistance to both
herbicides in one individual equals the product of the
Table 2. Possible effecis of mixtures on different species.
Species
Comrol by
A
B C
D
l„. -1
Vulnerable herbicide
++
++ 0
-H-
Mixing partner
-♦-+
0 -H-
+
*0 = no cOTttol; +
= partial control;
++ = conUol.
Volume 8. Issue 3 (July-September) 1994
637
722
WRUBEL AND GRESSEL: ARE HERBfCIDE MIXTURES USmJL K)R DELAYING EVOLUTION OF RESISTANCE?
Figure I. Tfw persistence of herbici<ks in mixtures as related to germinalRm flushes of weeds. The dis»pation of herbicides is usually linear when herbicide remaining
is plotted exponentially. The horizontal dasted line denotes when the herbicide is no longer biologically active, A. A .situation where a weed species germinates
throughCTJt the growing season and many flushes are affected by only one comptmem of a mixture. B. A situation where the weed species germinates in a single flush
and is affected by ixith components of the mixtures.
probabilities of resistance for each partner f(28) for insec-
ticides, (38) for herbicides]. For example; A weed has a
natural mutation frequency of for resistance to the
vulnerable herbicide and 10"'® to a mixing partner having
a different target site. The genes for resistance are inherited
independently of each other (i.e., are not linked). Then, the
joint probability of resistance to both pesticides in a mix-
ture is 10'® X l(h'® = 10-'^ which is very rare and is a
smaller number. Thus, it would be expected that the simul-
taneous co-resistance to both herbicides, the only type that
could appear, would evolve relatively slowly due to the
minuscule initial frequency of doubly resistant individuals.
Not only is the mutation frequency to joint resistance a
compounded number, but any lack of fitness due to each
mutation would also be compounded such that a weed with
dual resistance may be far less fit and less competitive than
wild type susceptible individuals (37, 38). However, the
combination of herbicides can significantly increase the
overall selection pressure on weeds by eliminating all
susceptible genotypes due to use of full rates of both
partners. In this case resistance to both hert>icides may be
delayed less than predicted by a compound model (38).
One major assumption of the compounded frequency of
the resistance mode! described above is that the use of
herbicides with different modes of action will not result in
selection for weed biotypes possessi ng a single mechanism
that detoxifies both partners. The evolution of generalized
detoxification systems such as the monoxygenases com-
mon in wheat have been suggested to explain broad cross-
resistance (33, 34) in blackgrass (Alopecurus myosuroides
Huds. # ALOMY) (62) and rigid ryegrass {Lolium rigidum
Gaudin # LOLRI) (64). There is some preliminary evi-
dence (25, 27, 51) to support this idea of biochemical
mimicry (33, 34) which is not universally accepted. (See
the section below. “Evolution of metabolic resistance," for
further discussion)
Characteristics of effective mixing partners for resis-
tance management. U is possible that there will be cases
of enhanced weed control by a mixture, but that such a
mixture will be contraindicated vis-i-vis resistance man-
agement. Simply combining pesticides with different
modes of action will not delay resistance if the efficacy and
temporal activity of the mixed pesticides do not match
(70). The mixing partner must effectively kill or severely
weaken the weeds most sensitive to the vulnerable herbi-
cide, because these weeds are the most likely to evolve
resistance (38. 59). Both components should do so with
nearly the same effectiveness; it may not be helpful if at
the rate used, the mixing partner kills 75% of the weeds
and the vulnerable kills 95%, unless the 20% remaining are
severely inhibited such that they have a lesser reproductive
capacity than the wild type. Otherwise, resistance could
quickly evolve in the remaining 20% of weeds.
Both components of the mixture need to have similar
persistence when weeds germinate throughout the crop-
ping season. Otherwise, there will be a period when only
the vulnerable one is present and effectively the target
weed will not be exposed to a mixture at ail (Figure 1 A).
Unlike crops, which have been selected to germinate uni-
formly and shortly after planting, seeds of many weed
638
Volume 8, Issue 3 (luly-September) 1994
723
WEED TECHNOLOGY
species have many flushes of germination during a crop-
ping season (20). If a susceptible weed has multiple flushes
during the season, and the vulnerable herbicide hasalonger
period of activity than the mixing partner, then the vulner-
able herbicide selects for individuals resistant only to it
after the mixing partner has dissipated (Figure 1 A). TTius,
if the vulnerable herbicide has season-long activity (i.e., is
selecting for resistant biotypes season-long, even when
weed populations are below the economic threshold), it is
critical that the mixing partner have the same persistent^.
This problem is accentuated when there is a long growing
season and there can be more flushes of weeds producing
viable seed in late season. Thus, a mixture may be more
efficacious in northern, short season soybean areas than in
southern areas with very long growing seasons.
A mixture that is not well matched for pereistence can
still be effective if the weeds germinate in a “single flush,”
without further germination, and both herbicides outlast
the flush with equal efficacy (Figure IB). Most cropping
systems have many different weed species, so this circum-
stance can hold for some species but may often be irrele-
vant for the agroecosystem as a whole.
Methods could be devised for using a short-persistence
mixing partner along with a long-persistence vulnerable
herbicide. The short persistence mixing partner could be
applied based on observations of weed germination or a
farmer could repeatedly spray this herbicide throughout
the season without such observations (not a recommended
practice). The farmer might have to treat with the mixing
partner late in the season (if registered) when application
might confer no economic gain. It is also conceivable that
a contact herbicide mixing partner, used late in the season,
would not effectively eliminate all resistant weeds under
the crop canopy. Unless there is very close overlap in the
duration of efficacy between the two herbicides, a resis-
tance management strategy based on their mixture is prob-
lematic and operationally complex.
The ideal mixing partner should have three other prop-
erties In addition to those just mentioned: Firstly, the
mixing partner should have a different target site of action
from the vulnerable herbicide. Thus, use of a iriazinc and
a uracil or phenylurea can be contraindicated as mixtures,
as they act on the same protein in photosystem II. The
situation for ALS-inhibitors is slightly more complex be-
cause of the differential pattern of cross-resistance among
weed species to ALS-inhibitor herbicides (30, 42, 73, 76).
This pattern probably results in part from different or
overlapping active sites for the herbicides on the ALS
molecule (77). All weed biotypes resistant to one ALS-in-
hibitor are cross-resistant to at least some other ALS-in-
hibitors (73), and it is now impossible to predict the pattern
of cross-resistance. Additionally, whereas one biotype of a
species may have limited cross-resistance to other ALS-in-
hibitors, other biotypes of the same species may have
broader overlapping spectra, i.e. the genes are present for
br(^ spectrum ALS resistance. Thus, two ALS-inhibitors
cannot be considered mixing partners for resistance man-
agement.
Secondly, the mixing partner should not be degraded in
the same manner as the vulnerable herbicide. For example,
if the vulnerable herbicide is degraded in the crop by a
glutathione-transferase, the mixing partner should have no
chemical site that can be attacked by that enzyme. This
criterion could be a problem in wheat where all biochemi-
caliy-seiective herbicides seem to be degraded by mono-
oxygenases in the crop (34). Herbicide mixtures for wheat
would be subject to evolution of resistance in weeds capa-
ble of evolving increased levels of monooxygenase detoxi-
fication systems. This can come about by the evolution of
higher levels of specific monooxygenases, by mutations
coding for enhanced substrate (herbicide) specificity of
one monooxygenase, or by mutations enhancing higher
constitutive levels of all or many monoxygenases.
Thirdly, another useful attribute in a mixing partner
would be to possess negative cross-resistance; i.e. where
individuals resistant to the vulnerable herbicide are more
susceptible than the wild type to the mixing partner. This
would actually reduce the frequency of resistant alleles in
the weed population. This strategy was first proposed for
herbicides on the basis of laboratory data (40), and infor-
mation on the existence of negative cross-resistance at the
whole plant level has been published recently (18).
USE PATTERNS OF ALS-INHIBITING HERBICIDES,
EVOLUTION OF RESISTANCE, AND
HERBICIDE MIXTURES
Resistance in soybean. ALS-inhibiting herbicides were
found to be highly efficacious in controlling weeds inade-
quately controlled throughout the season by other herbi-
cides and thus came into rapid use (e.g.. Table 3).
Imidazolinone-resistant populations of common cocklebur
were discovered in 1991 and 1992 in soybean fields in
eight apparently independent locations along the Missis-
sippi River valley.^ In each case the fields were continu-
ously planted to soybean and treated for several yeare with
Voiume 8. Issue 3 (July-September) 5994
639
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WRUBEL AND GRESSEL; ARE HERBODE MIXTURES USEFUL K)R l^AYING EVOLUTION OF RESISTANCE?
imazaquin. At one site in Mississippi resistant bit^ypes
were identified in 1991 after only three consecutive years
of banded applications of imazaquin with cultivation be-
tween the rows (78).® This rapid evolution is especially
worrisome, as it means that susceptible cocklebur ctmld
have grown in the areas between the rows. These suscep-
tible biotypes should have diluted the number of resistant
individuals in the seed bank and delayed the appearance of
resistant populations. In Mississippi, cocklebur biotyj^s
that evolved resistance due to exposure to imazaquin are
cross-resistant to imazethapyr.* However, ALS extracted
from these imazaquin-resistant cocklebur were sensitive to
ALS-inhibitors of other chemical groups (78). An
imazaquin-resistant biotype of cocklebur collected in Mis-
souri was cross-resistant to other imidazolinones and sul-
fonyureas.’ Because of the number of apparently unrelated
resistant populations that have been detected so far, after
just a few years of exposure, it is logical to conclude that
cocklebur has the capacity to readily evolve resistance to
the imidazolinones and possibly other ALS inhibitors.
Use of ALS-inhibitors in soybean and corn. The use of
imidazolinone herbicides has been increasing dramatically
in the U.S. The soybean area treated with either imazaquin
or imazethapyr in Illinois, the largest soybean producing
state, more than doubled from 20% in 1 990 to 43% in 1 992
(Table 3A). In Iowa, the soybean area treated with imida-
zolinones increased from 33% in 1990 to 52% in 1992.
Across all major U.S. soybean producing states imidazoli-
none use increased from 27% of area treated in 1990, to
39% in 1991, to 47% in 1992 (Table 3B). Even without
considering additional use of imidazolinones in soybean,
the exposure of weeds to these herbicides will be increas-
ing in the coming years because of their use in other
rotational crops such as com.
Commercial sale of imidazolinone-resistant com was
initiated in 1 993 by four seed companies (Pioneer Hi-Bred,
Zeneca Seeds, Ciba Seeds, and Cenex/Land O’ Lakes),
mostly in the northern com belt. About a half million
hectares of imidazolinone-resistant seed were available
*8arremine, W. L, 1993. Personal communication. Delta Res. and Ext. Ctr..
Stoneville, MS 38776.
^Kendig. J. A. and M. S. DeFelice. 1994. ALS resistant cocklebur {Xantkium
sirumarium L.) in Missouri. Weed Sci. Soc. Am. Absm 34: 1 2.
'^Edwards, M. 1993. Persona! conmmnicaiton. Pioneer Hi-Bred Int.. Inc.,
P.O. Box 6500, West Des Moines, lA 50265.
' ‘Grccnwald, R. i W3. Personal conununication. Zeneca Seeds, Des Mmnes,
lA 50266.
'^Christiansen, D. 1993. Personal communication. Ciba Seeds. GrrensbMo.
NC 27419,
Table 3. Use of aceioiactatc synthase inhibiting herbicides 1990-1992, fw .A)
each of the nine largest soyb^n producing slates and B) all majOT soybean
producing ^tes.
St^ and Ittdncide
Area
planted in
soybean
in 1992
Soybean area
treated^
1990
199!
1992
ha
—
% ■
A. Usage by state
Uiinois
3 850000
Imazethapyr
9
26
28
Imazaquin
11
14
15
Odorimuron
27
22
20
Iowa
3360000
Imazethaf^r
22
40
52
Imazaquin
II
3
NR**
ChlorimuTon
20
15
16
Minnesota
2230000
Imazeth^r
35
52
66
Imazaquin
NR
NR
1
Chlorimuron
NR
NR
NR
Indiana
1 840 000
Imazethapyr
8
18
23
Imazaquin
14
20
19
Chlorimuron
32
25
26
Missouri
1 740000
imazethapyr
7
13
42
Imazaquin
41
30
17
Chlorimuron
26
22
21
Ohio
1 520000
imazethapyr
4
16
19
Imazaquin
14
13
19
Chlwimufon
35
33
29
Nebraska
1 010 000
imazethapyr
16
32
39
Imazaquin
12
It
12
Chlorimuron
16
13
14
South Dakota
930000
Imazethapyr
10
28
34
imazaquin
NR
NR
NR
Chlorimuron
NR
NR
11
Kansas
770000
Imazethapyr
NR
11
16
Imazaquin
20
35
35
Chlorimuron
15
9
18
B. Usage for all
soybean stales'^
imazethapyr
II
24
29
Imazaquin
16
IS
18
Chlorimuron
20
17
17
*Source:{8).(9),and(I4)for 1990. 199Land 1992. respectively.
**Nm reported.
*Arca planted in soybean (million ha); 23.1 (1990); 22.3 (1991); and 21.2
(1992).
for planting in the 1993 season with the prospect of in-
creased availability in future years as well as development
of additional imidazolinone-resistant hybrid varieties
( 87 ) 10 , 11.12
Extending the use of imidazolinones to com presents
several potential problems in terras of weeds evolving
640
Volume 8, Issue 3 (July-September) 1994
725
WEEDTCCHNWXWY
resistance. A substantial part of the soybean area in the
northern com belt is rotated with com. Fifty-seven percent
of the area planted to either soybean or com in 1989 in the
northern com belt was used to grow the alternate crop in
1988 (32). In I991-"!992 com and soybean were rotated
on 54% of the crop area ( 1 7). Thus, a farmer who formerly
rotated herbicides along with soybean-corn crop rotations
now has the option to continuously use imidazolinones.
Some of the area planted to continuous com or cwn rotatwl
with crops other than soybeans, which formerly never
encountered imidazolinones, now will be exposed. Com
and soybean have similar growing seasons and across
most of the northern com belt they have essentially the
same spectrum of summer annual weeds. Species such
as foxtails (Setaria spp.), velveileaf {Abutilon theo-
phrasti Medicus # ABUTH), cocklebur, pigweeds {Ama-
ranthus spp.), common lambsquarters (Chenopodium
album L. # CHEAL), and smartweeds (Polygonum spp.)
are problem weeds of both crops. Thus, if imidazolinones
are used extensively in corn-soybean rotations, the same
populations of weeds will be exposed to the same herbi-
cide chemistry year after year, increasing the probability
of the evolution of herbicide-resistant weed biotypes. The
situation is further exacerbated by the availability of
sulfonylurea herbicides in soybean and com. Chlori-
muron { 2-[[[[(4-chloro-6-melhoxy-2-pyrimidinyl)amino
]carbonyl]amino]suifonyl]benzoic acid) was applied to
17% (Table 3B) and thifensulfuron {3-[[[[(4-methoxy-6-
methyl- 1 ,3,5-tria2in-2-yl)amino]carbonyl]amino)sulfon-
yl]-2-thiophenecarboxylic acid} to 7% of soybean crop
area in 1992 (14). Two recently released sulfonylurea
herbicides, nicosulfuron {2-[(t[4,6-dimethoxy-2-pyrimid-
inyi)amino]carbony!}amino]sulfonyl}-A/,A^-dimelhyl-3-
pyridinecarboxamide) and primisulfuron {2-[([([4,6-
bis(difluoromethoxy)-2-pyrimidinyl}amino]carbonyIJ-
amino]su!fonyl}benzoic acid), were used to treat 8% of the
com area in 1992 (14).
Research is also underway to develop varieties of wheat,
oilseed rape (Brassica napus L.) and tomato (Lycopersicon
esculentum Mill.) resistant to ALS inhibitors (43, 48, 60,
63, 84). Already in many agricultural areas there are crops
naturally resistant to at least one ALS inhibitor. With the
prospect of increasing use of ALS-inhibiting herbicides we
should expect the more extensive evolution of resistant
weeds to follow quickly.
'-^Owen. M.D.K, 1993. Persona! communication. Agronomy Dcp.. iowa State
Univ.. Ames. IA5001 1.
Analysis of herbicide mixtures recommended for tmi-
dazolinones in soybean/com cropping. At present, imi-
dazolinones are primarily used in soybean and are t«ing
extended into com. Thus, we have analyzed the mixtures
proposed for those two crops. As sulfonylurea and other
ALS inhibitor use becomes more widespread, their mix-
mres should be evaluated using the same criteria. As imi-
dazolinone-resistant cocklebur has been discovered in
several locations, we have chosen to analyze the usefulness
of the herbicide mixtures recommended by the manufac-
turer for lessening the likelihood of evolution of resistant
populations of this weed. We posed the following ihetori-
cal question: which, if any, of these mixtures might have
prevented the evolution of imidazolinone-resistant fX)pu-
lations of cocklebur? Cocklebur is an annual broadleaf
weed commonly found in cultivated lands, pastures, along
streams and rivers, and in waste places (44). Cocklebur is
considered the most competitive weed of soybean in the
southeastern U.S. (10). Each burr on die plant produces
two heieromorphic seeds, with lower seeds having less
dormancy than upper seeds (20, 44). Some seeds germinate
promptly while others remain dormant and germinate
months or years after maturity and dispersal (44). Cockle-
bur typically appears in fields throughout the growing
season. Small plants can flower and set seed in the photop-
eriods of the early and late growing season.® ‘^
Cocklebur presents a difficult case for herbicide mix-
tures aimed at managing resistance for imazaquin and
imazethapyr. Firstly, cocklebur is very sensitive to the
imidazolinone herbicides used in soybean. Thus, these
herbicides apply strong selection pressure for resistance.
The recommended application rate for imazaquin in soy-
bean is 140 g ai/ha (10). One-eighth that amount, 17 g/ha,
issufficient for control of cocklebur.® Imazethapyr controls
cocklebur when applied to soil (65 to 75% control) or
leaves (85 to 95% control) (1 1). Secondly, both imazaquin
and imazethapyr are sufficiently active in the soil to pro-
vide season-long control of cocklebur (as well as other
weeds). The manufacturer recommends waiting 11 mo
before rotating corn, barley (Hordeum vulgare L.), peanut
(Arachis hypogaea L.), or oat (Avena sativa L.) with soy-
bean treated with imazaquin (12). For imazethapyr the
recommended waiting periods are 9.5 mo for com and
peanut and 18 mo for most other crops (12). This suggests
that these herbicides have residual lifetimes sufficient to
remain effective against particularly susceptible crops and
weeds for long durations. Cocklebur can germinate,
flower, and set seed throughout the growing season, and
Volume 8, Issue 3 (Ju!y-September) !994
641
726
WRUBEL ANDGRESSEL: ARE HERBICIDE MIXTURES USEFUL FCH? DELAYING EVOLUTION OF RESISTANCE?
Table 4. Manufacturer's recommendations for broadleaf herbicide nuxtnres widi imidazoltnones to reduce the risk of weed resistance in soybean®.
Imidazolinone
Recommended
mixing paitner(s)
Oiaractoi^tcs of nuxing partner(s) for control of cocklebur
Imazethapyr
acifluorfen, lactofen, fomesafen
TTiese herbicides only have activity for very small cocklebur (3 to 4 leaf stage),
std efficacy is less than imidazolinones. All are short residual, contact hetbicides
requiring multiple applications for season-long cocklebur control.
Imazethapyr
metribuzin
MetrUnizin |»ovides only partial control of cocklebur
Imazeth^yr
iinuron
Limiron jwovides only partial control of cocklebur
imazethapyr and imazaquin
glyphosate, paraquat
Glyphosate and paraquat are non-selective, shwi residual, post weed emergence
herbicides. They effectively control cocklebur but multiple applications would be
required f(x season-long control.
Imazaquin
clomazonc
Clomazone is primarily a grass herbicide with only partial control of cocklebur.
®Mixtog partner recommendatiwis from (7).
after the crop has been harvested. By remaining active
throughout and beyond the growing season, the imidazoli-
nones can select for resistant, newly emerging cocklebur
biotypes for many months after application. Thus, an ef-
fective mixing partner for the imidazolinones must provide
equally effective season-long control of cocklebur.
Recommended mixing partners for soybean. Several of
the herbicide mixing partners recommended by the manu-
facturer provide only partial control of cocklebur and
would only delay resistant populations from evolving if
they severely inhibit cocklebur and if they have the
same duration of residual activity as the Imidazolinone
(Table 4). These include metribuzin [4-amino-6-(l,l-di-
methyl(ethy!)-3-(methylthio)-l,2,4-triazin-5(4//)'Onc],
1 i n uron [y-(3,4-dichlorophenyI)-A^-methoxy-A/-methy-
lurea], and clomazone {2-[(2-chlorophenyl)methyl)-4,4-
dimethyl-3-isoxazolidinone}. All three have shorter
effective persistence either due to shorter actual half-life
compared to the imidazolinones. or because they do not
inhibit cocklebur as much as the imidazolinones. Thus,
cocklebur germinating mid and late season are effectively
controlled only in cont^t with the ALS inhibitor. Acifluor-
fen (5-{2-chloro-4-(trif1uoromethyl)phenoxyj-2-nitro-
benzoic acid}, lactofen {(±)'2-ethoxy-l-melhyl-2-oxo-
ethyl-5-[2-chioro-4-(trifluoromethyl)phenoxy]-2-nitro-
benzoate}, and fomesafen {5-{2-chloro-4-(trifluoro-
methyl)phenoxy-A^-(methylsulfonyl)-2-nitrobenzamide}
are contact herbicides of relatively short persistence and
do not control cocklebur as well as the imidazolinones.
They are effective only for very small cocklebur (3- to
4-leaf stage). Glyphosate [iV-(phosphonomeihyl)glycine]
and paraquat (l,i'-dimeihyl-4,4'-bipyridimum ion) are
non-selective herbicides requiring special application
methods to protect crops from damage. Both herbicides are
strongly and rapidly adsorbed to soil, rendering them bio-
logically inactive. While glyphosate and paraquat control
cocklebur, their inclusion in a cocklebur resistance preven-
tion program requires that they be applied whenever the
weed is observed in the field. As cocklebur has staggered
and extended germination patterns, this becomes imprac-
tical. Thus, it appears that none of the mixing partners
presently promoted for use with imazaquin and
imazethapyr in soybean can effectively prevent resistant
biotypes of cocklebur from evolving and spreading.
The manufacturer of the imidazolinones is now recom-
mending laie-sea.son use of bentazon [3-(l-methylethyI)-
(l//)-2,l,3-benzothiadiazin-4(3//)'One 2,2-dioxidel. the
major herbicide replaced by the ALS-inhibitor, to control
cocklebur in the southern, long season soybean areas.^This
strategy, if adopted quickly by farmers might both contain
and set back resistance so that the imidazolinones could
remain effective for a longer period. This will be effective
only if bentazon can penetrate the soybean canopy to
eliminate all late season germinators. Otherwise, resistant
individuals will be left behind.
Recommended mixing partners for corn. Various mixing
partners recommended by the manufacturer for use in
imidazolinone-resistant com are presented in Table 5. Bro-
moxynil (3,5-dibromo-4-hydroxybenzonitrile), 2,4-D
[(2,4-dich!orophenoxy)acetic acid], and dicamba (3,6-di-
chloro-2-methoxybenzoic acid), when used at low rates in
most environments, are effective for control of cocklebur
but are short-persistence herbicides. Only atrazine [6-
chloro-Ar-ethyl-/V-( l-methy!ethyl)- 1 ,3 ,5-triazine-2,4-dj-
amine] matches the efficacy and persistence characteristics
(when used at full field rates) of imazethapyr and could
642
Volume 8, Issue 3 (Iu!y-Sep(ember) 1994
727
WEBiTCCHNOLOGY
Table 5. Manufacturer’s recommendations for broadleaf hertsicide mixtines wiUi
imazethapyr to reduce the risk of weed resistance in imidazohnaie resisi^l
com®.
Recommended
mixing partner
Characteristics of mixing partner for control of cocklebur
Atrazine
Has similar persistence and efficacy as imazethapyr for
cocklebur, but at recommended rate of ap^icaiion (555 g
ai/ha) would have little persistence.
Bromoxynil
A contact herbicide that degrades rapidly. It effectively
controls cocklebur but multiple applications would be
required for season-long control.
Dicamba
A systemic herbicide with limited persistence, that
effectively controls cocklebur. Multiple ai^tcaiions
would be required for season-long control.
2,4-D
A posiemergencc, shwi residual, systemic herWeide, that
provides effective control of cocklebur. Multiple
applications would be required for season-long control.
^Mixing partner recommendations from (7, i 2).
delay the evolution of resistant populations. However, at
the recommended application rate {555 g ai/ha) with
imazethapyr, atrazine would have shorter-lived field activ-
ity than the normally used rale, which is two to four times
higher. Thus, atrazine might not control cocklebur germi-
nating late in the season.
Analysis of mixtures proposed for sulfonylureas in win-
ter wheat. Much of the wheat cultivated around the world
is grown in areas where few other crops can be grown,
leading toexiensive monocultures. Increases in yields have
been largely due to breeding shorter, high harvest index
wheats that respond to increased fertilization, and/or grow-
ing long season winter wheats that continue growing in the
field for ca. 10 mo. Cultivating such wheats requires her-
bicides to suppress weeds, as weeds compete with the
newer, shorter, wheat cultivars, or come up and compete
in spring in the winter wheats. For over 40 yr, 2,4-D
controlled many broadleaf weeds, with a variety of hert)i-
cides providing a modicum of grass control. Postemer-
gence application of 2.4-D has short soil persistence and
often allowed a flush of susceptible weeds to go to seed
either before application, or after the herbicide dissipated.
By letting susceptible weed seed persist in the seed bank,
selection pressure for resistance has remained low. With
the exception of a recent minor case (85), this low selection
pressure may explain in part why no major outbreaks of
2,4-D resistant weeds have been reported.
The advent of highly persistent sulfonylurea herbi-
cides such as chloreulfuron and the slightly less pereistent
meisuifuron {2-[[[[(4-methoxy-6-methyl-l,3,5-triazin-2-
yl)aminojcarbonyl]aminolsulfonyl]benzoic acid| pro-
vitted high levels of control for a broad spectnim of weeds,
including some grasses. The users realized superior weed
control (though not always higher yields) and competitive
pricing brought about rapid acceptance of chlorsulfuron.
Soon after registration on wheat in 1982, chlorsulfuron
replaced about 40% of the 2,4-D previously used in U.S.
winter wheat (3). By 1988 18.5% of the total area of the
U.S. winter wheat crop was treated with chlorsulfuron
(slightly more than 2 million ha) compared to 9.2% for
2,4-D (5). Target site resistance to chlorsulfuron rapidly
evolved after 4 or 5 yr of continuous use in biotypes of
prickly lettuce, kochia, and Russian thistle (Salsola iberica
Sennen & Pau # S ASKR) (73). The manufacturer of chlor-
sulfuron quickly came up with a series of resistance man-
agement strategies for affected areas (4, 6 1 ). The strategies
included; a) no preemergence, only postemergence use; b)
application no more than once in 4 yr; c) fallow use was
proscribed; and d) use at lower rates in tank mixes with
other herbicides. Recommendation.s a-c and use at lower
rates all decrease selection pressure forevolution of target-
site resistance and their utility is self-evident. The question
we address here is whether mixing less vulnerable herbi-
cides with chlorsulfuron and other ALS inhibitors will
affect ihe rate of evolution of resi.stance.
Two types of resistance to chlorsulfuron have appeared
in wheat; a) target site resistance with a modified ALS (24,
71. 72), and b) metabolic resistance characterized by a
greatly enhanced rate of degradation of the herbicide (24,
25, 27). Both types have even evolved in different biotypes
of the same weed (22).
All of the mixture partners proposed for chlorsulfuron
have much lower biological persistence than chlorsulfuron
(Table 6). They are dissipated within 4 to 6 wk of applica-
tion whereas chlorsulfuron provides season long control,
often lasting into following seasons, depending mainly on
soil pH (2 1 ). Thus, none of the proposed partners meets the
equal persistence criterion (except for weeds germinating
in a single flush). The persistence problem has partially
been met by the recent introduction of sulfonylureas with
much shorter persistence. Some may persist longer than
some of the mixing partners. Data are not available to
compare rales of degradation in the same soil under the
same conditions. In any case, the short-residual ALS-in-
hibitors introduced for winter wheat have not gained wide
acceptance and are applied on only 3 to 6% of planted area
(14).
Other sulfonylureas have been proposed as mixing part-
Volumc 8, Issue 3 (July-September) 1994
643
728
WRUBEL AND GRESSEL; ARE HERBICIDE MIXTURES USEFUL FOR DELAYING EVOLUTiON OF RESISTANCE ?
Table 6. Manufacturer's recommendations of hei1>icide mixtures with dllorsul'
furon for resistance management in winter wheat®.
Recommended
mixing
partner(s)^
Characteristics of mixing partner(s> for resistance
management of chiorsulfuron^
2,4-D
A short residual systemic herbicide. Timing of
application important fw effective control of kodiia
generally not as effective as chlorsulfuron. especially
throughout the season.
MeJribuzin
A short residua! postemergence herbicide. Cwt provide
good control for kochia but not throughout the season,
and prickly lettuce but not in all areas throughout the
season. Only partially controls Russian thistle.
MCPA
A short residual contact herbicide. Does n« erntroi
Russian thistle, kochia. or prickly lettuce as well as
chlorsulfuron and not throughout the season.
Bromoxynil
A short residual contact herbicide. At some locations can
give excelicrti control of kochia. although ikh throughout
(he season. At other locations it is rated not nearly as
effective as chlorsulfuron. Control of Russian thistle only
fair.
Bromoxynil
+ MCPA
Both are short residual contact herbicides. Will not
control kodiia. Russian dtislie. or prickly lettuce as well
as chlorsulfuron thrwighout the season.
Dicamba
A short residual, contact herbicide. Nca as effective as
chlorsulfuron for control of kochia throughout the .season.
Only fair control of Russian thistle.
2.4-D
4 clc^yraltd
Both are postcmergence systemic herbicides that
dissipate mc»e rapidly than chlorsulfuron. Clc^yralid
provides only partial conhol of kochia arnl Russian
thistle. Mixture docs not add to effectiveness of 2.4-D for
target weeds.
Diuron
Diuron has a much narrower weed spectrum compared to
chlorsulfuron. Kochia. prickly lettuce, and Russian thistle
are not as effectively controlled as with chlorsulfuron.
‘Mixing partner recommendations from (16),
'’Clopyralid, (3,6-dichl0rO'2>pyridinecarbox>'tic acid); diuron. A^-(3.4-di-
chlorqjhenyD-A'.Mdimethylurca).
‘^Evaluations from various sources in infested areas.
ners but this does not meet the “different target” criterion,
while some mixture partners (2,4-D, MCPA [(4-chloro-2*
methylphenoxy)acetic acid], dicamba, bromoxynil) meet
it. None of the mixing p^ners with different modes of
action have the same spectrum of weeds controlled over
the whole season (Table 6). Thus, weeds such as kochia,
prickly lettuce, and Russian thistle would often be biologi-
cally “unaw^e” of a mixture partner, so that major weeds
known to evolve resistance will continue to do so despite
the mixture. Still, the rate of evolution may be somewhat
dampened due to early season control by the vulnerable
herbicide.
'■*1. Gressel, L. Segel, and M. Mangel, manu^ript in preparation.
Evolution of metabolic resistance in weeds. The above
strategies for wheat and soybean/com almost solely ad-
dress the evolution of target site resistance. There is a
possibility that mixtures would not preclude the evolution
of metabolic resistance. This could be prevented in com or
soybean by using a partner that cannot be degraded by the
same enzyme type as degrades the ALS inhibitors. This is
not the case in wheat, where in all documented cases
herbicides are degraded by monooxygenases (34), unless
another metabolic degradation system is activated by a
protectant (68). If broadleaf weeds can evolve enhanced
degradation by monooxygenases as have grass weeds (25,
27, 5 1 ), then there is reason to believe that the proposed
mixtures will be subject to evolution of a similar resistance.
Reducing application rates of herbicides in mixtures
lowers selection pressure for the evolution of target site
resistance and has probably enhanced the rate of evolution
of metabolic resistance, as has happened with insecticides
(SS).'"* Resistance derived from multiple genes or by gene
amplification can evolve quickly only if low rates are used,
which selects for incrementally added gene doses. Insects
and fungi have evolved metabolic pesticide resistances
under either polygenic control or due to gene amplification
(cf. 23, 67). Similarly, mammalian cancer cells have
evolved drug resistances that are also due to gene amplifi-
cation. Thus, the lower rates usable in mixture.^ of herbi-
cides can be expected to decrease the rale of evolution of
target site resistance and enhance the rate of metabolic
weed resistance (35).
Compliance with recommendations to use mixtures.
Assuming there were mixtures available that could manage
resistance, there Is nothing that now requires a farmer to
use them. Although the manufacturer of Imazethapyr is
strongly advocating mixtures for resistance management,
72% of the soybean farmers surveyed following the 1992
season indicated that they applied this herbicide alone and
not in mixture (Figure 2A). Twenty-three percent applied
imazethapyr with a grass herbicide as a complementary
mixing partner to increase the spectrum of weeds control-
led. rather than to control the weeds most likely to evolve
resistance. Only 5% of the farmers surveyed used a broad-
leaf mixing partner that might have some delaying effect
on the evolution of resistance in a weed like cocklebur.
In 1992, 29% of soybean farmers surveyed in Iowa and
Illinois (the two largest soybean producing states) reported
using imazaquin or imazethapyr alone or in combination
with ocher ALS inhibitors (Figure 2B). Thirty-nine percent
of fanners using the imidazolinones tank-mixed them with
644
Milume 8, Issue 3 (July-September) 1994
729
WffiDTKrHNOLOGY
Hi used alooe or wM sootier ALSiniubitor
□ grsss bcarladde or if brosdleaf does oot control cocklebor
^ herbictdetbstcoBaoiscocldebar
Figure 2. Usage of mixtures in soybean. A. The percentage of U.S. soybean
fanners, surveyed following the 1992 season, using imazethapyr alone, with a
grass herbicide, or with a broadleaf herbicide. Percentages arc based on 1069
soybean farmers that reported using imazethapyr <Hit of 7073 soybean fanners
surveyed. Source; (15). B. The percentage of soybean farmers in Iowa and
Illinois, surveyed following the 1992 season, using imazaqum <w imazethapyr
either alone, in tank-mix, or sequentially with other herbicides. Of the 1639
farmers surveyed in Iowa and Illinois, 48! (29..3^) used imazaquin or
imazethapyr. Source; (15).
a non-ALS inhibitor, while 37% used a sequential treat-
ment with a non-ALS inhibitor. Over 80% of farmers tank
mixing or sequentially mixing chose mixing partners that
can not control cocklebur (Figure 2B). The specific herbi-
cides used with the imidazolinones were similar whether
f^Ttiers used a tank mix or sequential applications. Sev-
enty-five percent of farmers using tank-mixes choose dini-
troaniline herbicides as the paitner, while 61% of farmers
used these herbicides in sequence with the imidazolinones.
The dinitroaniiines primarily control grass weeds and have
minimal activity on cocklebur. In only 15% of the cases
using tank-mixes and 19% of the sequential applications
were heibicides used that have high activity for cocklebur
(Figure 2B). These were all short residual herbicides, with
glyphosate being the most popular. In summary, very few
soybean farmers using imidazolinone herbicides are fol-
lowing the herbicide-resistance weed management mix-
ture recommendations of the manufacturers.
In winter wheat, chlorsulfuron has been removed from
market areas with the most severe resistance problems. In
areas where chlorsulfuron continues to be sold, many
farmers prefer it because of the weed free fields that result.
In 1992, 14% of total U.S. winter wheat area, or 42% of
the winter wheat area treated with herbicides, was treated
with chlorsulfuron. This accounted for slightly over 2
million ha, an area equal to that treated with 2,4-D (14).
An additional 7% of total winter wheat area was treated
with another long residual sulfonylurea, metsulfuron,
while two short residual sulfonylureas, thifensulfuron and
tribenuron { 2-[([[(4-melhoxy>6-methyl- 1 ,3,5-triazin-2-
yl)methylamino]carbonyl]amino]sulfonyl]benzoic acid},
were applied to 3 to 6% of planted area (14). Over 60% of
winter wheat growers surveyed after the 1992 season that
used herbicides applied at least one sulfonylurea herbicide
(15). Label requirements in wheat for mixing more highly
persistent sulfonylureas are often ignored, which has prob-
ably led to additional cases of resistance. Forty-six percent
of the farmers surveyed applying chlorsulfuron to winter
wheat in 1 992 used this herbicide alone or in tank mix with
metsulfuron, a sulfonylurea with only slightly less persist-
ence (Figure 3). There are also reports that many farmers
from areas where chlorosulfuron is proscribed purchase
the herbicide elsewhere.
Thus, it appears that companies believing that their
heibicides should be used in mixture for resistance man-
agement are having a difficult lime convincing farmers to
adopt this strategy. Based on present use patterns among
growers, manufacturers would have to market resistance-
prone herbicides only as premixes, to obtain compliance,
assuming satisfactory mixture partners for resistance man-
agement were identified.
\blume 8. Issue 3 (July-September) 1994
645
730
WRUBEL AND GRESSEL; ARE HERBICIM MIXTURES USEFUL FOR DELAYING EVOLUTION OF RESISTANCE?
100
;^80
i
<2 2
40
^ 00
u, .S
a> w> 20
•S
^ 0
1992
Figure 3. TTie percentage of winter wheat farmers surveyed following the 1992
season using chiorsuifuron alone, with another sulfonylurea herbicide, or with a
non-sulfonylurea herbicide. Percentages a-e based on M5 winter wheal farmers
who reported using chiorsuifuron out of 617 farmers surveyed who applied a
herbicide. Source; (15).
CONCLUDING REMARKS
While the proposed mixing strategies may have some
value for general weed control, the ones discussed do not
meet the criteria for resistance management in preventing
further evolution of resistant cocklebur or kochia as well
as other weeds with similar properties. Mixtures have
already broken down in Europe. Atrazine-resistant weeds
appeared when fenuron (A/,A^-dimethyl-A^-phenylurea), a
short residual herbicide, was used together with atrazine.
Initially, only half the populations were resistant due to
replenishment of susceptible plants from the seed bank.
Repeated use of the atrazinc-fenuron mixture enriched the
resistant population to near 100%.'^
Mixtures may theoretically be constructive tools for
managing resistance when they meet the criteria listed.
Still, it is questionable whether the problems of finding
partners with the proper efficacy and persistence along
with convincing farmers to use mixtures that increase costs
without immediate weed control benefits can be overcome.
If tenable mixtures could be found, they might have to be
marketed only as premixes, as is done with some vulner-
able fungicides. The herbicide mixtures presently recom-
mended do not seem to have the properties to prevent or in
'•^Armnon. H. U. 1994. Persona! communication. Swiss Fcikrral Res. Stn.-
Agronomy. Zurich-Reckenholz.
«)me cases significantly delay the evolution of resistant
weeds.
The possible lack of a major fitness difference between
ALS level resistant and susceptible biotypes also argues
for caution in use of these chemicals. We find it troubling
that herbicide mixtures are being represented by some as
a primary means to avoid or drastically delay ALS-inhibi-
tor resistance problems. We believe that the marketing
strategies leading to increased use of ALS-inhibiting her-
bicides, the development of imidazolinone-resistant com
cultivars and the development of other crop cultivars with
resistance at the level of ALS are together ill-founded. This
will likely result in even more widespread ALS-inhibitor
resistance in weeds, requiring drastic steps to remediate the
problem. The expansion of use of these herbicides, in the
long-term serves neither the interests of the chemical in-
dustry nor of the agricultural community, which depends
on industry. One must think beyond herbicides and short-
term economics to retain excellent but resistance-prone
chemistries such as the ALS inhibitors.
Now that ALS-resistant weeds have evolved in these
cropping systems, mixtures containing a few percent of
resistant and susceptible weed seeds can be used in con-
trolled experiments in the field to rapidly evaluate the
efficacy of various herbicide mixing strategies alongside
other management strategies. Such experiments can be
carried out in normally used cropping systems. This would
provide some real data to evaluate mixtures under field
conditions rather than relying too much on theoretical
considerations.
ACKNOWLEDGMENTS
The authors thank the many weed scientists in acade-
mia, extension, and industry who provided us with insights
and information, but the conclusions are our own and not
necessarily those of our colleagues. We thank W. Bar-
remine, P. Fay, M. Owen, L. Saari, and D. Shaner for useful
comments on an earlier version of this manuscript. J. G.
has the Gilbert de Botlon chair of Plant Sciences.
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Volume 8, Issue 3 (July-September) 1994
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Weed Technology. 2006, Volume 20:793-814
Reviews ■■ , i 'aii iiisii
Herbicide-Resistant Weeds: Management Tactics and Practices'
HUGH J. BECKJE^
Abstract: In input-intensive cropping systems around the world, farnrers rarely proactively manage
weeds to prevent or delay the selection for herbicide resistance. Farmers usually increase the adoption
of integrated weed management practices only after herbicide resistance has evolved, although her-
bicides continue to be the dominant method of weed control. Intergroup herbicide resistance in
various weed species has been the main impetus for changes in management practices and adoption
of cropping systems that reduce selection for resistance. The effectiveness and adoption of lierbicide
and nonherbicide tactics and practices for the proactive and reactive management of herbicide-resis-
tant (HR) weeds are reviewed. Herbicide tactics include sequences and rotations, mixtures, appli-
cation rates, sile-specitic application, and use of HR crops. Nonherbicide weed-management practices
or nonselective herbicides applied preplant or in crop, integrated with less-frequent selective herbicide
use in diversified cropping systems, have mitigated the evolution, spread, and economic impact of
HR weeds.
Additional index words: Herbicide resistance, integrated weed management.
Abbreviations: ACCase, acelyl-CoA carboxylase; ALS, acetolaclate synthase; APR aryloxyphen-
oxypropionate; CHD, cyclohexanedione; DSS, decision-support system; EPSPS, enolpyruvylshiki-
mate-3-phosphate synthase; HR, herbicide resistant; HS, herbicide susceptible; IWM, integrated weed
management.
INTRODUCTION
The main risk factors for the evolution of HR weeds
are: (a) recurrent application of highly efficacious her-
bicides with the same site of action; (b) annual weed
species that occur at high population densities, are wide-
ly distributed, genetically variable, prolific seed produc-
ers, and have efficient gene (seed or pollen) dissemina-
tion; and (c) simple cropping systems that favor a few
dominant weed species (Owen 2001a; Thill and Lemerle
2001). Globally, the most economically important HR
weeds include rigid (annual) ryegrass (Ij?liwn rigiduin
Gaudin), wild oat (Avena fatua L.), Amaranthus spp.
(redroot pigweed, A. retrofiexus L.; smooth pigweed, A.
hybridus L.; common waterhemp, A. rudis Sauer; and
tall waterhemp, A. tuberculatus (Moq.) J.D. Sauer), com-
mon iambsquarlers {Chenopodium album L.), green fox-
tail [Seraria viridis (L.) Beauv.], barnyardgrass [Echin-
ochloa ents-galU (L.) Beauv.j, goosegrass {Eleusine
indica (L.) Gaertn.], kochia {Kochia scoparia (L.)
‘ Received for publication June 14. 2005, and in revised fram Dccendwr
13, 2005.
'Plant Scientist, Agriculture and Agri-Food Canada, Ssekaioon Research
Centre, i07 Science Place, Saskatoon, Saskatchewan. Canada S7N 0X2.
E-mail: beckieh^agrac-ca.
Schrad.], horseweed [Conzya canadensis (L.) Cronq.'j,
and blackgrass (Alopecurus myosuroides Huds.) (Heap
2005). For the majority of HR weed biolypes, herbicide
resistance is target-site based, conferred by a single, ma-
jor (i.e., large phenotypic effect) gene with a high degree
of dominance (Powles et al. 1997). This mode of inher-
itance favors the rapid evolution of weed resistance to
herbicides applied at registered rates.
In high-input cropping systems around the world,
farmers are reluctant to proactively manage weeds to
prevent or delay the selection for herbicide resistance.
The cost and effort of prevenling/delaying resistance to
many herbicides are widely perceived or estimated to be
the same as that of managing HR weeds, and therefore
farmers often do not change their weed management pro-
gram until resistance has occurred. The lack of proactive
management of the evolution of HR weed populations
may be due to farmers’ primary interest in optimizing
short-term economic returns, or inability to assess the
economic risks associated with HR weeds (Rottevee! et
al. 1997).
Low adoption of resistance-avoidance tactics may
also be due to the lack of alternative herbicide groups
(defined by site of action) to control the target weeds, or
793
734
BECKIE: HHlBlCiDE-RESISTA.NT WEED MANAGEMENT
Table I. Use of integrated weed management practices by Western Australian grain fanners in 2(XX) (n == 132) (adapted from Lkweliyn et al. 2004).
Practice^
HR*’
Parmer adoption
no HR
All
Expected efficacy
T
Stubble burning
85
66
76
47 •*- 19
Weed seed catching
10
2
7
.57 i 15
Tillage
49
49
46
39 S 22/49 i 21
Autumn tickle (prcplant tillage)
57
26
44
Delayed planting
53
35
46
55 ± 23
Double knock
62
49
57
64 ± 21
Crop lopping
44
11
30
62 ± 17
Green manuring
21
11
17
74 ± 19
Crop cut for hay
31
49
39
Spray topping
95
94
94
High wheat seeding rate
Trill uraiin^*
5?
54
56
28 ± 17/35 ± 19
67 ± 14
“ Double knock, crop topping, and spray topping tire the use of a ncmsclective herbicide apjrfied; preplant (followed by another nonselectivc herbicide or
tillage), to annual legumes at postanthesis weed growth stage, and to padres, respectively, to reduce weed seed production.
HR: fanners with herbicide resistance (n = 77) vs. no resistance (n ~ 55).
'■ Efficacy expected by farmers for rigid ryegrass (Lolium ri$idnm Gaudin) control ± standard deviation; tillage, high seeding rate; difference among nonusers
and users, respectively.
^ included for comparison.
unrealistic expectations that new herbicide technology
will continually be forthcoming (Llewellyn et al. 2002).
However, herbicides should be viewed as a nonrenew-
able resource. With the cost of discovering, developing,
and marketing a novel herbicide at approximately United
States (U.S.) $150 to $180 million in 2005 (D. Porter,
personal communication), farmer cannot expect many
compounds with novel sites of action to be commer-
cialized in the near future.
Additionally, a lack of information on the impact of
management tactics and practices on selection of herbi-
cide resistance may limit a farmer’s ability to delay re-
sistance. How long herbicide resistance can be delayed
by implementing a comprehensive Integrated weed-man-
agement (FWM) program is uncertain. Moreover, rec-
ommendations to farmers to delay or prevent herbicide
resistance are often similar to those recommended for
managing resistance, thus discouraging the adoption of
prevention tactics. Socioeconomic factors in developed
countries, such as farmer demographics, increasing size
of farms with concomitant limited labor and time avail-
ability, high percentage of leased land by renters with a
general lack of awareness of previous herbicide history
or reduced motivation for long-term stewardship, and
preference for annual cropping systems based on life-
style choice and cash flow, reinforces a heavy reliance
on herbicides as the dominant method of weed control
(Friesen et al. 2000).
Farmers usually increase the adoption of IWM prac-
tices only after herbicide resistance has evolved (Beckie
and Gill, 2006). Populations of a number of HR grass
weed biotypes threaten cereal grain production in differ-
ent areas of the world. Cross-resistance (a single resis-
tance mechanism conferred by one or more genes) and
multiple resistance (two or more resistance mechanisms)
in weed species have often been the main impetus for
the utilization of a greater number of IWM practices in
cropping systems (Powles et al 1997, 2000). For ex-
ample, farmers in Western Australia with infesttaions of
HR rigid ryegrass practice weed seed catching at harvest
more frequently than those with no resistance (Table 1).
Farmers with resistance used an average of 8.4 IWM
practices, significantly more than farmers with no resis-
tance (mean of 6.6) (Llewellyn et al. 2004).
Prevention can cost significantly less than dealing with
resistance once it fully develops, where intergroup her-
bicide resi.siance occurs, or where few alternative her-
bicides are available (Orson 1999). The greatest direct
cost of herbicide resistance to the farmer can occur dur-
ing the first year of poor weed control and consequent
yield loss (Peterson 1999). Populations of weeds with
high fecundity potential, such as rigid ryegrass, can in-
crease rapidly after control failures caused by resistance.
To manage resistance, farmers first use alternative her-
bicides (i.e., addition of a tank-mix partner or rotating
to a herbicide with a different site of action). In some
situations, herbicides that selected for resistance may
continue to be used because of their cost-effective (i.e.,
economical) control of non-HR weed species (e.g., tri-
azines or glyphosate applied to land with triazine- or
glyphosate-HR biotypes, respectively). The addition of a
herbicide to control the HR weed biotype, however, will
794
Volume 20. Issue 3 (Juiy-September) 2006
735
WEK) TECHNOLOGY
increase costs to the farmer (Peterson 1999). The short-
term cost of resistance is minimal if alternative herbi-
cides are available, such as those for control of many
biotypes resistant to phenoxy or photosystem I-disrupt-
ing herbicides (Beckie et al. 2001b). In contrast, there
may be a limited number of herbicide options for control
of some intergroup-HR biotypes, and those that are
available usually increase costs. For example, most or
all alternative herbicides to control intergroup-HR bio-
types of wild oat or green foxtail in the northern Great
Plains increase costs to farmers (Beckie et al. 1999b,
1999c). Management of giyphosate-HR horseweed in
conservation-tillage systems in the North Delta region of
the United States requires a phenoxy herbicide and one
or two residual herbicides. As a consequence of this ad-
ditional herbicide cost (U.S. S16 to S62/ha), conserva-
tion tillage has dropped by about 50% in cotton (Gos~
sypium hirsutum L.) and 30% overall (Steckel et al.
2005).
The prime strategy for managing herbicide resistance
in weeds is to reduce the selection pressure for resistance
evolution by any one selecting agent, while maintaining
adequate weed control. Selection pressure has the great-
est impact on herbicide-resistance evolution and is a fac-
tor that farmers can control. Selection pressure imposed
by a herbicide is the product of selection intensity (ef-
ficacy) and selection duration (persistence in soil) (Put-
wain 1982). Herbicides applied in crop generally result
in the greatest selection pressure compared with other
application timings. Selection pressure against a weed
population over time, resulting in increasing frequency
of HR individuals that collectively pos.sess one or more
resistance mechanisms, is a function of frequency of ap-
plication. Mathematically, the relative selection pressure
of a herbicide on a target weed species in a population
has been defined a.s the proportion of HR plants divided
by the proportion of herbicide-susceptible (HS) plants
that remain after exposure to the herbicide (Gressel and
Segel 1982). These proportions are equal to one minus
the effective kill, defined by seed yield reduction (Beckie
and Morrison 1993; Gressel and Scgel 1982). For ex-
ample, if seed production of HR and HS biotypes is re-
duced by 42 and 99%, respectively, relative selection
pressure is estimated to be (1 — ().42)/(I — 0.99) =
(0.58)7(0.01) = 58. By definition, the selection pressure
can only be reduced by lowering the effective kill of HS
plants or increasing the effective kill of HR plants. No
selection pressure is exerted when HS and HR genotypes
are controlled equally. Diversification of selection pres-
sures on weed populations, such as varying the type and
timing of herbicide application (e.g., selective or non-
selective herbicides applied preplant, in crop, preharvest,
or postharvest), integrating cultural or mechanical weed
management practices with reduced herbicide use, and
divereifying the cropping system as a whole, is required
to reduce the selection pressure of any one selecting
agent (Boerboom 1999).
In this review, tactics and practices to effectively de-
lay or manage HR weeds in input-intensive cropping
systems worldwide are summarized. Herbicide-based
tactics are emphasized, because herbicides will continue
to be the dominant weed-control tool in these cropping
systems during the forseeable future. Nonherbicide tac-
tics and practices that have been proven effective in
managing HR weeds are outlined. Examples are provid-
ed to illustrate the impact of herbicide and nonherbicide
tactics on the successful proactive and reactive manage-
ment of HR weeds.
HERBICIDE TACTICS
A herbicide .sequence is defined as two or more ap-
plications of herbicides with different sites of action
within one crop, whereas herbicide rotation is the appli-
cation of herbicides with different sites of action to mul-
tiple crops over multiple growing seasons in a field. Her-
bicide sequences, rotations, or mixtures generally have
the greatest effect in delaying resistance when the mech-
anism conferring resistance is target-site based, the target
weed species are highly self-pollinated, and seed spread
is restricted (Beckie et al. 2001b; Wrubel and Gressel
1994). Multiple resistance can evolve within a weed pop-
ulation through a change in selection history (usually
sequential selection), through selection of multiple
mechanisms by a single herbicide, or through outcross-
ing among individuals containing different resistance
mechanisms (Hall et a!. 1994; Preston and Maliory-
Smith 2001). Based on a compounded resistance fre-
quency model, the probability of HR mutants with mul-
tiple mechanisms of resistance (target-site based) in an
unselccted population is the product of the probabilities
of resistance to each affected herbicide site of action and
thus is rare (Wrubel and Gressel 1994). However, fre-
quent use of herbicides in a field over time can enrich
HR populations with different resistance mechanisms.
Outcrossing among plants, such as Lolium spp. or black-
grass, in close proximity that possess different HR mech-
anisms can result in multiple-HR progeny. Spreading HR
seed within and among fields can also aid this process.
Volume 20, issue 3 (Juiy-September) 2006
795
736
BECKIE: HERBICHM- RESISTANT WEED MANAGEMENT
Herbicide Sequences and Rotations. Adoption. Perfor-
mance and cost of herbicides usually rank higher than
site of action when farmers select a herbicide. The lack
of suitable herbicide options associated with crop rota-
tion can be an impediment to herbicide group rotation
(Bourgeois et al. 1997b; Legere et al. 2000). The level
of adoption of herbicide group rotation for resistance
management has increased markedly during the past de-
cade in Canada and Australia. There is little information
on the adoption of this tactic in other countries. In west-
ern Canada in 1 998, fewer than 50% of farmers practiced
herbicide group rotation, even though awareness was
high (Beckie et al. 1999a). By 2003, 70 (Saskatchewan)
to 90% (Manitoba) of farmers claimed to rotate herbi-
cides by site of action (H. Beckie, unpublished data). In
2005, over half of the herbicide products sold in Canada
had resistance management labeling, which includes
group identification symbols on the label and guidelines
for resistance management tactics in the use directions
(N. Malik, personal communication). The guidelines
were a joint effort between the Pest Management Reg-
ulatory Agency (PMRA 1999) in Canada and the U.S.
Environmental Protection Agency (2001). By 1998 in
Australia, the adoption rate of herbicide group rotation
was 85%, attributed largely to site-of-action labeling on
herbicide containers (Shaner el al. 1999). It is the most
common heiticide resistance management tactic cited by
farmers in survey questionnaires conducted in Australia
(Shaner et al. 1999) and Canada (H. Beckie, unpublished
data). A prerequisite for herbicide group rotation Is keep-
ing field records of herbicides used each year. Software
packages of crop and herbicide rotation planners are
available in many jurisdictions, which facilitate record
keeping and can flag high-risk herbicide practices, such
as repealed use of herbicides with the same site of action.
Mitigating herbicide resistance risk. Evolution of target-
site resistance in weed biotypes is attributed to frequent
use of herbicides of the same site of action and their
propensity to select for HR biotypes (Beckie et al.
2001a; LeBaron and McFarland 1990). Knowledge of
resistance risk could be an incentive for farmers to prac-
tice herbicide sequences or rotations to delay the rate of
evolution of resistance. The ease of selection for HR
biotypes is governed by several factors. As de.scribed
previously, the selection pressure (efficacy and persis-
tence) imposed on the target weed species by a herbicide
is the most important factor affecting the rate of evolu-
tion of resistance. The slow evolution of resistance in
weed biotypes to phenoxy herbicides, first introduced in
1946, has been partially attributed to relatively low se-
lection pressure (Coupland 1994). Similarly, relatively
low efficacy of trifluralin, a dinitroaniline herbicide, on
rigid ryegrass has been cited as one reason for relatively
slow evolution of resistance (Table 1). In a 1998 Western
Australian field survey of rigid ryegrass, population den-
sities were unrelated to herbicide resistance, suggesting
the availability of alternative herbicides, particularly tri-
fluralin, to control HR rigid ryegrass (Llewellyn and
Powles2001).
Nonpersistent herbicides generally exert less selection
pressure than those that control successive flushes of ger-
minating weeds throughout the growing season. The
contribution of persistence to selection pressure, how-
ever, depends on timing of herbicide application and the
germination characteristics of the target species in a geo-
graphic region. The soil residual activity of herbicides
did not strongly influence selection pressure on wild oat
in a competitive crop (canola, Brassica napus L.) in
western Canada (Beckie and Holm 2002). The selection
pressure exerted on wild oat by residual herbicides was
the same as or lower than that of nonresidual herbicides.
In the relatively short growing season in the northern
Great Plains, few wild oat plants may emerge after post-
emergence application of a nonresidual herbicide and
produce viable seeds in a competitive crop. In other
agroecoregions, herbicide persistence in soil can have a
much greater effect on selection pressure.
Whereas a single mutation can confer resistance to
single site-of-action herbicides, multiple mutations with-
in a plant are often needed to confer resistance to her-
bicides with more than one site of action, such as chlor-
acetamide herbicides (Foes et al. 1998). As indicated
previously, individuals in an unselected population with
multiple mutations for resistance generally would be rare
(Preston and Mullory-Smith 2001; Wrubel and Gressel
1994). The frequency of HR alleles in unselected pop-
ulations defines the starting point for resistance evolu-
tion, and thus impacts the length of time for resistance
to evolve to noticeable levels. An unusually low rate of
mutation of the locus conferring resistance, or alterna-
tively few fit mutations, are speculated to contribute to
the slow evolution of resistance to phenoxys and other
herbicides, such as giyphosate (Gressel 1999; Jasieniuk
et al. 1995). Fit mutations are more probable for non-
competitive inhibitor's of target-site enzymes such as ace-
tyl-CoA carboxylase (ACCase, EC 6.4. 1.2) and aceto-
lactate synthase (ALS, EC 4.1.3.18), where the herbicide
binding site is different from the active site. The prob-
ability of finding an initial HR mutant in an unselcctcd
population increases with an increase in the number of
796
Volume 20, Issue 3 (iuly-September) 2006
737
WEED TECHNOLOGY
Figure I. Cliissificaiion of herbiciite site of action by risk of sclccticm for
targci'Sile resistance (high s 10; moderate = 11-20; tow >20 appiicati<His
(H. Beckic and L. Hall, unpublished data); “Other”: insufficient information
to definitively categorize as low or moderate risk. Numerical (Weed Sdetice
Society of America) and alphabetical (Herbicide Resistance Action Commit-
tee) herbicide groups are described in Mallory-Smith and Retzinger (2IKI3)
or Heap (200.5).
types of functional mutations (Murray et a1. 1996). There
are at least five different point mutations in each of the
ACCa^se and ALS target sites in HR weed biotypes, each
conferring a different cross-resistance pattern and level
of resistance (Dclyc and Michel 2005; Gressel 2002).
Indeed, the frequency of largel-site-based ALS inhibitor-
HR individuals in untreated populations of rigid ryegrass
was found to be relatively high, ranging from lO"’ to
10“'* (Preston and Powles 2002a). In contrast, most mu-
tations conferring resistance to glyphosate, a competitive
inhibitor of enolpynivylshikimate-3-phosphate synthase
(EPSPS, EC 2.5.1.19), and glufosinale, a competitive in-
hibitor of glutamine synthetase (EC 2.7.7.42), are be-
lieved to be lethal.
The risk of target-.site resistance, defined by the mean
number of applications before resistance is detected,
vaiies by herbicide group (Figure 1). This approach of
risk assessment assumes that a particular herbicide site
of action is effective for a set number of applications
before the onset of target-site resistance. The use of her-
bicide “shots” is appropriate in economic models and
farm-management decision aids (Diggle and Neve 2001 ).
Anecdotal information, namely, field histories of herbi-
cide use, usually is used for assessing the risk of select-
ing for resistance based on an herbicide’s site of action.
Only one long-term experiment has examined the effect
of frequency of herbicide use on the evolution of resis-
tance. In a large-plot field experiment conducted from
1979 to 1998, resistance in wild oat to triallate occurred
after 1 8 yr where the herbicide was applied annually in
Volume 20, Issue 3 (July-Scptctnbcr) 2006
continuous spring wheat {Triticum aesiivwn L.), but not
where it was applied 10 limes in a wheat-fallow rotation
over the same period (Beckie and Jana 2000).
It is widely agreed that ACCase and ALS inhibitor
herbicides pose a high risk for selecting HR biotypes
relative to herbicides from other groups (Deliow et al.
1997; Gressel 1997; Heap 1999; LeBaron and Mc-
Farland 1990; Monjardino et al. 2003). High-risk her-
bicides should be applied less often in sequences or ro-
tations than lower-risk herbicides. At a minimum, use of
high-risk herbicides in consecutive years in a field
should be avoided. In sequences, lower-risk, nonselec-
tive herbicides, such as photosystem-I electron diverters
(paraquat, diquat) or EPSPS inhibitor (glyphosate)
should be used preplant to reduce the number of weeds
selected with in-crop herbicides that pose a higher risk.
Ideally, high-risk herbicides should not be used in fields
with high weed densities, because the number of HR
mutants is proportional to population size (Jasieniuk et
al. 1996).
Nonselective herbicides, such as paraquat, are com-
monly applied at the postanthesis stage of rigid ryegrass
in annual legume (pulse) crops in Australia, referred to
as “crop lopping.” In Western Australia, four times as
many farmers with HR rigid ryegrass practice crop top-
ping than those with no resistance (Table 1). This prac-
tice can markedly reduce weed seed production (Gill and
Holmes 1997). In Australia, there has been wide adop-
tion of herbicide techniques to reduce seed production
to manage resistance in rigid ryegrass in both annual
legume crops and pa.siures ("spray topping”) (Table 1).
The Australian National Glyphosate Sustainability
Working Group (2005) recommends reducing the risk of
glyphosate resistance by rotating glyphosate with para-
quat for preplant weed control, or using a "double
knock” (or “double knockdown”) technique by follow-
ing in sequence a preplani glyphosate application with
tillage or a paraquat-based product (Weersink et al.
2005) (Table 1).
Trends discerned in the cross-resistance patterns of
weed species resistant to herbicides of the same site of
action may be used as a guide for strategic herbicide use.
Patterns of cross-resistance, however, cannot be accu-
rately predicted based on field histories of herbicide use.
Incidence of aryloxyphenoxypropionate (APP) resis-
tance in HR Avena spp. biotypes tends to be greater than
that of cyclohexanedione (CHD) resistance in many
countries (Beckie et al. 1999b, 1999c, 2002; Cocker et
al. 2000; Mansooji et a!. 1992; Seefeidt et al. 1994).
Thus, as a short-term tactic to manage ACCase target-
797
738
BECKIB; HERBICIDE-RESISTANT WEED MANAGEMENT
site resistance in populations of this species, CHDs may
have a higher probability of success. An apparently
widespread point mutation in the ACCase gene resulting
in an amino-acid change from isoleucine to leucine at
position 178! confers resistance to some APP and CHD
herbicides in several grass weed species (Delye et al.
2003; Kaundun and Windass 2004). In various grass
weed species, clethodim has often controlled ACCase
inhibitor-HR biotypes in dicot crops (Bradley and Ha-
good 2001). Apparently, the point mutation(s) that con-
fer(s) resistance to this herbicide occurs relatively infre-
quently.
Individuals in a population exposed to the same se-
lection pressure can exhibit different patterns of cross-
resistance, however, highlighting the probable short-term
success of this approach. Wild oat patches with different
cross-resistance patterns have been documented within a
field (Andrews cl al. 1998; Bourgeois ct al. 1997a). ALS
inhibitor resistance in a population of prostrate pigweed
{Amaranthus blltoides S. Wats.) in a field in Israel is
endowed by two point mutations, each conferring a dif-
ferent cross-resistance pattern (Sibony and Rubin 2003).
Allele-specific assays can delect different point muta-
tions (Delye et al. 2002; Kaundun and Windass 2004;
Siminszky et al. 2005). Such assays are being commer-
cialized to determine cross-resistance paiiems rapidly in
HR weed populations where resistance is target-site
based, providing farmers with the option of applying an
effective herbicide within the same growing season as
weed tissue samples are collected for testing.
Herbicide resistance is often attributed to a lack of
herbicide group rotation, that is, frequent or repealed use
of herbicides of the same site of action. However, there
is direct epidemiological evidence for the utility of her-
bicide group rotations in delaying the evolution of target-
site resistance. Examples where herbicide group rotation
has been credited in preventing or delaying resistance in
weeds include iriazine-HR weeds in North America (Ste-
phen.son et al. 1990), isoproturon-HR littleseed canary-
grass {Phalaris minor Retz.) in India (Singh et al. 1999),
ACCase inhibitor-HR wild oat in Canada (L6ghre ct al.
2000) and rigid ryegrass in Australia (Gill 1995), and
ALS inhibitor-HR common cocklebur {Xanthiwn stru-
marium L.) in the southern U.S. (Schmidt et al. 2004),
wild radish {Raphanus raphanistrum L.) in Australia
(Hashem et al. 2001a), paddy weed {Lindemia micran-
tha D.) in Japan (Iloh el al. 1999), and weeds in field
crops in Europe (Hartmann et al. 2000).
Intergroup herbicide resistance can be conferred by a
non-larget-sile mechanism, which commonly is en-
hanced metabolism (De Prado and Franco 2004). Met-
abolic resistance has been reported much more frequent-
ly in grass than broadleaf weeds (Werck-Reichhart et al.
2000). Cases of weed resistance due to metabolic detox-
ification are more frequent than those attributed to target-
site mutation in U.K. populations of blackgrass, Avena
spp., and Italian ryegrass (Lolium multifiorum Lam.) re-
sistant to ACCase inhibitors or other heihicides; in Eu-
ropean populations of blackgrass resistant to ACCase in-
hibitors, ALS inhibitors, or chiortoluron; and in Euro-
pean populations of grass species resistant to ALS in-
hibitors (Claude et al. 2004; Marshall and Moss 2004;
Moss et al. 2003). Metabolism-based resistance to her-
bicides of different sites of action will clearly limit the
effectiveness of herbicide group rotation as a tool to de-
lay the evolution of herbicide resistance. Testing popu-
lations to determine herbicide resistance patterns is even
more important where intergroup resistance is suspected
and will help identify remaining herbicide options for
farmers (Beckie et al. 2000).
Herbicides that are not readily metabolized in weeds
are less likely to select for metabolism-based resistance.
For example, the low incidence of dinitroaniline (e.g.,
trifluralin) resistance may be due to the paucity of de-
toxification mechanisms in target plants (Holt et al.
1993). Sulfometuron and imazapyr are slowly metabo-
lized in plants and have been usetl to discriminate be-
tween target-site and metabolic resistance in rigid rye-
grass (Boutsalis and Powles 1995; Preston and Powles
2002b). Two major enyzme systems have been impli-
cated in herbicide resistance due to increased detoxifi-
cation — cytochrome P450 monooxygenases and gluta-
thione i'-iransferases (Table 2). These detoxification sys-
tems are expressed both constitutively and induced
(upregulated) in response to herbicide safeners. Studies
of the inheritance of cytochrome P450 raonooxygenase-
dependent resistance in weeds have shown that a single
gene can endow cross-resistance to herbicides of differ-
ent sites of action applied at registered rates (Lelouz6
and Gasquez 2001; Preston 2004). Cross-resistance can
frequently occur between ACCase and ALS inhibitors,
or between photosystem-II inhibitors and ACCase inhib-
itors (Preston 2004). However, different patterns of
cross-resistance can occur in different species (Preston
and Maliory-Smith 2001).
Herbicides used in sequences or rotations that are de-
toxified via pathways different from these two enzyme
systems, or that are slowly or not metabolized (e.g., gly-
phosate, glufosinate, paraquat), will reduce the risk of
selecting for metabolism-based, intergroup-HR weed
798
Volume 20, Issue 3 (July-Septeraber) 2006
739
WEED TECHNCH^Y
Table 2. Herbicides metaboLized by cytochrome P450 rncKiooJ!yg«i^es (P450s) ot glut^ione 5-transferases (GSTs) in herbicide-resistant weed biotypes.
Species
P450s
GSTk
Hai>icide
Chemical
class*
Reference
Rigid ryegrass {LoHutn rigidiim Gaudin)
X
Simaane
TCazine
Burnet et al. (1993a)
X
CMoitoluroD
Urea
Burnet et al. (1993b)
X
Chlomilfuron
SU
Christopher et al. (1994)
X
Wclofqp
APP
Preslon el al. (1996)
X
INindintethalin
Diniiroanitine
Tardif and Powles (1999)
Isalian ryegrass (Lolhm muhiflorum Lam.)
X
Chlorsuiairon
SU
Bravin et al. (2004)
Biackgrass {Alopecunts mvosuroides Huds.)
X
ChlOTOtoiuron
Urea
Kemp et al. (1990)
X
tsopFoturoQ
Urea
Kemp et al. (1990)
X
Kclofop
APP
Menendez and De Prado (1996)
X
Fenoxapre^P
APP
Cummins et al. (1997)
X
Foioxaprop-P
APP
Letouze and Gasquez (2001)
X
Fhipv^tilfiircHi
SU
Letouze and Gasquez (2003)
X
Isc^roturtm
Urea
l.etouze and Gasquez (2003)
X
Chlorproturon
Urea
Letoiiz^ and Gasquez (2003)
X
Haloxyf<^
APP
Letouz^ and Gasquez (2003)
X
Ciodinafop
APP
Letouze and Gasquez (2003)
Slerile oat (Ave«a sterilis L.)
X
Diclofc^
APP
Maneechofe et al. (1997)
Littieseed canarygrass (Pbalaris minor Retz.)
X
k<^(»uron
Urea
Singh cl al. (1998)
Foxtail (Setaria) spp.
X
Atrazine
Triazine
Dc Prado et al. (1999)
Late watergra.ss [Echinochlott phvllopogon
(Stapf) Koss.}
X
Bi^yribac
PTB
Fischer eS al. (2000)
Downy brome (Bromus leclorum L.)
X
lYopoxycarbazone*’
SCT
Park et al. (2004)
Large crabgtass [Digitaria sangtiiiuilis
(L.) Scop-i
X
Imazethapyr
IMl
Hidayat and Preston (2001)
Common ehickweed [Stellaria media (L.) Vi]|.|
X
Mecoprop
Phenoxy
Coupland cl ai. (1990)
Velvetieaf (Ahuiiiem theophrasti Medicus)
X
Atrazine
Triazine
Anderson and Gronwald (I99J)
Wild mustard (Sinapis ar\'emis L.)
X
EthameKulfumn
SU
VeidhuLs et al. (2000)
Annual sowthistle (.Sonchiis oleraceiis L.)
X
Simazine
IViazine
Fraga and Tasende (2003)
* Abbreviations: APR aryloxyphetuixypropionaic; IMf, imidazoHnone; PTB, pyrimidinyhhiobcnzoate; SCR sulfonylamino-carbonyltriaztilinone; SU, stilfoiiyl-
*• Proposed naine. Chemical name; methyl 2(il4-tnethyl-3-oxo-3-pfopoxy-4.5-dihydro-lW-l,2.4-iriazo!-l-yI)carbonyl]amino)sulfony1)bcn2oatesodium salt.
biotypes. Most cases of cross-resistance across herbicide
sites of action have occurred through the use of wheat-
selective herbicides (Hidayat and Preston 2001). Thus,
herbicides not selective in wheat, such as sethoxydim or
clethodim, and nonselective herbicides used in HR crops,
such as glyphosate or glufosinate, will be important tools
for managing metabolic resistance in grass weed bio-
types in the future.
Herbicide-Resistant Crops: A Double-Edged Sword.
Adoption of HR crops is driven primarily by easier and
improved weed control or higher net returns (Burnside
1992; Devine and Buth 2001). Cultivation of such crops
will increasingly influence future herbicide-use patterns.
Globally, resistance to nonselective herbicides (i.e., gly-
phosate, glufosinate) is the dominant type of transgenic
crop (72%, stacked traits excluded), and cultivated area
has continued to expand since 1995 (Table 3). HR soy-
bean [Glycine max (L.) Mem] comprises the largest area
at 48.4 million ha or 60% of tlie area planted to trans-
genic crops. Other important iransgenic-HR crops in-
clude com (Zefl mays L.) (10% by area), cotton (about
6%), and canola (6%). Worldwide, 56% of soybean, 19%
Volume 20, Issue 3 (July-September) 20^
of canola, 15% of cotton, and 6% of com planted in
2004 were tr^sgenic-HR cultivars.
The judicious use of HR crops can slow the selection
of HR weeds by increasing hert)icide rotation options,
such as the substitution of high-risk herbicides with low-
er-risk products. Nonselective herbicides used in HR
crops in North America have been a powerful tool to
proactively and ^actively manage HR weeds, such as
those resistant to high-risk herbicides, including ACCa.se
and ALS inhibitors (Beckie et al. 2006). As a result, the
potential economic impact of these HR weeds has been
diminished. However, frequent use of HR crops in crop-
ping systems, resulting in recurrent application of her-
bicides of the same site of action, may select for new
HR weed biotypes or augment the selection that has oc-
curred previously. Evolved weed resistance through se-
lection pressure in HR crops generally poses a greater
risk than evolved resistance in related weed species
through gene flow because frequency of interspecific hy-
bridization and subsequent introgression is often low
(Beckie et al. 2001c; Warwick et al. 1999, 2004). No-
table exceptions may include gene flow from HR canola
to bird’s rapa'field mustard {Brassica rapa L.) in eastern
799
740
BECKIE: HERBICIDE-RESISTANT WEED MANAGEMENT
Table 3. Transgenic" crops grown in 2003 and 2004, listed by counhy, trait,
and crop (adapted from James 2003. 2004).
2003
2004
ha X ICr
%
ha X 10^
%
By country:
United States
42.8
63
47.6
59
Argentina
13.9
21
16.2
20
Canada
4.4
6
5.4
6
Brazil
.3.0
4
5.0
6
China
2,8
4
3.7
5
Paraguay
0
0
1.2
2
India
0.1
<1
0.5
1
South Africa
0.4
!
0.5
1
Oiher
0.3
<1
0.4
<1
Total countries
18
17
Total area
f>vn
81.0
By trait;
Herbicide re.sistance (HR)
49.7
73
58.6
72
Bt (Bacillus thiiringiensis)
12.2
18
15.6
19
HR + Bt
.0.8
9
6.8
9
By crop;
Soybean [Gh^iite max (L.) Merr.]"
41.4
61
48.4
«)
Coro (Zea mavs L.)‘
1.3.5
2.3
19.3
23
Cotton (Gossypium lursiUmn L,)^
7,2
ii
9.0
U
Canola (Brassica mpus L.)‘
3,6
5
4,3
6
■ fmidazoiinone-HR crops excluded.
*■ All HR,
' HR =•• 6.4 miiiion ha {9%) in 2003 and 8.1 miiHon ha (10%) in 2004.
'' HR = 4.1 million ha (6%) in 2003 (data not available for 2{K)4).
' All HR.
Canada (Warwick et al. 2003), HR wheat to jointed goat-
grass (Aegilops cylindrica Host) in the western United
Stales (Hanson et al. 2005; Seefeldt et al. 199S: Zemetra
et at. 1998), and HR rice {Oryza sativa L.) to red rice
(O. sativa L.) in the Americas (Gealy et al. 2003).
Potential impact of HR crops on selection for weed
resistance is largely dependent on the size and intensity
of the cropped area in an agricultural region and the
herbicide site of action. Occurrence of glufosinate-HR
weeds has not been reported. There are relatively few
reports of weeds resistant to photosynthesis inhibitors at
photosystem II (benzonitriles) (Heap 2005). The largest
class of HR weeds worldwide are those resistant to ALS
inhibitors. The use of ALS inhibitor herbicides in imi-
dazolinone-HR crops will continue the selection for ALS
inhibitor-HR broadleaf and grass weeds. Unless imida-
zolinone-HR crops and ALS inhibitor herfjicides are
used wisely, their commercial success will be limited.
Since the introduction of glyphosate-HR crops in the
mid-1990s, several weed species resistant to the hert>i-
cide have been reported (Heap 2005). The majority of
glyphosate-HR biotypes were not a consequence of gly-
phosate selection pressure in HR field crop production
systems, but in orchards and vineyards, roadsides, or
non-HR crops (e.g., preplant, preharvest, or postharvest).
- ■ A or B used alone
A in rotation
B in rotation
-«-• A & 8 In mixture
Figure 2. Predicted evolution of herbicide resistance (dominant inheritance)
in an outcrossing weed species following repeated selection with heibicides
A and B used atone, in a rotation, or in a mixture (adapted from Powics et
al. 1997).
To date since 2000, however, evolution of three gly-
phosate-HR biotypes has been linked to glyphosate-HR
cropping systems in the United States. In various regions
of the United Slates, sequential in-sea.son applications
combined with near glyphosate-HR soybean monocul-
ture (or glyphosate-HR cotton) have contributed to the
evolution of glyphosate-HR horseweed across a large
area in more than 10 states, glyphosate-HR common rag-
weed {Ambrosia artemisUfoUa L.) in Missouri, and gly-
phosale-HR Palmer amaranth (Aimranthus pahneri S.
Wats.) in Georgia (Heap 2005). Such practices create an
intense selection pressure for weed resistance and jeop-
ardize the future utility of this important herbicide. Giv-
en the importance of glyphosatc in reduced-tillage crop-
ping, monoculture glyphosate-HR crops and multiple in-
crop glyphosate applications should be dissuaded. The
inexpensive cost of glyphosate relative to total variable
costs and its lack of soil residua! activity are disincen-
tives for a reduction in herbicide-use intensity. Never-
theless, greater implementation of IWM practices in gly-
phosate-HR crops, such as an intermediate (e.g., 38 cm)
rather than a wide (e.g., 76 cm) row spacing in soybean
(Chandler et ai. 2001), can reduce weed populations and
thus help reduce the real or perceived need for sequential
in-crop glyphosate applications.
Herbicide Mixtures. Based on the compounded rCvSis-
tance frequency model, herbicide mixtures are predicted
to delay resistance longer than rotations (Diggle et al.
2003; Powles et ai. 1997) (Figure 2). Field experiments
are being conducted to verify model predictions (H.
Beckie, unpublished data). Acceptance by farmers of
herbicide mixtures for resistance avoidance has been aid-
ed by cost-incentive programs from industry, formulated
mixtures (e.g., phenoxy plus an ALS inhibitor), and the
rapid evolution of resistance in specific cases. The her-
bicide combinations may be applied at lower individual
800
Volume 20. Issue 3 (Juiy-September) 2006
741
WEED TECHNCMLOGY
herbicide rates (Little and Tardif 2(X)5), especially when
interacting synergistically (Gressel 1990). A survey of
1,800 farmers in western Canada from 2001 to 2(W3 in-
dicated that a majority of them tank-mix herbicides to
delay or manage ALS inhibitor-HR broadleaf weeds (H.
Beckie, unpublished data).
If mixing partners of different sites of action do not
meet the criteria of similar efficacy and persistence, plus
different propensity for selecting for resistance in target
species, the effectiveness of mixtures for delaying target-
site resistance will be reduced. For example, a mixture
of an ALS inhibitor, chlorimuron, and metribuzin for
ALS inhibitor resistance management of common wa-
terhemp in the mid-western United States is not effective
because chlorimuron is more persistent than metribuzin
and common waterhemp has uneven and season-long
emergence (Sprague et al. 1997). Imazaquin applied with
pendimethalin did not delay imazaquin resistance in
smooth pigweed because pendimethalin did not ade-
quately control the species (Manley et al. 1998). Mix-
tures can inadvertently accelerate the evolution of mul-
tiple resistance if they fail to meet basic criteria for re-
sistance management and are applied repeatedly (Rubin
1991). A biotype of rigid ryegrass became resistant to a
mixture of amitrole and atrazine after 10 yr of wide-
spread and repeated use (Burnet et al. 1991). To effec-
tively delay metabolic resistance, the mixing partners
must be degraded via different biochemical pathways
(Wrubel and Gressel 1994). However, information on the
mode of degradation of herbicides in plants is not known
by farmers. Furthermore, mixtures to prevent or delay
metabolic resistance in grass weeds, where this mecha-
nism is most prevalent, may be cost-prohibitive unless
graminicide partners interact synergistically and can be
applied at lower rates.
Challenges to farmer adoption of mixtures for herbi-
cide resistance management include increased cost and
availability of suitable mixing partners that meet the cri-
teria outlined above. The inherent limitation of mixtures
in delaying target-site resistance is illustrated by the fol-
lowing example. The ALS inhibitor herbicide, thifensul-
furon plus tribenuron (formulated mixture), is popular
for controlling broadleaf weeds in cereal crops in die
northern Great Plains. The phenoxy herbicide, MCPA, is
registered as a tank mixture with this ALS inhibitor
(Anonymous 2005). Eleven weed species are controlled
by both mixing partners, including ball mustard {Neslia
paniculata (L.) Desv.], kochia, redroot pigweed, Russian
thistle (Salsola iberica Sennen & Pau), field pennycress
{Thlaspi afTense L.), and wild mustard (Sinapis arvensis
L.). TTiis mixture should markedly delay ALS inhibitor
target-site resistance in these species, particularly those
that are highly self-poilinaied, such as field pennycress.
MCPA poses a low risk for selecting for resistance (Fig-
ure 1), both mixing partners have short soil residual ac-
tivity, and MCPA is inexpensive. However, the rate of
MCPA used in the mixture may result in reduced effi-
cacy on some species, such as redroot pigweed and Rus-
sian thistle, compared with that of the ALS inhibitor her-
bicide. Moreover, common chickweed {SfeUaria media
(L-) Vill.] and common hempnettle (Gakopsis tetrahit
L.) are only controlled by the sulfonylurea herbicide.
Numerous ALS inhibitor-HR populations of these two
species have been reported.
Tliere is limited anecdotal evidence of the usefulness
of mixtures in herbicide-resistance management. Mix-
tures with ALS inhibitors have successfully delayed ALS
inhibilor resistance in weeds in rice in Japan and in field
crops in Europe (Gressel 1997; Itoh et al, 1999). Farmers
who included mixtures of herbicides with different sites
of action coupled with various cultural practices were
less likely to select ALS inhibitor-HR weed populations
(Shaner et al. 1997). Chenopodium and Amaranthus
spp., which often have evolved triazine resistance when
iriazines were used alone, rarely have been reported to
evolve resistance where atrazine plus chloracetainide
mixtures were used for over 20 yr in monoculture corn
in North America (Wrubel and Gressel 1994). Atrazine
is applied at a lower rate in this mixture, thus reducing
selection pressure. Pendimethalin is an effective mixing
partner (or when used in sequence) for propanil to delay
or manage propanil resistance in junglerice [Echinochloa
colona (L.) Link] in rice in Central America (Riches el
al. 1997; Valverde 1996).
Effective resistance management is realized by her-
bicide mixtures that result in synergistic effects. Some
carbamates and organophosphates competitively inhibit
aryl acylamidase (EC 3. 1.1. a), the enzyme responsible
for catalyzing propanil metabolism in rice and propanil-
HR junglerice. This inhibition can result in synergistic
effects. A formulation of propanil and piperophos, a
phosphoric herbicide, was first marketed in 1995 in Cos-
la Rica and cost-effectively controls propanil-HR jun-
glerice while achieving selectivity in rice (Valverde
1996; Valverde et al. 1999). Mixtures comprising a re-
duced rate of propanil and piperophos or anilofos are
now widely used in Costa Rica and Columbia (Valverde
et al, 2()()0). Similarly, mixtures of anilofos or pipero-
phos with propanil at various rate combinations syner-
gistically control propanil-HR bamyardgrass in rice in
Volume 20, Issue 3 (July-September) 2006
801
742
BECKIE: HERBICIDE-RESISTANT W^D MANAGEMENT
Table. 4. Propanil in combination with piperophos for selective contrd of
propanil-resistanl barnyardgrass in rice: additive (y\) or synergistic (S) effects
{adapted from Norsworlhy et al. 1999a).
Propanil
Piperophos
Weed control
Rice injury
.
0.83
0
33
0
0.11
43 A
0
0.33
42 A
0
1,0
56 A
0
3.0
63 S
1
IAS
0
53
0
O-Il
64 A
0
0.33
57 A
1
1.0
81 S
4
3.0
86 S
3
3.3
0
62
0
o.n
78 A
1
0.33
83 A
.3
1.0
96 S
3
3.0
93 S
4
6.6
0
81
0
0.11
92 A
3
0.33
94 A
5
1.0
99 A
$
3.0
98 A
7
LSD (O.O.S)
14
3
the southern United States with little or no crop injury
(Daou and Talbert 1999; Norsworlhy et al. 1999a,
1999b; Talbert et al. 2000) (Table 4).
Cafi herbicide rotations or mixtures exploit reduced fit-
ness of herbicide-resistant weeds and negative cross-re-
sistance? Reduced fitness of triazine-HR plants com-
pared with HS plants, documented frequently in the
1970s, resulted in optimistic predictions that this “cost
of resistance” would also be prevalent in biotypes resi.s-
tant to herbicides of other sites of action (Gressel and
Segel 1982). The target-site mutations conferring most
cases of triazine resistance reduce photosynthetic effi-
ciency, which is often manifested by decreased plant
productivity and competitiveness (i.e., reduced fitness).
Upon discontinuation of triazine herbicides, reduced fit-
ness of HR compared with HS biotypes was predicted
to reverse the evolution of resistance at a rate dependent
on the fitness differential between biotypes. Unfortu-
nately, reduced fitness of biotypes resistant to herbicides
of other sites of action has generally been minimal or
not detectable (Holt and Thill 1994). Lack of measurably
reduced fitness in HR biotypes has been infcired from
little decline in the proportion of HR:HS individuals
measured in fields over time after use of the selecting
herbicide was discontinued (Andrews and Monison
1997). For noncompetitive inhibitors of target-site en-
zymes, such as ACCase or ALS, the various sites of
mutations for resistance are not near the active site of
the enzyme and thus there is little fitness loss detectable
due to lower affinity lor the normal substrates (Gressel
1999; Wrubel and Gressel 1994).
Negative cross resistance, that is, HR plants are more
sensitive to a herbicide than HS plants, has been docu-
mented in several triazine-HR weed biotypes (Dabaan
and Garbutt 1997; Gadamski et ai. 2900; Jordon el al.
1999; Parks et al. 1996). Some herbicides that inhibit
photosyslem II bind more efficiently to the mutant tri-
azine binding domain than to the wild (HS) type. Tri-
azine-HR weeds frequently show negative cross resis-
tance to other photosystem-Il inhibitors, such as benta-
zon and pyridate; triazine-HR weeds can also exhibit
negmive cross resistance to herbicides that do not affect
photosystem II (Gadamski et al. 2000). Explanations for
this phenomenon depend on the specific herbicide, but
are largely speculative. The potential combined value of
negative cross-resistance and general lack of fitness of
triazine-HR biotypes In managing triazine resistance in
weeds worldwide has yet to be realized (Gadamski et al.
2000) . Nevertheless, pyridate is now mixed with triazine
herbicides and applied on millions of hectares annually,
especially in Europe, to control triazine-HR biotypes and
preserve the cost-effectiveness of this cla,ss of herbicides
(Gressel 2002). Negative cross resistance has also been
observed in non-triazine-HR biotypes. For example, an
Imidazolinone-HR smooth pigweed biotype was 10-foId
more sensitive to cloransulam, another ALS inhibitor,
compared with an HS biotype (Poston et al. 2001).
Herbicide Rates. Many herbicides are commonly ap-
plied at iess-than-registered rates to reduce costs. For
example, in-crop herbicides are applied at reduced rates
to 28% of cropped land annually in western Canada
(Leeson et al. 2004, 2006; Thomas et al. 2003). When
farmers apply herbicides at below-registered rates, it is
based primarily on their experience with a product’s per-
formance as affected by weed growth stage or environ-
mental conditions. They expect good weed control, al-
though they are aware of the increased risk of suboplimal
control. However, herbicide rate reduction without a cor-
responding reduction in efficacy will have no effect on
selection for resistance. Model simulations have sug-
gested that it is not profitable to reduce herbicide rales
to reduce selection pressure (efficacy or persistence) for
resistance, unless accompanied by a compensating in-
crease in nonherbicidal weed control (Diggle and Neve
2001) . The resulting increase in the abundance of HS
weed populations would reduce crop yield and quality
and increase weed seed return to the seed bank (Gord-
dard et al. 1996; Morrison and Friesen 1996).
Beckie and Kirkland (2003) examined the implication
802
Volume 20. Issue 3 (July-September) 2006
743
WEK) TECHNOLOGY
A B
Herbicide rate {proportion of recommended)
Figure 3. Implication of reduced herbicide rates on target-site reistance en-
richment in wild oat: percentage of ACCase inhibitor-resistant individuals in
seeds harvested after 4 yr of herbicide application at varying rates (A), and
resistant seedlings recruited from the seed biink after 4 yr for the recoin-
mentied (open circles) and high crop seeding rate (solid circles) treatments
(B) {reproduced from Beckie and Kirlcland (2003) by permissitm of the Weed
Science Society of America).
of reduced rates of ACCase inhibitors in a 4-yr diverse
crop rotation in conjunction with variable crop seeding
rates on the enrichment of HR (target-site based) wild
oat. As simulation models predict, reduced herbicide ef-
licacy decreased the proportion of HR individuals in the
population after 4 yr (Figure 3A). The high crop seeding
rate compensated for a one-third reduction in herbicide
rate by limiting total (HR plus HS) wild oat seed pro-
duction and by reducing the number of HR seedlings
recruited from the seed bank (Figure 3B). The study con-
cluded that the level of resistance in the seed bank can
be reduced without increasing the total seed bank pop-
ulation by manipulating agronomic practices to increase
crop competitiveness against wild oat when ACCase in-
hibitor rates are reduced.
Herbicides applied at registered rates can clearly select
for major gene (e.g., target-site) resistance, whereas ini-
tially, suboptimal herbicide rates may select for both ma-
jor and minor gene (i.e. quantitative) resistance. Evolu-
tion of quantitative resistance relies on outcrossing
among plants, resulting in incremental accumulation in
their progeny of minor genes with additive or multipli-
cative effects (Jaseniuk et al. 1996). Therefore, such her-
bicide resistance is most probable and would evolve
most rapidly in species such as blackgrass, rigid rye-
grass, and kochia. Quantitative resistance has been doc-
umented or postulated in HR weed populations such as
chlortoiuron-HR blackgrass in the United Kingdom (Ca-
van et ai. 1999; Chauvel and Gasquez 1994; Hall et al.
1994; Willis et al. 1997), diclofop-HR rigid ryegrass in
Australia (Gressel 1997; Neve and Powles 2005a, 2005b;
Preston and Powles 2002b), dicamba-HR kochia in
North America (Belles et al. 2CK)5; Cranston et al. 2001;
Dyer et al. 2000; Westra et al. 2000), and isoproturon-
Table J. Incren^nUii increase in (he level of resistance (resistance factor,
R/S), as mcaimred by the dose required to kill 50% of the population (LD,!,)
or reduce biomass by 50% (GR,u), of rigid ryegrass bioiype VLRl after two
or three cycles of selection with diclofop applied at subiethal doses (0,1 to 2
times the IX rate of 375 g ai/ha> under greenhouse conditions (adapted from
Neve and l^jwles 2005a).
Dicloft^ selection
regime (proportion
of 1 X rale)
R/S based on LD^o
R/S based on
Nontre^cd control
0.1, 0.2
7.4
6.7
0.1, 0.2, 0.5
n.8
16.3
0.1, 0.2, I
55.8
49.3
0.1. 0.5
10.9
6.4
0.1. 0.5, 2
40.1
20.4
HR litlleseed canarygrass in India (Kulshrestha et al.
1999; Malik and Singh 1995; Singh et al. 1998, 1999).
Less-than-recommended rates have been implicated or
speculated as the causal factor in herbicide resistance in
these biotypes. These species have a significantly or
highly outcrossing mating system, except !ittle.seed can-
arygrass (Malik et al. 1998).
A population of rigid ryegrass evolved resistance to
diclofop at the field-recommended rate when it was ex-
posed to two or three cycles of subiethal rates in the
greenhouse (Table 5). Similar results were found in a
greenhouse study of the effect of subiethal rates of di-
clofop on 31 previously nontreated populations of rigid
ryegrass (Neve and Powles 2005b). These results were
consistent with those of a previous epidemiological
study where levels of diclofop resistance in rigid rye-
grass populations were positively con'elated with the to-
tal amount of the herbicide applied over time and where
low rales relative to those applied in other countries were
typically used (Gressel 1997; Heap and Knight 1982).
Maxwell and Mortimer (1994) and Gressel (1997) sug-
gest that soil-residual herbicides may select for quanti-
tative resistance because late-emerging weeds are ex-
posed to lower herbicide doses that may allow accu-
mulation of HR alleles. However, the mechanism of re-
sistance to soil residual herbicides, such as triazines and
sulfonylureas, is often target-site (i.e., major gene) mu-
tation.
Gressel (1995) and Gardner et al. (1998) advocated a
tactic of revolving herbicide doses to delay the evolution
of major monogene (target site) and quantitative resis-
tance. Routine reduced-rate application that lowers effi-
cacy is not a good weed- or weed-resistance-manage-
ment tactic (Morrison and Friesen 1996). If suboptimal
rates are applied, nonherbicide methods to suppress
weed seed production should be employed. Clearly, her-
bicides should not be repeatedly applied at suboptimal
Volume 20. Issue 3 (Juiy-September) 2006
803
744
BECKIE: HERBICIDE-RESISTANT WEED MANAGEMENT
rates to significantly or highly outcrossing target weeds,
such as Lolium spp., blackgrass, and kochia, particuiarly
when they occur in large populations (Gressel 2002; Ja-
sieniuk et al. 1996).
Are there opportunities, however, to reduce rales with-
out significantly lowering herbicide efficacy? In the past,
registered rates were frequently based on the amount
needed to control the least-sensitive weed, whereas other
weeds on the product registration may be sensitive at
much lower rates. Thus, the selection pressure on these
very sensitive species can be extremely high. For ex-
ample, reduced but effective ALS inhibitor hert>icide
rates used to control common chickweed in Europe com-
pared with those used in North America doubled the time
for resistance evolution by reducing the lime those her-
bicides remain active in the soil (Beckie et al. 2001a;
Kudsk et al. 1995). Recent trends in herbicide regulation
and registration include more detailed information pro-
vided to users to adjust rales according to prevailing en-
vironment conditions and herbicide sensitivity, growth
stage, or population densities of the target species; a pri-
mary regulatory objective in many countries is to pro-
mote the application of products at minimum effective
doses (N. Malik, personal communication).
Site-Specific Herbicide Application. Site-specific man-
agement with the use of a global positioning system can
be useful in monitoring and managing HR weed patches
at early stages of development in a field over time. Un-
fortunately, most farmers in the northern Great Plains
fail to detect small HR patches (H. Beckie, unpublished
data). Comprehensive field scouting and HR weed patch
management after in-crop herbicide application are usu-
ally not performed because of either a lack of awareness
of the benefit of this practice or inconvenience due to
large farm size. A study conducted at a 64-ha no-till site
in western Canada assessed how preventing seed shed
from HR wild oat affected patch expansion over a 6-yr
period (Beckie et al. 2005). Area of treated patches in-
creased by 35%, whereas nontreaied patches increased
by 330% (Figure 4). Patch expansion was attributed
mainly to natural seed dispersal (nontreated) or seed
movement by equipment at time of planting (nontreated
and treated). Extensive (94 to 99%) seed shed from
plants in nontreated patches before harvest or control of
HR plants by alternative herbicides minimized seed
movement by the combine harvester. Although both
treated and nontreated patches were relatively stable over
time, this study demonstrated that preventing seed pro-
duction and shed in HR wild oat patches can markedly
slow the rate of patch expansion. Consequently, herbi-
Figurc 4. Patch tnana|enicnt of herbicide-resistant wild oat in a 6-yr exper-
iment in the northern Great Plains; a nontreated patch in 1997 and 2002 (A)
vs. seed shed prevented in a patch from 1997 to 2002 (B) ft and v axis in
mccers, ad^^tted from Beckie ct al. 200.5).
cide effectiveness in a field is extended in space and
time.
Sitc-specific herbicide application, utilizing weed
abundance as a basis for delineating application areas in
a field, would allow some reduction in the overall selec-
tion pressure. Costs of acquiring reliable weed-abun-
dance distribution maps and herbicide application have
limited its adoption by dry-land farmers growing rela-
tively low cash-value crops. The effect of precision her-
bicide application on the rale of evolution of resistance
would depend on the frequency of herbicide application
to specific areas of a field over time and the proportion
of the field treated each year. If application frequency of
herbicides to specific areas of a field (e.g., lower-slope
areas) is similar to conventional herbicide application,
HR gene (seed, pollen) flow from these field areas to
those treated less frequently may negate any potential
benefits of the technology. Furthermore, if these treated
areas contain the majority of the weed population present
in the field, then this tactic may still result in a selection
pressure similar to that of a blanket application.
Analogous to the refugia tactic in crops possessing the
Bacillus thuringknsis trait to mitigate insect resistance,
HS weed refuges has been proposed as a tactic to delay
the evolution of herbicide resistance. However, leaving
refugia of RS individuals to dilute the proportion of HR
alleles in a population by gene flow will not be effective
because the recessive control of resistance in outcrossing
weed species is rare (Jasieniuk el al. 1996). Additionally,
in cases of triazine resistance conferred by chloroplast
804
Volume 20. Issue 3 (July-Sepfeniber) 2006
745
WEED IBCHNCMXKjY
gene mutation, genetic recombination among plants does
not occur (Stankiewicz et al. 2001). The only docu-
mented case of recessive inheritance of major monogene
resistance in an outcrossing species was that of a piclo-
ram-HR yellow starthistle (Centaurea sohtitialis L.) bio-
type found in the state of Washington (Sabba el al. 2003;
Sterling et al. 2002).
INTEGRATING NONHERBICiDE TACTICS
WITH HERBICIDES
Minimizing weed seed production is central to both
HR and non-HR weed management programs. Cultural
or mechanical practices affect weed population densities
and seed production, and thus can delay the evolution of
herbicide resistance by reducing the number of HR al-
leles in a population. Where high levels of HR alleles
are believed to be present in unselected populations, such
as ALS inhibitor resistance in common waterhemp and
Palmer amaranth in North America (Peterson 1999) or
Lolium spp. in Europe and Australia (Dinelli et al. 2000;
Matthews and Powles 1992; Maxwell and Mortimer
1994; Preston and Powles 2002a), it is important to
maintain low population densities via nonchemicai meth-
ods or by using herbicides with a relatively low likeli-
hood to select for these HR alleles. This tactic is also
useful in fields where the high-risk ACCase and ALS
inhibitors have been used frequently for over 20 yr.
Many of these fields are likely well advanced along the
herbicide-resistance evolution curve.
Cultural or mechanical practices will only hall or re-
verse the rate of enrichment for herbicide resistance in
a weed population by eliminating selection pressure
(controlling HS and HR plants equally in the absence of
herbicide selection pressure) or controlling HR plants
more than HS plants, respectively. Nonherbicide practic-
es may increase the effective kill of HR plants relative
to that of HS plants in situations where differences exist
in the population dynamics of HR and HS biotypes.
Seeds of triallate-HR wild oat are generally less dormant
than those of HS populations (O'Donovan et al 1999).
Greater and more rapid emergence of HR individuals
compared with HS individuals, analogous to that of ALS
inhibitor-HR kochia biotypes (Dyer et al. 1993), may be
potentially exploited for selective HR biotype control by
tillage or nonselective herbicides before delayed plant-
ing. Similarly, triazine-HR black nightshade {Solanum
nigrum L.) in The Netherlands emerges earlier than HS
plants because of germination at lower soil temperatures
(Kremer and Lotz 1998). In contrast, early planting of
winter wheat in the Pacific northwest region of the Unit-
ed States can potentially reduce the competitive ability
of HR Italian ryegrass, which emerges later than HS in-
dividuals (Radosevich et al. 1997). Tillage to bury seeds
of an HR biotype of rigid ryegrass inhibited seedling
recruitment compared with that of an HS biotype (Vila-
Aiub et al 2005).
The issues of economic risk, labor availability, and
time management impact the adoption of some cultural
or mechanical practices for HR weed management.
Moreover, some practices such as stubble burning or in-
tensive tillage are contrary to recommendations to im-
prove soil or air quality or conserve soil, water, and en-
ergy, and thus their use is discouraged. Evolution of her-
bicide resistance in weed populations often has not re-
sulted in less herbicide use or a marked increase in
nonchemicai control methods, except in some cases such
as intergroup resistance in weeds (Powles et al 1997;
Preston and Mallory-Smith 2001) or glyphosate-HR
horseweed (Steckel et al. 2005). Used singly, the effec-
tiveness of nonherbicide practices is lower and less con-
sistent than that of many herbicides, and may be highly
dependent on environmental conditions; when used in
combination, however, nonherbicide practices can man-
age weeds effectively (Blackshaw et al. 2004; Gill and
Holmes 1997; Matthews 1994) (Table 6). Some nonher-
bicide tactics and practices that have proven effective in
managing HR weeds are summarized below.
Cropping Systems and Practices. Crop rotations are
dictated primarily by profit potenlial and not the man-
agement of HR weeds. Crop rotation, however, is fre-
quently cited as one of the most influential factors in
delaying or managing HR weeds (Bourgeois et al
1997b; Carey et al 1995; Chauvel el al 2001; Gill and
Holmes 1997; Hartmann el al 2000; Powles et al 1997;
Ritter and Menbere 1997; Shaner et al. 1999; Singh et
al 1999; Stephenson et al. 1990). Diversity in sequences
of crop types and phenologies in a rotation (i.e., dicots
vs. monocois; winter- vs. spring-planted; cool vs. warm
season; annual vs. perennial) may directly or indirectly
reduce weed populations. Crop rotations can facilitate
herbicide rotation or reduction (Beckie and Gill 2006).
A field study in the northern Great Plains linked ACCase
and ALS inhibitor resistance In wild oat to a lack of crop
rotation diversity (Beckie el al 2004). Inclusion of fall-
planted and perennial forage crops in annual spring crop-
based rotations effectively slowed the evolution of her-
bicide resistance in this weed species (Figure 5). A field
survey documented the ability of 3- to 6-yr alfalfa {Me-d-
icago saliva L.) stands to reduce wild oat populations in
cropping systems through crop competition and cutting
Volume 20. Issue 3 (July-September) 2006
805
746
BECKIE: HERBICIDE-RESISTANT WEED MANAGEMENT
Table. 6. Effect of cropping system on density of ACCasc ii^ibittH'-resistant biackgrass in the final year of an experiment in Burgundy, France (adaptett from
Chauvel ei al. 2001).
Crop rotation'
Tillage*’
Hanting date’^
Herbicide use*
Density
no./m-
WB-WW-WW
Chisel al!
Early
High
9-3
Moldboard all
Delayed
High
0-8
Chisel all
Delayed
Low
29
SB-SP-WW
Chisel all
Early
High
1.9
Chisel-chisei-moldboard
Delayed
High
0.3-1-4'
Chisel all
Delayed
Low
10
’’Winter barley-winter wheat-winter wheat (WB-WW— WW> vs. spring barley-spring pea-winter whciU (SB-SP-WW).
^ Tillage regime (plowing) after crop harvest.
' Relative to the local area.
^ Relative intensity of use of alternative herbicide.s.
' Split treatments consisting of postemergence nitrogen fertilizatiem al tow and iHsinal rates, respectively.
regime of the crop for hay (Oniinski et al. 1999). The
survey found that wild oat population densities were re-
duced by 96% in cereal fields that followed alfalfa versus
a cereal crop.
Traditionally, Australian agriculture was based on
crop-pasture rotation systems. A 3-yr pasture phase was
shown to be a low-economic-risk option (Gill and
Holmes 1997; Pearce and Holmes 1976). Rigid ryegrass
population density was reduced 88 to 96% in wheat fol-
lowing pasture grazed in the spring during the flowering
and reproduction stages of the weed (Pearce and Holmes
j
. Cont cereals
1 ‘ 1 '
• 1 ■ 1
« Gp2 herb.:Y-1 Gp2-HR
No crop rotation
No falKforage crops
Figure 5. Significant associations between ALS inhibitor-resistant wild oat
(Gp2-HR) and management practices in the northern Great Plains as deter-
mined from multiple correspondence analysis (Cent, cereals, continuous ce-
reals; R,t„ reduced tillage; Gp2 herb., ALS inhibitor used in current year; Gp2
herh.:Y-l, ALS inhibitor used 1 before; No crop rotation, ct(^ rolafion not
used; No fail/forage crops, fall-planted or forage crops itot used) (ttoapted
from Beckie et al 2004).
1976). The combination of grazing and nonselective her-
bicides (spray topping) reduces rigid ryegrass seed pro-
duction, resulting in a rapid and marked decline in weed
abundance (Gill and Holmes 1997). Preference for con-
tinuous annual cropping systems and poor economic re-
turns, however, have led to a decline in the widespread
inclusion of pastures in rotations (Monjardino et al.
2004).
The potential value of crop rotation to delay or man-
age HR weeds will not be realized unless accompanied
by diversification or reduction in herbicide use. Repealed
use of herbicides with the same site of action will negate
the weed-suppression benefits associated with crop ro-
tation. Crop rotations had little influence on occurrence
of ACCase inhibitor-HR wild oat In the northern Great
Plains because farmers frequently applied these herbi-
cides to cereal, oilseed, and annual legume crops that
dominate cropping sy.stems (Leg^re et al. 2000). Occur-
rence of resistance in wild oat was the lowest in rotations
where frequency of fallow was the highest because of
the reduced frequency of herbicide use. Similarly, de-
spite diversity in crop rotations in We.stem Australia, re-
peated triazine use in different crops selected for triazine
resistance in wild radish (Hashem et al. 2001b).
Inclusion of competitive crops and competitive culti-
vars of a crop in rotations is viewed by farmers as being
important in HR weed management (Bourgeois et al.
i997b; Shaner et al. 1999). Quantitative trait loci for
traits in wheat associated with weed competitiveness
have been identified. These markers can be used by crop
breeders to select for weed-competitive genotypes (Cole-
man el al. 2(X)1). However, crop competitiveness can
also be enhanced by increasing seeding rates. With the
widespread appearance of HR rigid ryegrass, many Aus-
tralian farmers are routinely increasing crop seeding
rates by 20 to 40%, resulting in greater plant densities.
806
Volume 20. Issue 3 (July-September) 2006
747
WEED TECHNOUXJY
to improve compelitiveiiess (Table 1) (Gil! and flolraes
1997: Medd ei al. 1987; Powles 19S)7). This practice is
most, cost effective for cereals. In the northern Great
Plains, increased crop seeding ndc is the most consistent
cuituraJ practice for managing weeds and maintaining
crop yields (Beckie and Kirkland 2(K)3; Blackshaw et al.
2004).
.Delayed, pianling is often promoted for the control of
some HR gra.ss weed species in Europe, such as winter
wild oat (/fvcrti? ludovidana Durieu), hood canarygrass
{Phalaris paradoxa L.), and blackgrass (Tabb 6, Chau-
vei et al. 2001; Orson 1999; Sattin et al. 2001), by de-
pleting the seed bank before crop planting. Delayed rice
planting in Central yVraerica is commonly used to reduce
1-LR jungierice populaliorx densities (Valverde el al. 20(X),
2001). in Australia, delayed crop planting has been in-
tcgiate<i with other control tactics to manage. I-iR rigid
ryegrass (Tabic 1) (Gill and Holmes 1997; Powles and
Matthews 1996).
Tillage Systems. Owen (200ib) reviewed the impact of
tillage and mechanical practices in managing HR weed
populiiLions. The judicious use of timely tillage has been
cited often as an importaiti practice to delay or manage
HR weeds (Bourgeous et al. 1997b; Chauvel et al. 21K)1;
Orson mid Livingslon 1987; Peterson 1999; Stephenson
et al. 1990). Tillage may substitute for herbicide use or
inlliieiice seed bunk dynamics. For example, plowing to
hiry weed seeds of blackgrass to reduce germination and
emergence has been proven highly effective for man-
agement of HR populations in Rtirope (Moss 1997; Or-
son and Livingston 1987). Timely tillage can also stim-
ulate weed germination before crop planting, such :is
“autumn tickle” (Table 1) (Boutsalis and Powles 1998:
Gill and Holmes 1997).
11^14 rhave fteqoeatty linked
heriricide 4i;l weeds'to.eanservation-tiDageSv^
tieia> jiartltaku-ly n«-tnK which ace increasiflgjv being
adopted by fhmterj-bccaijse ot cost and umeerftciencte’i
Ratification ot the Kvotn Protocol on greenhouse gas
emissions will tuither encourage Jamiers to adc*pl re-
duced-tillage systems through economic incentives to in-
crease carbon .sequc.stration in soil. In a field study by
Beckie et al. (2004), ALS inhibitor-HR wild oat was
associated wilii such systems (iigiire 5). Reduced tillage
substitutes herbicide ii.se for tillage to varying degree.s.
Reduced-tillage cropping can increase the abundance of
specific weed species and consequently, result in greater
herbicide use. However, an analy.sis of multiple studies
found little evidence that reduced tillage inci-eases her-
bicide use (Nazarko el al. 2005; Zhrsng el al. 2(KK}). in
the absence of tillage, weed .secdling.s may be derived
largely from seeds shed in the previous crop and con-
centrated near the soil surface. Consequently, there will
be little buffering against resistance evolulion from old
seeds, which may have greater percentage susceptibility
(Moss 2002).
LimUing Herbicide-Resistance Gene Spread. Gene
flow through pollen or seed movemejil fnsm HR w^eed
populations can provide a source of HR alleles in pre-
viously HS populatiorLS. Because rates of gene flow are
generally higher than rales of matation, the time required
to i^ach a high level of herbicide resistance in such sit-
uations is greatly reduced (Jaseniuk et al. 1996). It is
difficult to control the spiead of herbicide resistance via
pollen flow, espt'cially when resistance is often cjidowcd
by a single, dominant or .semidomitiant gene (Lctouze
and Ga-squez 1999; Richter and Powles 1993; Smeda el
al. 2000). For example, pollen of ALS inhibitor -HR ko-
chia can move more than .i0 m in a cropped field (Mal-
lory-Smiih el al. 1993), and ACCase inhibitor-TlR al-
leles in rigid ryegrass polleii can move more than 10 m
in cropped or noncropped conditions (Hawthorn-Jackson
el al. 2(K).3). Seed movement is probably responsible fur
the majority of gene flow in weed populations (Diggle
anti Neve 2001). Seed movement has the patential to
influence HR gone spread on. a much larger scale than
pollen flow.
HR weed seed spread within and among fields has
been documented (Andrews et al. 1998; Hidayat et al.
2094; Li et al. 2(X)0; Kilter and Meribere 1997; Stephen-
son el al. 1.990; Tsuji et al. 2003). Fields within farms
are more likely to have HR weeds than randomly picked
fields, indicating movement of HR seed between fields
via equipment (Anderson et al. 1 996) or similar selection
pressure among fields within a farm. Sharing of equip-
tncul among farmers ha.s also been implicated in herbi-
cide resistance (Debrcuil ct al. 1996). Weed seed spread
by machinery, noncomposled inunure, silage, or conlam-
inaied conitnercial seed slocks or feed (Ritter and Men-
bere. 1997; Stephenson et ai. 1990) is generally greater
tlian natural seed dispersal. For example, wild oat seeds
can spread more Uiaii 150 m by a combine harvester
(Shirtliffe ;uid Eni/, 200.5). Spread of herbicide resistance
among wild oat (Avena spp.) patches witliin 350 m of
each other has been documented in the United Kingdom
(Cavan e( al. 1998). Wind dispersal of weed species hav-
ing lightweight seeds, such as prickly lettuce (Ixictuca
serriola L.) (Rieger el al. 2001) and borseweed (Daucr
and Mortcnscu 2(K15: VanGessel 2001), can also spread
herbicide resistance rapidly. Wind can cflicicndy Srans-
Volunie 2;>. Isrn'.c 3 (July-Scptcmber) 2006
807
748
BECKiE: HERBICIM-RESISTANT WiaiD MANAGEMENT
Table 7. RIM {resistance and integrated management) model scentuios: Eranomit^ly t^mal freqtKnc^ of integrated weed management (IWM) practices when
selective herbicide use is restricted over a 10- year period,* and resulting plant d^ity of matoe rigid ryegrass in a lupin-wheat rotation (adapted from Pannel!
et al. 2004),
Optimal frequency of iWM practices''
herbicide
applicasion.s
High crop
seeding rates
Crop lopping'
Seed ciMching
Delayed planting +
glyphosaie
nonselective
treatments
Mature wei
density"
.
no./m^
iNU. ui over, a lo-yi — — — ■
no.
2
10
5
10
10
35
3
4
10
5
10
6
31
6
6
10
4
10
2
26
8
8
10
2
10
1
23
6
10
6
1
10
0
17
6
* Usage of ACCase- or ALS-inhibiting herbicides restricted fw proactive or reactive resistance management.
” Frequency of use of IWM practices resulting in greatest profitability over a 10-yr period for a given frequency of selective herbicide use.
' Lupin phase only.
'' 10-yr mean.
port kochia and Russian thistle tumbleweeds for long
distances (Mallory-Smith et al. 1993). As the incidence
of herbicide resistance increases in a region, pollen and
seed movement in addition to selection will increasingly
influence such occurrences.
Management practices that limit the spread of HR
seed can slow the occurrence of herbicide resistance. In
western Canada, farmers who reported practicing weed
sanitation (e.g., cleaning harvesting and tillage equip-
ment when moving between fields, covering the grain
truck box, mowing or spraying ditches or uncontrolled
weed patches, applying composted versus fresh manure)
were less likely to have HR wild oat than those who
were less careful (L^g^re et al. 2000). Cleaning equip-
ment when moving among fields, and mowing weed
patches, ditches, and headlands ranked fourth and fifth,
respectively, in importance among herbicide-resistance-
management practices cited by farmers in western Can-
ada (Bourgeois et al. 1997b). If the HR population cov-
ers a wide area across the field, management should fo-
cus on reducing seed return and spread by using low-
risk herbicides in conjunction with cultural practices,
such as cutting the crop (hay, silage, or green manure)
before or soon after flowering of the HR weed species,
growing competitive annual crops such as barley {Hor-
deum vulgare L.) or perennial crops, or collecting weed
seeds at harvest. Weed populations can decline rapidly
within one to two growing seasons for species having a
relatively short-lived seed bank, such as rigid ryegrass.
Capture of weed seeds during the harvest operation is
a technique used primarily by farmers dealing with her-
bicide resistance (Table 1). Some weed species, such as
rigid ryegrass, do not shed seeds until well after maturity
and therefore allow farmers the opportunity to collect
seeds during harvest. In Western Australia, Gill (1996)
reported a 60 to 80% removal of rigid ryegrass seeds,
which reduced weed infestation in the subsequent crop
by 73%. Although weed seed catching/removal at har-
vest is effective in managing HR weeds (Gill 1997; Gill
and Holmes 1997; Matthews 1994), farmer adoption is
low (Powles 1997; Shaner et al. 1999; Thill et al. 1994)
(Table 1). In contrast, weeds such as wild oat may shed
most seeds by cereal crop harvest in the northern Great
Plains. Therefore, harvesting after extensive seed shed
can reduce HR wild oat seed spread by equipment
(Beckie et al. 2005).
Decision-Support Systems. Use of a decision-support
system (DSS) can help farmers choose the best combi-
nation of IWM practices to delay or manage HR weeds
on their farm. The most advanced DSS to date is the
RIM (resistance and integrated management) model de-
veloped for IWM of single or multiple species in Aus-
tralia (Monjardino et al. 2003; Panned et al. 2004). It
allows farmers to quickly assess the agronomic and eco-
nomic performance of numerous combinations of man-
agement options over varying time frames (Table 7).
Such a DSS, when continually maintained and updated,
can be a useful tool for farmers to combat herbicide re-
sistance in weeds.
CONCLUSIONS
Proactive or reactive management for herbicide resis-
tance in weeds (a) must consider the relative risks of
herbicides of different sites of action to select for target-
site resistance and the differing propensity of herbicides
to be metabolized in HR biotypes when sequencing or
rotating herbicides; (b) must meet basic criteria for ef-
fective herbicide mixtures; and (c) should incorporate
Volume 20, Issue 3 (JuJy-Sepcember) 2006
749
WEED tk:hnology
agronomic practices in cropping systems that help reduce
weed seed production and spread. Use of low-risk, non-
selective herbicides applied preplant or in HR crops
improved HR weed management. However, frequent use
of HR crops such as those resistant to iinidazolinones or
glyphosate may maintain conditions that lead to resis-
tance, namely, simplified cropping systems favoring a
few dominant weed species and frequent use of single
site-of-action herbicides.
The extent to which farmers alter their current farming
systems to manage herbicide resistance depends on the
nature and magnitude of infestation of an HR biotype.
In many cases, simply switching to an alternative her-
bicide will cost-effectively control the HR population.
For serious herbicide resistance problems, for example,
heavy infestations of intergroup-HR weed species, a lon-
ger-term cropping systems approach may be required.
Approaches to IWM differ, depending on agroecological
conditions, biology, and ecology of the weed species
with evolved resistance, and agronomic and socioeco-
nomic considerations by farmers. Although herbicides
remain the dominant weed-control tool, diversification In
cropping systems and practices can result in less herbi-
cide used and thus a reduction in selection pressure for
resistance. Even serious weed-resistance problems can
be managed successfully if farmers are receptive to
changes in their cropping systems. The increasing inci-
dence and complexity of herbicide resistance in weeds
will inevitably require farming systems with a reduced
dependence on herbicides.
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814
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Congress of tlje ®ntteii States
S>ot!sc of i^rprcsciUatibrs
COMMITTEE ON OVERSIGHT AND GOVERNMENT REFORM
2157 Rayburn House Office BuiLOiNG
WASHtrrGTON. DC 20515-6143
October 15, 2010
The Honorable Jim Jones
Deputy Assistant Administrator
Office of Chemical Safety and Pollution Prevention
U.S. Environmental Protection Agency
1200 Pennsylvania Ave., N.W.
Washington, D.C. 20460
Dear Mr. Jones;
In connection with the September 30, 2010 hearing of the Domestic Policy Subcommittee,
entitled, “Are “Superweeds” an Outgrowth of l.ISDA Biotech Policy*? (Part Il)“, I hereby request
that you provide answers in writing to the following questions for the hearing record.
1 . Has USDA asked EPA to share its expertise on preventing pesticide resistance in the
context of USDA’s preparation of an environmental impact statement for Roundup
Ready Alfalfa?
2. How many discussions or communications between USDA and EPA have specifically
concerned 1 ) how USDA might mitigate or prevent the spread of Roundup resistance
in weeds: and/or 2) how USDA might create a process whereby the agency would
develop ways of mitigating or preventing the spread of Roundup resistance in weeds?
3. Docs EPA believe that the Roundup Ready Alfalfa EIS now reflects adequately EPA\s
concern about pest resistance?
Ranking member Jordan submits the following additional questions:
1 . Are there new technologies currently under review by USDA and EPA that would
offer multiple modes of action to address weed resistance? Given the urgency
cxpres.sed by the entire panel to address the issue of herbicide-resistant weeds, arc
there plans to expedite regulatory approval process to facilitate availability of these
new technologies?
756
Tlie Honorable Jim Jones
October 15, 2010
Page 2
2. Is it true that development and registration of a new pesticide active ingredient takes 8
to 10 years, costs hundreds of millions of dollars, and requires more than 100 scientific
studies conducted at the manufacturer’s expense? After approval, does EPA continues
to monitor use of the pesticide in the marketplace?
3. Had farmers experienced problems with herbicide-resistant weeds prior to the
introduction ofbiotech crops?
4. Is there any reason to slow, delay or discourage the development and approval of new
herbicide-resistant crops?
5. Will the introduction of new agricultural products such as herbicide-resistant crops
benefit U.S. fanners?
6. Is the approval of such products a priority for EPA?
7. What steps is EPA taking to ensure such products are available to farmers?
The Oversight and Government Reform Committee is the principal oversight committee in
tlic House of Representatives and has broad oversight jurisdiction as set forth in House Rule X.
We request that you provide written answcis to these questions as soon as possible, but in no
case later than 5:00 p.m. on October 30, 2010.
If you have any questions regarding this request, please contact Jaron Bourke, Staff Director
at (202) 225-6427.
Sincerely,
Dennis J. Kucinich
Chainnan
Domestic Policy SubcommiUee
cc: Jim Jordan
Ranking Minority Member
2
757
Questions for the Record
Committee on Oversight and Government Reform
Subcommittee on Domestic Policy
Hearing on “Are ‘Superweeds’ an Outgrowth of USDA Biotech Policy? (Part II)”
September 30, 2010
1. Has USDA asked EPA to share its expertise on preventing pesticide resistance in the
context of USDA’s preparation of an environmental impact statement for Roundup
Ready Alfalfa?
The EPA and USDA/APHIS/BRS have discussed resistance management plans for
herbicide resistant crops in general. USDA also asked EPA for input on the Roundup Ready
alfalfa EIS, and we provided comments on that EIS describing how resistant weeds might
develop in response to widespread planting of Roundup Ready alfalfa.
2. How many discussions or communications between USDA and EPA have specifically
concerned 1) how USDA might mitigate or prevent the spread of Roundup resistance in
weeds; and/or 2) how USDA might create a process whereby the agency would develop
ways of mitigating or preventing the spread of Roundup resistance in weeds?
EPA has had approximately seven discussions with USDA/APHIS/BRS concerning
herbicide resistant crops and the methods that could be used to manage resistance, including
Roundup resistance. Several of these discussions concerned a project with the Weed Science
Society of America (WSSA) to develop a comprehensive literature review to better understand
the scope of herbicide resistance in genetically-engineered and non-genetically-engineered crops.
The project was undertaken because controlling resistance is extremely complex and there is
limited information on the most effective methods to manage resistance in the field. It is hoped
that the results of the WSSA project will help EPA and USDA develop more effective methods
to promote resistance management among pesticide users.
3. Does EPA believe that the Roundup Ready Alfalfa EIS now reflects adequately EPA’s
concern about pest resistance?
Upon review of the draft EIS, EPA expressed concerns to USDA regarding the
development of herbicide resistant weeds. It is our understanding that USDA will incorporate
EPA’s comments concerning resistance into the final EIS. EPA plans to review the final EIS to
determine whether EPA’s concerns are addressed.
Ranking member Jordan submits the following additional questions:
1. Arc there new technologies currently under review by USDA and EPA that would offer
multiple modes of action to address weed resistance? Given the urgency expressed by
the entire panel to address the issue of herbicide-resistant weeds, are there plans to
expedite regulatory approval process to facilitate availabilities of these new
technologies?
758
EPA does not regulate directly the herbicide-tolerant plant construct and cannot speak to
whether the regulatory approval process will be expedited. EPA does, however, register
pesticides that are used on herbicide-tolerant plants and ensures that the necessary conditions of
use are adequate to protect human health and the environment. EPA is working with USDA and
professional societies, including the Weed Science Society of America (WSSA), to increase
understanding and use of the best practices and strategies to manage pest resistance, including
resistant weeds found in herbicide-tolerant crops. EPA is also working with the American
Phytopathological Society and the Entomological Society of America to identify the best
practices to manage pest resistance to fungicides and insecticides. One important component of
resistance management is for pesticide users to use products that have different modes of action.
To facilitate this, EPA is updating its Pesticide Registration Notice which provides guidance to
pesticide registrants on resistance management labeling. This work is being coordinated with
Canada and Mexico through NAFTA. Additionally, EPA believes that herbicide-tolerant plants
that are resistant to more than one herbicide, allowing for rotation of herbicides with differing
modes of action, may be a useful tool in a comprehensive resistance management strategy.
2. Is it true that development and registration of a new pesticide active ingredient takes 8
to 10 years, costs hundreds of miiiions of dollars, and requires more than 100 scientific
studies conducted at the manufacturer’s expense? After approval, does EPA continues
to monitor use of the pesticide in the marketplace?
Developing a new pesticide product can be a lengthy process. It takes time to identify
new pesticidal active ingredients, determine their potential efficacy, develop the data necessary
for registration, and complete the registration process. But, completing the registration process
takes just a fraction of the total time needed to develop and bring a product to market. For
example, the time period allowed under the Pesticide Registration Improvement Renewal Act
(PRIA 2) for EPA to render a registration decision for genetically modified plant incorporated
protectant (PIP) products varies from 12 to 18 months.
As to the number of scientific studies required for the registration process, and their
associated costs, these are variable because the data requirements are tiered. Applicants and
registrants do not share with EPA information regarding the cost of product development,
therefore, EPA cannot speak to product research and development costs Additional costs may be
incurred if the studies initially submitted to the Agency are deficient and do not permit us to
make the necessary findings under the statute. The number of scientific studies submitted in
association with a new pesticide will fluctuate depending upon the different circumstances
described above.
After registration, EPA uses federal, state and private market surveys on pesticide use to
understand pesticide use in the marketplace.
3. Had farmers experienced problems with herbicide-resistant weeds prior to the
introduction of biotech crops?
The first herbicide resistant weed was reported in 1957 with the use of 2,4-D on sugar
canc in Hawaii. There are currently 194 herbicide resistant weed species according to the
- 2 -
759
International Survey of Herbicide Resistant Weeds. The vast majority are not related to the
introduction of herbicide resistant crops.
4. Is there any reason to slow, delay or discourage the development and approval of new
herbicide-resistant crops?
EPA does not currently regulate directly herbicide-tolerant plant constructs. Pursuant to its
authority under the Plant Protection Act, USDA regulates genetically engineered plants to ensure
that these plants are not plant pests. Therefore, we cannot speak to whether there are actual
bases grounded in specific regulatory scenarios to slow, delay, or discourage the approval of any
particular herbicide-tolerant crop product.
5. Will the introduction of new agricultural products such as herbicide-resistant crops
benefit U.S. farmers?
As a general matter, it can be stated that the introduction of new agricultural products
typically provide benefits to U.S. farmers. New agricultural products can simplify weed control
by allowing the use of broad spectrum herbicides on crops that would not normally tolerate these
chemistries; promote no-till farming; control difficult to manage weeds; and allow growers more
control over application timing. Herbicide-tolerant crops have been used in the U.S. agricultural
system for over 10 years. The use of these crops has resulted in demonstrable economic and
environmental benefits. Increases in herbicide resistant weeds, however, have been a concern for
many farmers.
6. Is the approval of such products a priority for EPA?
As noted above, EPA docs not currently regulate directly herbicide-tolerant plant
constructs. EPA registers and imposes necessary conditions on use of the herbicide intended to
be used in conjunction with herbicide-tolerant crops. As we do not currently regulate directly
herbicide-tolerant plant constructs, we are not in a position to make approval of such products a
priority. With respect to the herbicides intended to be used in conjunction with such crops, EPA
approves the registration and use conditions of such herbicides according to the schedule
established by the Pesticide Registration Improvement Amendments Act (PRIA 2).
7. What steps is EPA taking to ensure such products arc available to farmers?
EPA collaborates with USDA/APHIS/BRS as necessary on its regulatory approvals.
Moreover, EPA is working with UDSA/APHIS/BRS on improving understanding of the
evolution of herbicide resistance and steps that can be taken to manage resistance.
- 3 -
760
ONE HUNDRED ELEVENTH CONGRESS
Congress of tlje ^tateg
Spouse of ^eMie0entnrilJcs
COMMiTTEE ON OVERSIGHT AND GOVERNMENT REFORM
21 57 Rayburn Hojse Office Building
Washington. DC 20515-6143
MiitKir. (aK)2J5-5C51
a»c»!v ('02;2JS-S0;4
wv^i.oversisfit.hciitse.gov
October 15, 2010
The Honorable Ann Wrigjit
Deputy Undersecretary for Marketing and Regulatory Programs
U.S. Department of Agriculture
1400 Independence Ave., SW
Washington, D.C. 20250
Dear Undersecretary Wright:
In comiection with tiie September 30, 2010 hearing of the Domestic Policy Subcommittee,
entitled, ‘'Are “Superweeds” an Outgrowth of USDA Biotech Policy? (Part II)”, I hereby request
that you provide answers in writing to the following questions for the hearing record.
1 . You say in your written testimony that ‘‘there must be a plant pest risk to deny a foil
deregulation, and herbicide resistance does not constitute a plant pest risk.” That is a
reference to Section 4 1 1 of the Plant Protection Act. But the very next section of the
Act, Section 41 2, covers your authority to prevent the spread of “noxious weeds.”
Section 412 gives the Secretary authority to “prohibit or restrict... the movement... of
any plant. . .if the Secretary determines that the prohibition or restriction is necessary to
prevent. . .the dissemination of a. . .noxious weed within the United States.” Can you
point us to any provision of the Plant Protection Act that limits USDA to acting
exclusively under Section 4 1 Us authority and denies USDA the ability to use the
authority given to it by Section 412?
2. The Act defines noxious weeds (at 7 U.S.C, § 7702) as “any plant or plant product that
can directly or indirectly injure or cause damage to crops ... or other interest of
agriculture. . . or the environment” (emphasis added). Is there any limitation in the
statute’s definition of “noxious weeds” that prevents its application to herbicide
resistant weeds?
3. A plain reading of Section 412 in the context of the Act gives the Secretary broad
authority to restrict the use of Roundup-resistant crops if sound science determines that
those restrictions are necessary to prevent the spread of Roundup-resistant noxious
weeds. Yet the Department has not used this authority to mitigate or prevent the
The Honorable Ann Wright
October 15, 2010
Page 2
spread of existing or the developm«it of new species of herbicide-resistant weeds.
Why not? Please provide all documents discussing what the scope of the Secretary’s
exercise of authority under Sections 41 1 and 412 should be, including any legal
memoranda prepared since the lime of the Act’s enactment.
4. You say in your testimony that “industry came to us and asked us to look at partial
deregulation as one way to allow the planting of a GE crop.” Will you provide the
Subcommittee with copies of all such petitions for partial derej^ilation, as well as any
related documentation or materials provided by the industry?
5. You have stated in court that any partial deregulation would be subject to analysis
under the National Environmental Policy Act (NEPA) and would not, therefore,
qualify as a categorical exclusion from those analytical requirements. See Fourth
Declaration of Cindy Smith, Center for Food Safety v. Vilsack, No. 3:08-cv-00484-
JSW (N.D. Cal, July 15, 2010). In view of recent litigation experience in which the
Department has been rebuked by separate federal courts for failing to comply with
NEPA requirements, will you explain in detail what the standard(s) for a Finding of No
Significant Impact would be in the case of this partial deregulation?
Ranking member Jordan submits die following additional questions:
1. Will the introduction of new agricultural products such as herbicide-resistant crops
benefit U.S. farmers?
2. Is the approval of such products a priority for USDA?
3. What steps is USDA taking to ensure such products are available to farmers?
The Oversight and Government Reform Committee is the principal oversight committee in
the House of Representatives and has broad oversight jurisdiction as set forth in House Rule X.
We request that you provide written answers to these questions as soon as possible, but in no
case later than 5:00 p,m, on October 30, 2010.
If you have any questions regarding this request, please contact Jaron Bourke, Staff Director
at (202) 225-6427.
Sincerely,
Dennis J. Kucinich
Chainnan
Domestic Policy Subcommittee
cc: Jim Jordan
Ranking Minority Member
762
Questions for the Record — U.S. Department of Agriculture Response
Subcommittee on Domestic Policy Hearing
“Arc Superweeds an Outgrowth of USDA Biotech Policy?”
September 30, 2010
Chairman Kueinich
1. You say in your written testimony that "there must be a plant pest risk to deny a full
deregulation, and herbicide resistance does not constitute a plant pest risk." That is a
reference to Section 41 1 of the Plant Protection Act. But the very next section of the
Act, Section 412, covers your authority to prevent the spread of "noxious weeds."
Section 412 gives the Secretary authority to "prohibit or restrict... the movement.. .of any
plant... if the Secretary determines that the prohibition or restriction is necessary to
prevent...the dissemination of a...noxions weed within the United States." Can you point us
to any provision of the Plant Protection Act that limits USDA to acting exclusively under
Section 411's authority and denies USDA the ability to use the authority given to It by
Section 412?
Response:
There is no provision of the Plant Protection Act (PPA) that limits the U.S. Department of
Agriculture (USDA) to only using its authorities under Section 41 1 of the Act, and not Section
412. In fact, USDA’s Animal and Plant Health Inspection Service (APHIS) uses authorities
under both sections of the PPA and currently plays a significant role in protecting American
agriculture from both plant pests and noxious weeds.
To clarify. Section 412 of the PPA refers to noxious weeds, and the APHIS Plant Protection and
Quarantine program has always defined a noxious weed as being either invasive or spreading at
an uncontrolled rate, and also as harmful in some way to agriculture or the environment. The
fact that a genetically engineered (GE) plant has a resistance to an herbicide does not make that
plant any more invasive, destructive, or harmful than its non-GE form. Section 412 is only
relevant to the discussion of herbicide resistance if the plant itself is a noxious weed before it is
genetically altered or becomes a noxious weed with herbicide resistance after it is genetically
altered.
The preamble to a recent proposed rule (“Importation, Interstate Movement, and Release Into the
Environment of Certain Genetically Engineered Organisms; Proposed Rule,” 73 Federal Register
197 (9 October 2008), pp 60007-60048.), discusses the standard APHIS uses for ‘noxious’
weeds:
“The distinction between a weed and a noxious weed warrants emphasis. “Weeds,” in
the broadest sense of the word, could include any plant growing where and/or when it is
unw'anted; even plants that are desirable in some settings may be considered weeds in
others. In a narrower sense, weeds are invasive, often non-native, plants which impact
natural and managed ecosystems, often with significant negative consequences due to lost
yields, changes in management practices, altered herbicide use, etc. Only a traction of
these problematic weeds are considered to be so invasive, so harmful, and so difficult to
763
control that Federal regulatory intervention to prevent their introduction or dissemination
is justified, and these are the focus of the regulatory controls placed on them by APHIS.
However, any weed, and virtually any plant or plant product, can be evaluated by APHIS
to determine whether its characteristics and potential impacts warrant its listing as a
noxious weed.”
2. The Act defines noxious weeds (at 7 U.S.C. § 7702) as "any plant or plant product that
can directly or indirectly injure or cause damage to crops...or other interest of
agriculture.. .or the environment" (emphasis added). Is there any limitation in the statute’s
definition of "noxious weeds” that prevents its application to herbicide resistant weeds?
Response:
There is no provision in the Act that limits that statute’s definition of “noxious weeds” to prevent
the definition from applying to herbicide resistant weeds. I would like to clarify that APHIS
does in fact consider resistance to herbicides as one of a number of factors when the Agency
determines whether a plant should be considered a Federally-listed noxious weed. The primary
consideration is stated in Section 412 of the PPA which refers to noxious weeds as either being
invasive or spreading at an uncontrolled rate. Further, they must be hannful to agriculture or the
environment. However, no plant has been determined to be a noxious weed solely because of
resistance to a single herbicide.
3. A plain reading of Section 412 in the context of the Act gives the Secretary broad
authority to restrict the use of Roundup-resistant crops if sound science determines that
those restrictions are necessary to prevent the spread of Roundup-resistant noxious weeds.
Yet the Department has not used this authority to mitigate or prevent the spread of existing
or the development of new species of herbicide-resistant weeds. Why not? Please provide
all documents discussing what the scope of the Secretary’s exercise of authority under
Sections 411 and 412 should be, including any legal memoranda prepared since the time of
the Act’s enactment.
Response:
The evolution of pests to become resistance to herbicides, insecticides, and other pesticides has
been an issue for farmers for decades, and is not solely caused by the use of GE herbicide
tolerant crops. As exemplified by the Australian experience, it is frequently the repeated use of a
.single herbicide mode of action that leads to the appearance of herbicide resistant weeds. The
Act does not provide authority to the Secretary of Agriculture to regulate the use of herbicides.
To halt the spread of herbicide resistant weeds, and to prevent further development of more
herbicide resistant weeds, a more fundamental, scientific approach is needed to determine how
herbicides result in the appearance and spread of herbicide resistant plants and how to
effectively use herbicides to minimize the risk of herbicide resistant weeds. The U.S.
Environmental Protection Agency (EPA), which has the authority to regulate pesticides —
including herbicides — has used its pesticide registration authority to mitigate the development of
insect resistance to insecticide produced by genetically engineered crops. EPA achieves this by-
regulating the amount of insecticide present in the environment and by imposing resistance
764
management plans on plant incorporated protectants that make pesticidal claims. The regulation
of the insecticide and use of refuges was based on scientific research on how insect resistance
develops in targeted pests, and the best strategies available, in terms of deployment of
insecticides, that will minimize the development of resistance in these insects.
USDA will continue to actively support research and extension as we work to determine how
plants evolve resistance to herbicides, and what mitigation measures will minimize or halt the
herbicide resistance in plants. Strong science is needed to support regulation, and the USDA is
committed to providing resources and expertise to help those farmers that use herbicides in their
farming practices.
We are providing to you all of the documents you requested with the exception of documents
that would fall under the attorney/client privilege. We would be happy to discuss access to these
documents with you; however, we are unable to provide you with copies of these documents.
The requested documents are included in Appendix A. They include:
Syngenta Seeds, Inc.; Availability of Petition and Environmental Assessment for Determination
ofNonregulated Status for Corn Genetically Engineered To Produce an Enzyme That Facilitates
Ethanol Production, 74 Federal Register 106, (4 June 2009), pp 26832-26835.
Issue Paper 2: Incorporation of the Plant Protection Act Noxious Weed Provisions, U.S.
Department of Agriculture, Animal and Plant Health Inspection Service, Biotechnology
Regulatory Services, April 28, 2009. *Note: Provided during public meetings on revisions to
APHIS’ biotechnology regulations
Importation, Interstate Movement, and Release Into the Environment of Certain Genetically
Engineered Organisms; Proposed Rule. 73 Federal Register 197, October 9, 2008, pp 60008-
60048.
Plant Pests, Introduction of Genetically Engineered Organisms or Products, Final Rule, Federal
Register, 52 Federal Register 115, June 16, 1987, pp 22892-22915.
4. You say in your testimony that "industry came to us and asked us to look at partial
deregulation as one way to allow the planting of a GE crop." Will you provide the
Subcommittee with copies of all such petitions for partial deregulation, as well as any
related documentation or materials provided by the industry?
Response:
Yes. The requested documents are included in Appendix B. They include:
Forest Genetics International Letter to USDA Requesting Partial Deregulation of Roundup
Ready Alfalfa Events J10I/.II63, August 6, 2010.
Environmental report. Partial Deregulation Measures for Cultivation of Roundup Ready®
Alfalfa Events J10I/JI63, Forest Genetics International, August 5, 2010
765
Monsanto and KWS Letter to USDA Requesting Partial Deregulation of Roundup Ready
Sugarheet Event H7-I, July 29, 2010.
Environmental Report, Interim Measures for Cultivation of Roundup Ready Sugar Beet Event
Monsanto, July 30, 2010.
5. You have stated in court that any partial deregulation would be subject to analysis under
the National Environmental Policy Act (NEPA) and would not, therefore, qualify as a
categorical exclusion from those analytical requirements. See Fourth Declaration of Cindy
Smith, Center for Food Safety v. Vilsack, No.3 :08-cv-00484-.ISW (N.D. Cal., July 15,2010).
In view of recent litigation experience in which the Department has been rebuked by
separate federal courts for failing to comply with NEPA requirements, will you explain in
detail what the standard(s) for a Finding of No Significant Impact would be in the case of
this partial deregulation?
Response:
USDA is committed to performing thorough environmental reviews and seeking the views of the
public on issues before the Department, including the regulation of GE organisms. In
considering a request for a partial deregulation, APHIS would follow Agency and Council on
Environmental Quality (CEQ) NEPA implementing procedures to indentify the appropriate level
of NEPA analysis and documentation required, prior to taking any regulatory action. APHIS
would carefully consider the possible environmental impacts of each regulatory action to ensure
the appropriate level of science-based analysis required for a decision is adequate and sufficient.
APHIS will conduct an analysis on each of the issues regarding a partial deregulation, and then
make a determination based on the context and intensity factors from the CEQ NEPA regulations
that define how an issue may “significantly” impact the human environment, found in 40 CFR §
1508.27. This includes analyzing the significance of an action in several contexts and
considering both short- and long-term effects, the degree to which the proposed action affects
public health or safety, and the degree to which an action may impact endangered or threatened
species, among other considerations listed under the regulations.
Ranking member Jordan
1. Will the introduction of new agricultural products such as herbicide-resistant crops
benefit U.S. farmers?
Response:
Yes. The use of herbicide-resistant crops has had a significant, positive impact on the
agricultural community. Benefits include:
o Increased profitability and efficiency for U.S. farmers — farmers can produce
higher yields on less land;
o Use of safer herbicides;
o Decreased soil erosion due to increased no-till farming.
766
As the world’s population increases, the demand for food is growing and the land available to
farm is shrinking. To ensure the United States can meet these demands and yet protect and
conserve our valuable farmland, USDA is pursuing policies that promote the coexistence of
biotechnology-derived, conventional, and organic methods. Biotechnology is poised to be a
critical tool in addressing important global issues, including food security, sustainability, and
climate change. At USDA, we advocate the safe and appropriate use of this technology to help
meet the agricultural challenges and consumer needs of the 21st century.
2. Is the approval of such products a priority for USDA?
Response:
Regulating the products of biotechnology is a critical role for USDA, We are committed to a
strong, science-based biotechnology regulatory program because we view it as essential to the
development of a sustainable agricultural system.
I can assure you that we take the biotechnology regulatory process very seriously, and that we
strive for thorough and complete reviews, which can take a significant amount of time. While
we have been challenged in recent years to respond to an increasing number of petitions for
deregulation, we are constantly looking for ways to improve the process. For example, we have
undertaken a reorganization of our biotechnology staff, and have hired additional scientists to
improve performance and efficiency. We have also awarded contracts to assist with the
preparation of technical documents, and to help us evaluate the many thousands of public
comments received through the NEPA process. To further strengthen our program, USDA
requested an increase of nearly $5.8 million in FY 201 1 for our biotechnology program. If
enacted, we would hire additional staff and improve the program’s responsiveness without
sacrificing its thoroughness.
3. What steps is USDA taking to ensure such products are available to farmers?
Response;
From a regulatory standpoint, our goal is to have a rigorous, science-based program in place to
ensure that GE products, including herbicide resistant crops, are thoroughly vetted through our
process, examined under NEPA, and determined safe before use by U.S. producers. We believe
that our system achieves that goal, and has enabled producers to have access to innovative
technologies that contribute to our larger agricultural economy, food seciuity, and sustainability.
It is important to point out that we’ve made thousands of regulatory decisions without legal
challenge, and none of our plant pest determinations have been overturned in court — though we
do remain concerned about the court rulings on our NEPA documentation process. However, we
continue to learn from those rulings and improve our processes, leading to higher quality
environmental reports and reviews.
767
Appendix A. Documentation Responsive to Question 3 — ^All documents discussing what
the scope of the Secretary's exercise of authority under Sections 411 and 412 should be,
including any legal memoranda prepared since the time of the Act's enactment.
Syngenta Seeds, Inc.; Availability of Petition and Environmental Assessment for Determination
of Nonregulated Status for Corn Genetically Engineered To Produce an Enzyme That Facilitates
Ethanol Production, 74 Federal Register 106, (4 June 2009), pp 26832-26835.
Issue Paper 2: Incorporation of the Plant Protection Act Noxious Weed Provisions, U.S.
Department of Agriculture, Animal and Plant Health Inspection Service, Biotechnology
Regulatory Services, April 28, 2009. *Note; Provided during public meetings on revisions to
APHIS’ biotechnology regulations
Importation, Interstate Movement, and Release Into the Environment of Certain Genetically
Engineered Organisms; Proposed Rule. 73 Federal Register 197, October 9, 2008, pp 60008-
60048.
Plant Pests, Introduction of Genetically Engineered Organisms or Products. Final Rule, Federal
Register, 52 Federal Register 115, June 16, 1987, pp 22892-22915.
Appendix B. Documentation Responsive to Question 4 — Copies of all such petitions for
partial deregulation, as well as any related documentation or materials provided by the
industry.
Forest Genetics International Letter to USD A Requesting Partial Deregulation of Roundup
Ready Alfalfa Events JIOl/JJ 63, August 6, 2010.
Environmental report. Partial Deregulation Measures for Cultivation of Roundup Ready®
Alfalfa Events JI0I/J163, Forest Genetics International, August 5, 2010
Monsanto and KWS Letter to USDA Requesting Partial Deregulation of Roundup Ready
Sugarheet Event H7-I , July 29, 2010.
Environmental Report, Interim Measures for Cultivation of Roundup Ready Sugar Beet Event
H7-1, Monsanto, July 30, 2010.
768
April 28, 2009
Issue Paper 2: Incorporation of the Plant Protection Act Noxious Weed Provisions
L Objective of the Proposal
The goal of incorporating the noxious weed authority of the Plant Protection Act of 2000 (PPA)
into the proposed revisions to the 340 regulations is to recognize and utilize both the plant pest
and the noxious weed authorities provided by the Statute. The PPA grants the Secretary of
Agriculture authority to develop regulations in order to detect, control, eradicate, suppress,
prevent, or retard the spread of plant pests or noxious weeds. The PPA combines the authorities
of several previous related acts, including the Plant Quarantine Act of 1912 (PQA), the Federal
Plant Pest Act of 1957 (FPPA), and the Noxious Weed Act of 1974 (NWA).
APHIS’ current Part 340 biotechnology regulations were first promulgated in 1987 using the
FPPA and PQA, which provided USDA authority to regulate the importation and interstate
movement of articles that are likely to result in the introduction or dissemination of plant pests.
APHIS is proposing to revise the Part 340 regulations to also include its PPA noxious weed
authority to regulate certain GE organisms. The proposal seeks to:
• Prevent potential gaps in APHIS’ Part 340 regulatory oversight, namely for GE
organisms which are unlikely to pose a plant pest risk but could pose a noxious weed
risk.
• Have the regulatory authority to consider a broader range of potential harm from GE
plants i.e., not just their potential for being a plant pest, but also their potential to be a
noxious weed.
• Improve clarity of risk assessments, by evaluating GE plants that could be considered
potential noxious weeds, in addition to evaluating their potential to be plant pests.
• Be able to regulate non-living material derived from a GE plant, if APHIS concludes that
such material is likely to pose a noxious weed risk (e.g., create a noxious weed harm as
enumerated in the PPA by injuring the interests of agriculture, the environment, or public
health).
11. Description of Significant Comments Received to date.
Commenters focused on both the issue of incorporating the noxious weed authority into the
scope of the rule as well as the issue of exactly how the noxious weed authority would be utilized
or applied.
Many commenters focused on the very broad range of significantly harmful impacts
encompassed in the noxious weed definition in the PPA. In general, industry and trade groups
raised concerns that APHIS should narrowly limit its interpretation of the noxious weed
definition, so that it was clear, for example, that economic or aesthetic impacts alone in the
769
April 28, 2009
absence of any significant physical damage did not make any plant a noxious weed. On the other
hand, several public interest groups and numerous individuals wanted APHIS to interpret the
definition as inclusively as possible, especially with regard to impacts on the environment, public
health, and marketing or product quality impacts such as indirect impacts on organic agriculture.
Some commenters felt that the proposed rule “set the bar too low” for GE plants. If the impacts
of GE plants are compared against impacts of “real” noxious weeds, as proposed, then few GE
plants could ever rise to that level of harm and most GE plants might be quickly evaluated by
APHIS to not be under its PPA jurisdiction and thus not subject to the Part 340 regulations. That
is, only those plants that are noxious weeds (or are likely to be noxious weeds) to begin with
would actually be within the scope of the Part 340 regulations,
III. APHIS Current Thinking
APHIS considers that it is preferable to revise its regulations to incorporate the noxious weed
authority of the PPA. Doing so would allow regulatory oversight of GE organisms that do not
fall within the jurisdiction of the current regulation’s plant pest authority. APHIS also considers
that the proposed revisions could also improve the clarity and transparency of APHIS’ biotech
risk assessments and enable APHIS to consider a broader range of factors (e.g., interests of
agriculture, public health, the environment) that could potentially be injured by the GE plant if it
were determined to be a noxious weed. The specifics of how APHIS will evaluate the noxious
weed risk of GE plants may require some additional development and clarification. APHIS must
consistently apply its PPA noxious weed authority and thus its noxious weed assessment of GE
plants under the proposed regulations must be similar to and consistent with the way that APHIS
has in the past and continues to evaluate the noxious weed ri.sk of non-GE plants. It is not
justifiable either from a regulatory or a scientific perspective to hold GE plants to a different
standard than non-GE plants for risks regulated under the same statutory authority by the very
same agency. However, APHIS will need to develop clear criteria and decision-making
standards in order to better inform the public of how it intends to apply its PPA noxious weed
authority to GE plants. Those criteria and standards will likely need to be incorporated into the
regulation.
IV. Issues for Further Discussion
Comments related to incorporation of the PPA noxious weed authority into the proposed
regulations raised a number of issues that APHIS will have to carefully consider:
• How can APHIS apply its PPA noxious weed authority to GE plants in a way that
is consistent with and similar to its past and current noxious weed regulation of
non-GE plants?
• What criteria or standards for evaluating GE plants as noxious weeds could
APHIS develop that are consistent with the PPA definition of noxious weeds and
APHIS application of its noxious weed authority to non-GE plants?
770
April 28, 2009
• How can APHIS develop noxious weed criteria applicable to GE plants and relate
those criteria to the various impacts included in the PPA noxious weed
definition — such as impacts on “other interests of agriculture” and “public
health” — that are consistent with its past and current non-GE noxious weed
assessments?
771
F
i
Part IV
Department of
Agriculture
Animal and Plant Health Inspection
Service
7 CFR Part 340
Importation, Interstate Movement, and
Release Into the Environment of Certain
Genetically Engineered Organisms;
Proposed Rule
772
60008 Federal Register / Vol. 73, No. 197 /Thursday, October 9, 2008 /Proposed Rules
DEPARTMENT OF AGRICULTURE
Animal and Plant Health Inspection
Service
7CfR Part 340
[Docket No. APHIS-2008-0023]
RIN 0579-AC31
Importation, Interstate Movement, and
Release into the Environment of
Certain Genetically Engineered
Organisms
agency: Animal and Plant Health
Inspection Service, USDA.
ACTION; Proposed rule; notice of public
forums.
SUMMARY: We propose to revise our
regulations regarding the importation,
interstate movement, and environmental
release of certain genetically engineered
organisms in order to bring the
regulations into alignment with
provisions of the Plant Protection Act.
The revisions would also update the
regulations in response to advances in
genetic science and technology and our
accumulated experience in
Implementing the current regulations.
This is the First comprehensive review
and revision of the regulations since
they were established in 1987, This rule
would affect persons involved in the
importation, interstate movement, or
release into the environment of
genetically engineered plants and
certain other genetically engineered
organisms.
DATES: We will consider all comments
that we receive on or before November
24, 2008. We will also consider
comments made at public forums to be
held in Davis, CA; Kansas City, MO; and
Rivordale, MD,
ADDRESSES: You may submit comments
by any of the following methods:
• Federal eRulemaking Portal: Go to
http://www.regvlations.gov/fdmspublic/
component/
mam?mam-DocketDetail&'d=APHIS-
2008-0023 to submit or view comments
and to view supporting and related
materials available electronically.
• Postal MaU/Commercial Delivery:
Please send two copies of your comment
to Docket No. APHIS-2008-0023,
Regulatory Analysis and Development,
PPD, APHIS, Station 3A~03.8, 4700
River Road Unit 118, Rivordale, MD
20737-1238. Please stale that your
comment refers to Docket No, APHIS-
2008-0023.
• Public Forums. Written and oral
comment will bo accepted at three
public forums held during the comment
period. Sec Public Forums below.
Reading Room: Y ou may read any
comments that we receive on this
docket in our reading room. The reading
room is located in room 1141 of the
USDA South Building, 14th Street and
Independence Avenue, SW„
Washington, DC. Normal reading room
hours are 8 a.m. to 4:30 p.m., Monday
through Friday, except holidays. To be
sure someone is there to help you,
please call (202) 690-2817 before
coming.
Other Information: AdditioMi
information -about APHIS and its
programs is available on the Internet at
http://www.aphis.usda.gov.
FOR FURTHER INFORMATION CONTACT:
Biotechnology Regulatory Services.
APHIS, 4700 River Road Unit 147.
Riverdale, MD 20737-1236; (301) 734-
5710.
For information about the public
forums, contact: Dr. T. Clint Nesbitt.
BRS. APHIS, 4700 River Road Unit 147,
Riverdale. MD 20737-1238; (301) 734-
5673.
SUPPLEMENTARY INFORMATION:
Public Forums
In order to provide additional
opportunities for the public to comment
on the proposed rule, APHIS will hold
public forums in three locations: Davis,
CA; Kansas City, MO: and Riverdale,
MD (see Meeting Locations below).
These informal forums are designed to
engage interested individuals from the
public and elicit comments related to
the proposed rule. The format will
consist of informational posters and
comment stations. Attendees will be
able walk through the forum during the
open hours and interact with other
attendees and APHIS personnel. Short
welcoming remarks will be given by
APHIS personnel at 4:30 p.m. and again
at 6 p.m. {local time), but there is no set
schedule for each poster station, so the
public may come and go at any time
during the forum period. Participants
will have the opportunity, if desired, to
record brief oral comments with a court
reporter or to submit comments in
writing, following directions provided
at the comment stations. A transcript of
the oral comments amd a copy of any
written comments submitted at the
public forums will be placed in the
rulemaking record and will be available
for public inspection.
The purpose of these public forums is
to allow Uie public a venue in which to
interact with APHIS representatives and
to allow APHIS to solicit further
information from the public. Comments
received at these public forums will be
added to this Docket.
Dates: Tire public forums will be held
in Davis, CA, on October 28, 2008; in
Kansas City, MO, on October 30, 2008;
and Riverdale, MD, on November 13,
2008. Each public forum will be held
from 4 p.m. to 7 p.m.. local time.
Meeting Locations: The public forums
will be held at the following locations:
USDA Riverside, Oklahoma City
Memorial Conference Rooms B, C. and
D, 4700 River Road, Riverdale, MD,
20737. For directions or facilities
information, call (301) 734-8010.
Walter A. Buehler Alumni & Visitors
Center, Alpha Gamma Rho Hall,
University of California, Davis, CA,
95616. For directions or facilities
information, call (530) 754-9195 or visit
http://ivww.alumnicenter.ucdavis.edu/.
Hilton Kansas City Airport, Shawmeo
Room A, 8801 NW 112th Street, Kansas
City. MO, 64153. For directions or
facilities information, call (816) 891-
8900 or visit http://www.biltonkci.com/
Table of Contents
J. Introduction
n. Background
A. APHIS Role in Federal Regulation of
Genetically Engineered Organisms
B. Current Regulations in 7 CFR part 340
C. Plant Protection Act Authority to
Regulate Plant Pests. Noxious Weeds,
and Biological Cotitrol Organisms
III. Proposed Rule
A. Proposed Regulatory Scope (§ 340.0
Scope and General Restrictions)
1. Genetically Engineered Organisms
Subject to 7 CFR part 340
2. Deleting the List of Organisms Which
Are or Contain Plant Pe.sts
3. Regulating Whole Organisms, Parts, and
Nonliving Products
B. Permits for Authorizing Importation,
Interstate Movement, and Release Into
the Environment of Certain GE
Organisms
1. Elimination of the Notification
Procedure
2. Revisions to Permit Procedures
3. Permit Types and Environmental
Release Categories {§ 340.2(b))
4. Permit Application Information
Requirements (§ 340.2(c))
5. Permit Conditions (§340.3)
6. Elimination of Courtesy Permits
C. Conditional Exemptions from Permit
Requirement (§340.4, §340.5)
D. Petitions for Nonregulated Status
{§ 340.6)
E. Compliance. Enftucement, and Remedial
Action (§ 340,7)
1. Ensuring Compliance with Permits and
Exemption Activities
2. Low Level Presence of Regulated GE
Plants in Seed or Grain
F. Administrative Changes
t, Confidentiai Business Information
(§340.8)
2. Time Frames for APHIS Action on
Permit Applications and Petitions
3. Duratioii Period for Permits
G. Definitions and Miscellaneous Changes
IV. Required Analyses
A. National Environmental Policy Act
773
Federal Register / VoL 73, No. 197/Tiiursday, October 9, 2008/Proposed Rules 60009
B. Executive Order 12866 and Regulatory
Flexibility Act
C. Executive Order 12372
D. Executive Order 12988
E. Paperwork Reduction Act
F. E-Government Act Compliance
I. Introduction
The U.S. Department of Agriculture’s
(USDA) Animal and Plant Health
Inspection Ser\'ice (APHIS) regulates the
safe introduction (environmental
release, interstate movement, and
importation) of certain genetically
engineered (GE) organisms under its
regulations in 7 CFR part 340. The
regulations govern the introduction of
GE organisms that might be plant pests,
APHIS has amended the regulations
several times in an effort to respond to
the need for streamlined procedures and
has established clear procedures to
remove GE organisms that do not pose
a plant pest risk from obligations under
the regulation.
The APHIS regulations have been
used most frequently for permits and
notifications for importation, interstate
movement, or environmental releases of
GE plants, although a smaller number of
permits have been issued for GE
microorganisms and insects. To date,
APHIS has authorized more than 13,000
environmental releases of GE plants,
most of which have been part of the
development of improved crop varieties
for agriculture. These controlled
environmental releases are sometimes
referred to as field tests or field trials,
in recognition of their relationship to
field tests done in the traditional
development of plant varieties, and in
this document the terms field lest or
field trial should be understood to moan
environmental release. In addition to
permits and notifications, APHIS has
completed reviews in response to
petitions requesting nonregulated status
under these regulations. To date, APHIS
has granted 74 determinations of
nonregulated status, and all of these
have been for GE plants (more
information about these is posted at
hitp://mvw.aphisMsda.gov/brs/
not_reg.btmI ). Many of these plants
have since been used to develop plant
varieties that have become part of the
options that growers have for
agricultural production in the United
States and other countries. The APHIS
determinations of nonregulated status
have been for the GE plant(s) and their
progeny. The GE plant with
nonregulated status can be used
subsequently in plant breeding
programs or in agriculture just like other
plant lines. A GE plant that has received
nonregulated status can be bred with
another GE plant with nonregulated
status, and the resulting progeny whicii
could contain multiple GE traits still
retains nonr^ulated status.
The bulk of APHIS-authorized
introductions have i^n crop plants
bearing genes which confer resistance to
certain insects or tolerance to certain
herbicides. Although the current
program has been effective in ensuring
the safe environmental release,
interstate movement, and importation of
certain genetically engineered
organisms, technological advances have
led to new uses and questions about
how the current regulations and APHIS
authorities will be used to maintain
appropriate overact. Advances in
technology have created possibilities for
new and different traits, such as those
that would produce a compound for
pharmaceutical or industrial use. In
addition, researchers have been
producing organisms that may not fall
under the scope of our current
regulations and are also beginning to
focus more on perennial plants, such as
grasses or trees, which may be capable
of establishing and persisting outside
the site of introduction.
APHIS is proposing to revise its
regulations in order to respond to
emerging trends in biotechnology, to
address the current and future needs of
the agency, to continue to ensure a high
level of environmental protection, to
improve regulatory processes so that
they are more transparent to
stakeholders and the public, to more
efficiently use agency resources and to
eliminate unnecessary regulatory
burdens.
Given the diversity of U.S.
agriculture, the USDA Advisory
Committee on Biotechnology and 21sl
Century Agriculture recently in its
March 2008 consensus report
encouraged the continuing support of
coexistence among various agi icullural
production systems in U.S. agriculture.
APHIS concludes that the changes it is
proposing will continue to support
coexistence in U.S. agriculture.
In addition, APHIS is proposing
changes to the regulations to reflect
provisions of the 2008 Farm Bill
recently enacted. Section 10204 of Title
X of the Food, Conservation, and Energy
Act of 2008 (Farm Bill) requires the
Secretary of Agriculture to take action
on each issue identified in the
document entitled “Lessons Learned
and Revisions under Consideration for
APHIS’ Bioteclmology Framework,’’ and
where appropriate, promulgate
r^ulations. APHIS is proposing certain
regulatory changes concerning permit
application information requirements,
permit conditions, records, and reports
that address many of the considerations
outlined in Section 10204.
APHIS is also aligning this proposed
nile with recommendations arising from
the 2005 audit of the USDA Office of
Inspector General entitled “Controls
Over Issuance of Genetically Engineered
Release Permits.”
II. Background
A. APHIS Role in Federal Regulation of
Genetically Engineered Organisms
Under the Coordinated Federal
Framework for Regulation of
Biotechnology,^ USDA works with the
Food and Drug Administration (FDA)
and the Environmental Protection
Agency (EPA) to ensure that the
development and testing of
biotechnology products occur in a
manner that is safe for plant and animal
health, human health, and the
environment. USDA and EPA are the
agencies responsible for protecting U.S.
agriculture and the environment. EPA is
responsible for the human health,
animal health, and environmental safety
issues raised by any posticidal
substance produced in genetically
engineered (GE) organisms. FDA has
authority over tlie safety of the whole
food product other than the pesticidal
components regulated by BPA.
B. Current Regulations in 7 CFR Part
340
APHIS administers regulations in 7
CFR part 340, "Introduction of
Organisms and Products Altered or
Produced Through Genetic Engineering
Which are Plant Pests or Which There
is Reason to Believe are Plant Pests”
(referred to below as the regulations).
The current regulations govern the
introduction (importation, interstate
movement, or release into the
environment) of certain GE organisms
termed “regulated articles." Regulated
articles are essentially GE organisms
which might pose a risk as a plant pest.
APHIS first promulgated these
regulations in 1987 under the authority
of the Federal Plant Pest Act of 1957
(FPPA) and the Plant Quarantine Act of
1912 (PQA), two acts that were
subsumed into the Plant Protection Act
(PPA, 7 U.S.C. 7701 et seq.) in 2000,
along with other provisions.
Under the current regulations, a GE
organism is a regulated article if it is a
plant post or if the Administrator has
reason to believe it is a plant pest; more
specifically:
’ The Coordinated Framework is described in a
notice pubiished in the Federat Register on June 26.
198C (51 FR 23302). The notice may he viewed at
http://i^'ww.aphis.usda.gDv/brs/fedregisier/
coordinatndymimwork.pdf.
774
60010 Federal Register /Vol.
“if the donor organism, recipient organism,
or vector or vector agent belongs to any
genera or taxa designated in § 340.2 and
meets the definition of plant pest, or is aii
unclassified organism and/or an organism
whose classification is unknown, or any
product wliich contains such an organism, or
any other organism or pnrduct altered or
produced through genetic engineering which
the Administrator determines is a plan! pest
or has reason to believe is a plant pest.”
(Definition of regulated article, § 340.1J
In other words, APHIS regulates the
introduction (importation, interstate
movement, and environmental release)
of GE organisms if (1) any of the
recipient, genetic donor, or vector
organisms are plant pests or of unknown
classification or (2) the Administrator
has determined or has reason to believe
the GE organism is a plant post. As
constructed the regulations apply to GE
microorganisms, insects, and other
traditional types of plant pests and to
any GE plants if plant pest organisms
(bacterial and viral plant pathogens) are
the donor organisms and vector agents
used in the creation of these GE plants.
Taxa containing "known plant pests”
are those listed in current § 340.2.
Current regulations also include a
petition procedure (§ 340.5) which
allows petitioners to ask APHIS to add
or subtract taxa from the list in § 340.2.
That list has not been amended since it
was established in 1987.
As defined under the current
regulations and the PPA, most plants arc
not plant pests, with the exception of a
few parasitic plant species, such as
striga, witchweed, and dodder.
The primary procedure for regulation
under the PPA is the issuance of a
permit, which is an authorization by the
Secretary to move plants, plant
products, biological control organi.sms,
plant pests, noxious weeds, or articles
tmder conditions prescribed by the
Secretary. The PPA also authorizes the
Secretary to determine which classes of
the above articles must have a permit to
be moved. Conditions as.sociated with
those permits can be tailored to achieve
the appropriate level of regulatory
control to make it unlikely that actions
under the permit would result in the
introduction or dissemination of a plant
pest or noxious weed.
APHIS currently uses a permit and
notification system to authorize
importation, interstate movement and
release into the tmvironmenl (currently
referred to as "introductions”) of certain
GE organisms. Under the current
regulations, all regulated articles are
eligible for the permitting procedure,
but only certain plants are eligible for
the notification, procedure. Currently,
mo.st regulated GE plants are introduced
73, No. 197 / Thursday, October 9,
under notification, which is a
streamlined procedure. Examples of GE
plants introduced under the notification
procedure are those GE plants altered to
be resistant to certain, insects or
herbicides. GE plants that do not meet
the notification eligibility criteria and
ail other GE organisms, such as
microbes and insects, must be
introduced tinder the permit procedure
in current § 340.4. In recent years,
APHIS has processed most notifications
and permits throtigh its electronic, e-
permitting system that is accessible by
the internet at http://
www.aphis.usda.gov/permits/
learnepermits.shtml.
In making a regulatory determination
for a permit or notification for a GE
oiganism subject to the part 340
regulations, APHIS makes such a
determination on whether the actions
under notification or permit are unlikely
to result in the introduction or
dissemination of a plant pest. This
determination takes into account
various risk factors, including, among
other things, a low risk that the GE
organism or its progeny can persist,
reproduce, and establish without human
assistance. Other risk factons that would
support an "unlikely” determination
would be minimal availability of
suitable hosts or habitats for the
organism and low risk that the organism
may cause damage to plants and plant
products.
Regarding the risk of introduction or
dissemination of the GE organism as a
plant pest, an “unlikely” determination
lakes into consideration both the nature
of the organism (i.e., low risk that the
organism or its progeny can persist,
reproduce, establish, and spread
without human assistance) and any
additional mitigations that are placed
upon the organism that restrict its
movement and make its unauthorized
introduction or dissemination unlikely.
The notification procedure was first
added to the regulations in 1993, and
then amended in 1997 to allow a
broader range of plant species to be
eligible for the procedure, The
notification procedure was designed to
be a streamlined procedure with the
eligibility criteria and performance
standards already built into the
regulations. Over the past decade,
APHIS has tjrpically authorized 700-
1 200 notifications per year.
As part of the notification procedure,
applicants must adhere to performance
standards set forth by APHIS for proper
confinement of the GE plants. The goal
of proper confinement is to ensure that
the GE plants do not persist in the
environment. Under the notification
procedure applicants provide
2008 /Proposed Rules
information about the introduction
sufficient for APHIS to evaluate
eligibility for the procedure and impacts
on the environment. This information
includes information on the plant
species, introduced gene(s), iocation(s),
and anticipated lime frame for the
introduction.
For notifications, the eligibility
criteria and the performance standards
stated in the regulations must be met,
but APHIS does not prescribe how the
performance standards must be met. For
example, one of the performance
standards in § 340, 3(c)(5) requires that
"The field trial must bo conducted such
that (i) The regulated article will not
persist in the environment, and (ii) No
offspring can be produced that could
persist in the environment” The
responsible person might meet this
standard in a field trial by isolating the
regulated GE plants at a sufficient
distance to preclude gene flow from the
GE plant to sexually compatible plants
in the vicinity. Another design protocol
might meet the same performance
standard by planting the GE plant at a
time in the growing season when
surrounding plants of the same specie.s
would not be biologically capable of
being fertilized by pollen from the GE
plant (temporal isolation).
The regulations in current § 340.3(e)
specify that the APHIS notification
procedure must be completed within 30
days for environmental release and
importations and within 10 days for the
interstate movement of a regulated
article, If APHIS completes the review
process and finds that all regulatory
requirements have been met, the
notification is authorized in a process
termed "acknowledgement,” and the
applicant can proceed with the
introduction under the terms of the
notification, Notifications are valid for
one year from the date of introduction.
Approximately 10% of APHIS
authorizations are done under the
permitting procedure. The permitting
procedure, found in §340.4 of the
current regulation, describes the typos
of permits, information required for
permit application, the standard permit
conditions, and admini,strative
information (e.g,, time frames, appeal
procedure, etc.). Permits include
specific conditions that must be
followed by the permit holder. Standard
permit conditions are listed in the
regulation, and APHIS can supplement
these with additional conditions as
necessary. The current regulations
specify the amount of time that APHIS
is allotted for review of complete permit
applications: 60 day.s for permits for
importation and interstate movement;
120 days for environmental release.
775
Federal Register/VoL 73. No. 197/Thursday, October 9, 2008 /Proposed Rules 60011
Some regulated articles are
conditionally exempt from the
requirement for permits when moved
interstate under the conditions
stipulated in the regulation. Conditional
exemptions currently exist in the
regulations for the interstate movement
of certain GE bacteria {Escherichia coli,
Bacillus subtilis), fungi {Saccharomyces
cerevisiae), as w'oll as the plant species
Arabidopsis thaliana. APHIS
established these conditional
exemptions from interstate movement
permit by amending the regulations in
1988 and 1990,
APHIS forwards the applications for
all permits, and notifications, with any
confidential business information
redacted, to Stale regulators in the
Stales to which regulated articles will be
moved and/or in which environmental
release is planned. This is done to notify
States of the requested action and to
allow States to review and comment on
proposed releases or importations or
movements.
The current regulations also include
various provisions and prescribed
standards for containers, marking, and
identity that apply to shipments of
regulated articles, For example, there
are instructions regarding how to label
containers of imported regulated articles
with the nature of the contents, origin
and destination, and other information,
and detailed instiuctions on what
materials (plastic, metal, etc.) and
dimensions may bo used for containers
of regulated articles.
Under the current regulations, APHIS
may also grant “nonregulated status” to
a GE organism in accordance with the
procedure described in §340.6. A
determination of nonregulated status
means that the organism is no longer
subject to the part 340 regulations, and
therefore there is no longer any
requirement for APHIS authorization
under part 340 for a permit or
notification when the GE organism is
imported, moved interstate, or released
into the environment.
C. Plant Protection Act Authority to
Regulate Plant Pests, Noxious Weeds,
and Biological Control Organisms
Under the provisions of the PPA,
Congress has granted the Secretary of
Agriculture authority to develop
regulations in order to detect, control,
eradicate, suppress, prevent, or retard
the .spread of plant pests or noxious
weeds. The PPA grants the Secretary'
authority to regulate the movement into
and through the United Stales of any
plant, plant pest, plant product,
biological control organism, noxious
weed, article, or means of conveyance,
in order to prevent the introduction or
dissemination of plant pests and
noxious weeds.
The current regulations were
promulgated under former statutes, i.e.,
the FPPA and PQA, which provide
USDA authority to regulate articles that
present a risk of plant pest introduction
or dissemination. In addition to the
provisions of the FPPA and PQA, the
PPA incorporates authority that
previously was under the Noxious Weed
Act of 1974. In order to best evaluate the
risks associate with these GE
organisms and regulate them when
necessary, APHIS needs to exercise its
authorities regarding noxious weed.s and
biological control organisms, in addition
to its authority regarding plant pests.
The definition of plant pest in the
PPA is broad and includes living
organisms that could directly or
indirectly injure, damage, or cause
disease in any plant or plant product {7
U.S.C. § 7702(14)). Under the PPA,
organisms which could be plant pests
include:
• Protozoans
• Non-human animals
• Parasitic plants
• Bacteria
• Fungi
• Viruses or viroids
• Infectious agents or other pathogens
• Any article similar to or allied with
any of the above articles.
The definition of noxious weed in the
PPA includes;
• * ■* any plant or plant product that can
directly or indirectly injure or cause damage
to crops (including nursery stock or plant
products), live.stock, poultry, or other
interests of agriculture, irrigation, navigation,
the natural resources of the United Stales, the
public health, or the environment. (PPA
§7702(10)}
An important distinction between
noxious weeds and plant pests is that
noxious weeds under the PPA are
always plants or plant products. Plant
pests are usually not plants (w'ith the
exception of certain parasitic plants
such as dodder, striga, and witchweed),
but are other types of organisms that
harm plants.
III. Proposed Rule
A. Proposed Regulatory Scope (§340.0
Scope and general restrictions)
We propose to better align the
regulations with the PPA authorities in
order to ensure that the environmental
release, importation, or interstate
movement of GE oigani.sms does not
pose a risk of introducing or
disseminating plant pests or noxious
weeds. Although the current program
has been effective in ensuring the safe
environmental release, interstate
movement, and importation of
genetically engineered organisms,
technological advances have led to the
possibility of developing GE organisms
that do not fit within the plant pest
definition, but may cau.se environmental
or other types of physical harm or
damage covered by the definition of
noxious weed in the PPA. Therefore, we
consider that it is appropriate to align
the regulations with both the plant pest
and noxious weed authorities of the
PPA.
1. Genetically Engineered Organisms
Subject to 7 CFR pari 340
We are proposing to revise the scope
of the regulations in § 340.0 to make it
clear that decisions regarding which
organisms are regulated remain science-
based and take both plant pest and
noxious weed risks into account. The
proposed scope of the regulations states
that genetically engineered organisms
whose importation, interstate
movement, or release into the
environment would be subject to the
regulations are;
Genetically engineered plants if;
(i) The unmodified parent plant from
which the GE plant was derived is a
plant pest or noxious weed, or
(ii) The trait introduced by genetic
engineering could increase the potential
for the GE plant to be a plant pest or
noxious weed, or
(iii) The risk that the GE plant poses
as a plant pest or noxious weed is
unknown, or
(iv) The Administrator determines
that the GE plant poses a plant pest or
noxious weed risk.
Genetically engineered non-plant,
non-vertebrate organisms if:
(i) The recipient organism can directly
or indirectly injure, cause damage to, or
cause disease in plants or plant
products; or
(ii) The GE organism has been
engineered in such a way that it may
increase the potential for it to be a plant
pest: or
(iii) The risk that the GE organism
poses as a plant pest is unknown, or
(iv) The Administrator determines
that the GE organism poses a plant pest
risk.
Under the current regulations, there is
no explicit statement of the relative
responsibilities of the Administrator
and regulated parties in determining
whether an organism met the definition
for regulated article and therefore would
be subject to the regulations. Under the
proposed regulations, the responsible
person for a GE organism could
correctly apply the criteria in § 340.0 to
determine whether the GE organism is
subject to the regulations. Alternatively,
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60012 Federal Register /Vol. 73, No. 197 / Thursday, October 9, 2008 /Proposed Rules
llie Administrator could determine any
GE organism to be regulated after
determining that the GE plant poses a
plant pest or noxious weed risk.
In many cases, it will be very
straightforward for a responsible person
to apply these criteria and determine
that a GE organism is subject to the
regulations. For example, the GE
organism would clearly be subject to the
regulations if the recipient organism
were a plant pest or noxious weed. A GE
organism would also clearly be subject
to the regulations if there was little data
or previous experience available
concerning the recipient organism’s
plant pest or noxious weed potential, or
the type of modification, with the result
that it is difficult to do a reliable
evaluation of the risks that the GE
organism may bo a plant pest or noxiou.s
weed.
In other cases, it may not be readily
apparent to the responsible person for a
GE organism whether or not the
organism falls within the scope of
§ 340.0 and is regulated. For this reason,
persons who are not sure about whether
a GE organism falls within the
regulations or who maintain that a
particular GE organism is not subject to
the regulations based on their belief that
it is not an organism within the scope
of § 340.0 may consult with APHIS.
A GE organism may bo within the
scope of the regulations based on the
information available at the time of the
determination, which is usually loss
information than is available when the
Administrator evaluates, for example,
whether a regulated GE organism should
be considered for an exemption from the
requirement for a permit, or should be
considered for a determination of
nonrt?gulatod status (see discussion of
§ 340,6 below regarding nonrogulated
status). In other words, this scope
determination has one purpose (to
determine whether regulation is
necessary at all) and is based on one
level of knowledge about a GE organism,
while determinations regarding such
things as necessary permit conditions or
exemptions or nonregulated status have
a different purpose and are based on a
different level of knowledge about a GE
organism.
It is important, to note that while a GE
organism may be within the scope of the
regulations due to certain identified
plant pest or noxious weed risks, it may
akso be within the scope of the
regulations if there is not. enough
information about the GE organism’s
potential plant pest or noxious weed
risks to make a decision regarding those
risks. At the early stages of developing
a GE organism, there may not be
sufficient information available about
the organism to clearly determine the
potential associated plant pest or
noxious w^d risks. Unknown risks
might lead to a determination by the
Administrator that a GE organism
should be subjected to regulatory
oversight if APHIS lacks familiarity with
the non-transformed recipient organism
or the introduced trait.
The proposed scope makes it clear
that the mere act of genetic engineering
docs not trigger regulatory oversight or
moan that a GE organism will pose risks
as a plant pest or noxious weed. Instead,
if clarifies that APHIS would subject a
GE organism to regulatory oversight
based upon known plant pest and
noxious weed risks of the parent
organisms, or based upon the traits of
the GE organism, or based upon the
possibility of unknown risks as a plant
pest or noxious weed when insufficient
information is available.
Consultation With APHIS Regarding the
Scope of These Regulations
The criteria described in the scope
should help developers form a
reasonable expectation as to whether
their GE organism is within the scope of
the regulations, based on the nature of
the parent organisms, the engineered
traits, and the amount of information
available regarding the organism and
similar organisms.
APHIS anticipates that initially the
range of GE organisms that the
Administrator may determine to be
covered by the proposed regulatory
scope will be broad. This will be due to
both an initial measured
implementation of the revised
regulatory oversight as well as to the
application of the scope criteria to the
transformed organisms and recipient
traits. Over time, the range of GE
organisms subject to oversight is
expected to decrease as .APHIS becomes
more familiar with these organisms and
receives information from which it can
reach a conclusion that these GE
organisms or groups of organisms do not
present increased or unfamiliar plant
pest or noxious weed risks. Because the
Administrator may make such a
determination at any time the
Administrator receives information that
a GE organism is within the scope,
APHIS expects that developers will seek
early consultation with APHIS on
whether the regulatory scope covers
their GE organism. Since it is generally
necessary for research or business plans
to inclutle, as early as possible, elements
addressing regulatory processing,
approval, and compliance, it will be in
the interest of the developers to
determine the regulatory status of their
GE organism prior to contemplating its
movement or environmental release.
Therefore, APHIS will offer to consult
with a developer of a GE organism
regarding whether the GE organism is
within the scope of the proposed
regulations.
After consultation and review of
available information, the Administrator
will respond in writing as to whether
the Administrator has determined that
the GE organism is within the scope of
the regulations. APHIS plans to make
information publicly available by
posting and maintaining information on
its Web site about the dotorrainations it
makes pursuant to this consultation
process to help the public and regulated
entities understand which organisms are
subject to the regulations.
We welcome suggestions from the
public on the most appropriate ways to
provide administrative guidance to the
public on the issue of which GE
organisms are within the scope of the
regulations. The Agency is especially
intere,sted in ways which will balance
transparency with the efficient use of
Agency resources in conducting
consultations and communicating
information to the public regarding
which GE organisms are within the
scope of the regulations.
Organisms Specifically Excluded From
the Scope of the Regulations
Specifically excluded from the
proposed regulatory scope are GE
microorganisms that are regulated as
biological control organisms by the EPA
under provisions of the Federal
Insecticide, Fungicide, and Rodenticide
Act (FIFRA). APHIS concludes that
there is no need for such GE organisms
to bo evaluated by both agencie.s, EPA
is already evaluating the environmental
safety of such organisms with respect to
their impact on the entire environment,
including plants. We also propose to
retain an exclusion from the current
regulations for GE microorganisnus
where the recipient microorganism is
not a plant pest and which have
resulted from the addition of genetic
material from a donor organism where
the material is well characterized and
contains only non-coding regulatory
regions.
Effect of Noxious Weed Authority on
the Scope of the Proposed Regulations
The definition of noxious weed
encompasses plants that pose risks akin
to plant pests, because it includes “any
plant or plant product” that can “injure
or cause damage to crops * * * other
interests of agriculture * * * or the
environment”, bnt also includes plants
that can pose harm to non-plant
organisms, such as humans. Therefore
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Federal Register/ Vol. 73, No. 197/Thursday, October 9, 2008/Proposed Rules 60013
evaluation of noxious weed risk
expands what wo can consider, while
still including those risks examined
under the plant pest approach. When
considering risks associated with a GE
plant, we would continue to consider
whether it can harm plants, as well as
whether it can cause the other types of
physical harm or damage described in
the definition for noxious weed.
The first consideration in determining
if a plant is a noxious weed is
identifying what direct injury or damage
(physical harm) the plant causes. If
direct harm or damage is established,
the next consideration is to evaluate any
indirect damage the plant may cause to
interests of agriculture, irrigation,
navigation, the natural resources of the
United States, the public health, or the
environment. In general, federally listed
noxious weeds are plants that are likely
to be aggressively invasive, have
significant negative impacts, and are
extremely difficult to manage or control
once established.
The distinction tetween a weed and
a noxious weed warrants emphasis.
“Weeds,” in the broadest sense of the
word, could include any plant growing
where and/or when it is unwanted; even
plants that are desirable in some settings
may be considered weeds in others. In
a narrower sense, weeds are invasive,
often non-native, plants which impact
natural and managed ecosystems, ofien
w'ith significant negative consequences
due to lost yields, changes in
management practices, altered herbicide
use, etc. Only a fraction of these
problematic weeds are considered to be
so invasive, so harmftil, and so difficult
to control that Federal regulatory
intervention to prevent their
introduction or dissemination is
justified, and these are the focus of the
regulatory controls placed on them by
APHIS. However, any weed, and
virtually any plant or plant product, can
be evaluated by APHIS to determine
whether its characteristics and potential
impacts warrant its listing as a noxious
weed.
APHIS currently lists 98 aquatic,
terre.strial, or parasitic plant taxa as
noxious weeds. The species included in
the list illustrate the kinds of plants
APHIS considers to be sufficiently
invasive, damaging, and difficult to
control to be deemed noxious weeds.
Table 1 describes some specific
examples from the Federal noxious
weed list and the kinds of impacts
noxious weeds can have, to illustrate
the types of effects APHIS will be
looking for when evaluating whether GE
plants reviewed under part 340 have
any potential noxious weed traits, The
experience and precedents developed
by the APHIS-PPQ noxious weed
program provide a guide for the
regulation of plants that may be noxious
weeds, and we intend to apply it to the
consideration of GE plants in the same
way.
Table 1— Examples of Impacts Caused by Federally Listed Noxious Weeds
Impact
Description of impact
Example species
Lost productivity of Noxious weeds may directly compete
crop (ieids, with crop plants for limited resources.
drameticafiy reducing yields.
ParasiUc damage to
crops.
Reduced productivity
of pasture.
Injury to humans or
livestock.
Parasitic plants can cause significant
reductions in yield by attaching them-
selves to a host plant, removing nutri-
ents and ultimately killing it.
Grazing animals may avoid noxious
weeds and consume the more favor-
able pasture species, resulting in in-
creased noxious weed populations at
the expense of more favorable spe-
cies. Noxious weeds may also
outcompete desirable pasture spe-
cies.
Many noxious weeds are toxic, harming
humans or livestock either when con-
sumed or by direct contact.
Unchecked over-
growth.
Physical obstruc-
tions.
Noxious weeds may be capable of
completely dominating the landscape
and preventing the use of cultivated
or pasture lands for agriculture.
Growth rate and habit of some noxious
weeds may physically hamper the
movement of livestock and humans,
or interfere with navigation of water-
ways.
Cogongrass {Imperata cylindrica) infests over 20 crop species; it releases
chemicals into the soil that suppress crop growth and causes damaging
puncture wounds to plant roots, bulbs, and tubers. Other examples include
Benghal dayflower (Commetina benghalensis), red rice {Oryza spp,), and
kikuyugrass {Pennisetum clandestinum).
Federally listed noxious parasitic plants include the dodders {Cuscuta spp.)—
with common names like strangleweed. devii's-guts, hellbine, and witch’s
hair — and wrilchweed (Striga spp.), which causes devastating losses in corn,
sorghum, and rice.
Serrated tussock (Nassella trichofoma) has heavily infested large areas, leaving
them completely incapable of supporting livestock,
Cape tulip {Homeria spp.) contains a cardiac glycoside, which can be fatal to
livestock. Contact with giant hogweed {Haracleum mantagazzianum) causes
painful skin blisters. Three-cornered jack (Emex australis) and devil’s thorn
(Emex spinosa) both bear spiny fruits that can cripple or cause injury to live-
stock or other animals.
Mite-a-minute vines {Mikania cordata and M. micrar^tha) can entirely smoltier
fields and forests in a dense, tangled mass of vines. A single plant of the
aquatic weed giant salvinia {Salvinia spp.) can blanket 40 square mites in 3
months, and produce an underwater mat 3 feet thick.
Certain mesquites {Prosopis spp.), joinied prickly pear {Opuntia aurantiaca),
and African boxthorn {Lycium ferocissimum) form impenetrable thickets filled
with thorns or needles, blocking the movement of grazing animals, injuring
them or preventing access to food and water.
Disruption of water
flow.
Aquatic noxious weeds may disrupt
water flow, adversely affecting irriga-
tion, drainage and flood control ca-
nals, city water intakes, and rec-
reational water use.
Notable examples include hydrilla {Hydrilla verticillata), giant salvinia {Salvinia
spp.), and Chinese waterspinach {Ipomoea aquatica). Dense mats of oxygen
weed (Lagarosiphon msyoi) can completely shut down operation of hydro-
electric plants.
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60014 Federal Register /Voi. 73, No. 197 /Thursday, October 9, 2008 /Proposed Rules
Table 1— Examples of Impacts Caused by Federally Listed Noxious WEEDS—Continued
Impact
Description of impact
Example species
Habitat alteration
Noxious weeds may severely alter
water quality by changing oxygen
and nutrient content, may dramafi-
cally lower local water tables, or
could so significantly outccxnpele or
overgrow other vegetation resulting in
a complete ecological shift of the
habitat.
Infestation of l^s and ponds with hydrilla {Hydrilla verticillaia) can alter aquat-
ic ^xtsyslems so drastic^iy that native plants are entirely eliminated, ren-
<^ing the habitat unsuitable for fish and other unidlife.
As discussed above. APHIS’
determination that a plant is a noxious
weed is based on notable physical harm
OF injury caused by the plant. The
elements of the noxious \veed definition
include a number of interests that might
be damaged by noxious weeds including
not only plants but irrigation,
navigation, the natural resources of the
United States, the public health, the
environment and interests of
agriculture. Often APHIS quantifies the
physical harm or injury in terms of
economic losses. Loss in commodity
value due to the presence of noxious
weeds in seeds, for example, is a
consequence of the anticipated physical
damage that would be caused if the seed
containing a noxious weed were
distributed and planted; the economic
loss is never simply the result of market
preference to have commodities free of
certain noxious weed seeds in and of
itself, in the absence of any potential
physical damage or harm. APHIS does
not consider significant economic
effects alone that are not linked to
physical damage to be sufficient to
determine a plant is a noxious weed.
Certainly, some noxious weeds can
cause physical harm to the health of
humans or livestock and other animals.
In general, these impacts occur when
individuals come into direct contact
with the noxious plants or plant parts,
which may cause physical injury or are
toxic or otherwise harmful when
consumed. Conceivably, noxious weeds
growing in crop fields could potenlially
threaten public health, for example, if
toxic parts of the noxious weeds are
harvested and inadvertently enter the
food supply. If such toxic or otherwise
harmful noxious weed parts were found
in food and caused the food to be
"adulterated” within the meaning of the
FFDCA, FDA could take regulatory
action against the food.
Whereas APHIS has no direct role in
ei'aiuating the safety of foods, the
agency plays an important supporting
role in safeguarding the food supply by
protecting the health of plants and
animals at the farm level. When
evaluating whether a particular GE plant
may be a noxious weed because it poses
a public health risk when growing in the
environment, APHIS considers toxicity
and other food safety information,
including the tjrpe reviewed by EPA and
FDA. In the case of GE plants. APHIS
would not ^sess the safety of the GE
plant for human or animal
consumption, but would consider
available information about toxicity and
other food safety information in
assessing noxious weed risk posed by
the plants growing in the environment.
It should be noted, moreover, that
most GE plants that APHIS has been
regulating in the past, such as varieties
of GE com and soybeans modified with
common agronomic traits, do not
qualify as "noxious weeds”. But with
the increasing diversity of both
agronomic and non-agronomic traits
being engineered into plants it is
appropriate to place regulatory controls
upon GE plants proportionate to the
likelihood that they may present a
noxious weed risk until the potential
risk can be appropriately evaluated.
How Non-Plant, Non-Vertebrate GE
Organisms Fall Within the Scope of the
Regulations
The proposed revision of the
regulations retains control for potential
plant pest risks posed by non-plant,
non-vertebrale GE organisms. We would
continue to explicitly use the plant pest
provisions of the PPA for regulating
non-plant, non-verlebratc GE organisms
which align with the taxa listed in the
PPA definition of plant pest. In its
reviews of GE non-plant and non-
vertebrate species, APHIS will continue
to assess GE insects, fungi, bacteria, and
other non-plant, non-vertebrate
organisms for their potential to pose
risks as plant pests.
The scope of the regulations as
defined above makes it clear that it is
the Administrator, and not the public,
who determines whether a non-plant
organism is within or outside the
proposed scope of the Part 340
regulations. APHIS welcomes public
comment on the proposed concise
criteria that the Administrator would
consider when concluding that a GE
organism is not a plant pest. We
envision providing additional
information on the Administrator’s
interpretation on such criteria at the
time of the final rule or in subsequent
administrative guidance,
GE Vertebrate Animals Do Not Fall
Within the Scope, of the Regulations
Although the PPA definition of plant
pest includes the potential for a
nonhuman, vertebrate animal to be
considered a plant pest, APHIS decided
at this time that there are no
demonstrated risks or pending CE
animal developments indicating that it
is necessary for the proposed
regulations to evaluate vertebrate GE
animals as potential plant pests.
Because other statutory authoritievS exist
for addressing GE animals, APHIS could
guard against any plant pest risks that
might bo presented by GE vertebrate
animals without directly regulating
them under the regulations in part 340.
On the other hand, we propose to
regulate GK invertebrate animals under
part 340 because many classes of
invertebrates include known plant pests
(e.g., insects, arachnids, nematodes,
gastropods, etc.).
How GE Biological Control Organisms
(BCOs) Fall Within the Scope of the
Regulations
The PPA defines biological control
organism (BCO) as “any enemy,
antagonist, or competitor used to control
a plant pest or noxious weed” (7 U.S.C,
7702(2)). The PPA gives the authority to
regulate plant pests and noxious weed.?,
not specifically biocontro! organisms.
APHIS recognizes that BCOs may have
the potential to affect populations of
noxious weeds or plant pests, or become
plant pests themselves. To fall within
the .scope of the proposed regulations,
the GE BCO would have to pose a threat
as a plant pest or noxious weed, There
are relatively few examples today of GE
BCOs, but these may become more
common in the future. For example,
some researchers are developing GE
biological control ptnkbollworms that
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Federal Register/ Vol. 73, No. 197 / Thursday, October 9, 2008 /Proposed Rules 60015
are sterile, which achieve their
controlling effect by reducing the ability
of fertile, non-GE pink bollworms to
produce offspring. Such GE pink
boliworm BCOs would fall within the
scope of the proposed regulation,
because they are plant pests. Although
there are currently no examples of using
GE plants as BCOs. such a GE plant
would be evaluated under the proposed
regulations to evaluate whether it is a
noxious weed or a plant pest.
Currently, the federal regulation of
microbial BCOs is regulated by EPA
under FIFRA, and this covers GE as well
as non-GE microorganisms used to
mitigate the effect of pests. Unlike the
PPA, which limits the definition of BCO
only to organisms used to control plant
pests and noxious weeds, FIFRA covers
microorganisms used as biological
control for any pest. APHIS considers it
duplicative to have these regulations
include GE microbial BCOs under its
scope since FIFRA already adequately
covers them, so APHIS is proposing that
the regulatory scope language in
§ 340.0(d) would explicitly exclude GE
microorganisms if they are already being
regulated as BCOs by EPA under FIFRA.
Wo are proposing to only regulate GE
BCO macro-organisms that fall under
the proposed regulatory scope (APHIS-
PPQ currently regulates the macro-
organism non-GE BCOs used to control
plant pests and noxious weeds pursuant
to other regulations). APHIS welcomes
public comment on this aspect of its
proposal.
Intrastate Movements of GE Organisms
Between Contained Facilities and
Activities in Contained Facilities Do Not
Fall Within the Scope of the Regulations
Under the current regulations, certain
GE organisms are only regulated by
APHIS if they are imported, moved
interstate, or released into the
environment. The regulations do not
govern intrastate movements between
contained facilities such as laboratories,
nor do they govern such activities as
creating GE organism in a contained
research laboratory. The proposed
revision does not change this aspect of
the regulations.
2. Deleting the List of Organism.? Wliich
Are or Contain Plant Pests
In § 340.2 of the current regulations,
there is a list of taxa that are considered
to be plant pests. Under the proposed
scope, this list is not needed because we
would not use taxonomic classification
of donor and recipient organisms to
determine if a GE organism is regulated.
When in the course of evaluating a GE
organism APHIS considers whether a
donor or recipient species is likely to bo
a plant pest or noxious weed, we would
consider the most up-to-date pest
information maintained by PKJ. This
information is more specific than the
information in the list of plant pest taxa
in the current r^ulations, and should
be more useful and reliable than static
lists of taxa, APHIS welcomes public
comment on deletion of the taxa list and
preferred sources of plant pest and
noxious weed information for use under
the proposed r^ulations.
With del^on of this list from the
regulations, there is also no longer a
need for the procedure currently
described in § 340.5 for amending this
list.
3. Regulating Whole Organisms, Parts,
and Nonliving Products
APHIS proposes to clarify the
regulated status of nonliving plant
products in the regulations. First, the
PPA defines a plant pest only as any
living stage of any of the articles
specifically named in the plant pest
definition that can directly or indirectly
injure, cause damage to, or cause
disease in any plant or plant product.
Moreover, APHIS does not consider
most GE organisms or parts of GE
organisms which cannot reproduce to
present a risk as plant pests or noxious
weeds.
Conversely, we would regulate
importation, interstate movement and
release into the environment of GE
seedlings, seeds, tubers, cuttings, bulbs,
spores, etc., because there is a
reasonable, albeit small, possibility of
reproduction, establishment, and spread
if these were deliberately or accidentally
released into the environment without
authorization.
Viable pollen from GE plants
imported, moved interstate, or released
into the environment would bo subject
to the regulations because such
movements of pollen can reasonably
lead to genomes becoming established
in the environment. Similarly, in
circumstances where an article
incidentally contains viable pollen,
during movement, APHIS would
consider the movement regulated. There
are many cases, however, when pollen
may be present but is no longer capable
of producing offspring, e.g., nonviable
or immature pollen. In such cases,
APHIS would not r^uire permits under
this part. The commercial distribution
of cut flowers is one pollen movement
situation that APHIS has considered in
light of the regulations, especially in
cases where the flowers are grown in
other countries then import^ only as
cut flowers. APHIS considers these
circumstances to pose little, if any risk,
and therefore would not require permits
for these activities.
The PPA defines a noxious weed as
encompassing both plants and plant
products. A plant product is defined as
“any flower, fruit, vegetable, root, bulb,
seed, or other plant part that is not
included in the definition of plant; or
any manufactured or processed plant or
plant part." APHIS has regulated GE
organisms under part 340 for over 20
years, and there is no shong evidence to
suggest the need to regulate nonliving
(nonviable) plant products in most
cases. However, if in a specific case the
importation, interstate movement, or
environmental release of nonliving
products of a GE plant may pose
noxious weed risks, APHIS has clear
authority to address tho,se risks by
imposing permit conditions on the
handling of such nonliving products of
the GE organism in the permit issued for
the associated living GE organism. The
proposed regulations state clearly in
§ 340.3(b) that the Administrator may
also assign permit conditions addressing
nonliving plant materials associated
with or derived from GE organisms
when ,such conditions are needed to
make it unlikely that the nonliving
materials would pose a noxious weed
risk. APHIS invites consultation from
any person considering a movement or
release of nonliving materials derived
from a GE organism who is uncertain as
to whether it would be regulated.
B. Permits for A uf/jorizj'ng Importation,
Interstate Movement and Release Into
the Environment of Certain GE
Organisms
1. Elimination of the Notification
Procedure
APHIS first added the notification
procedure to the regulations in 1993 as
an administratively streamlined
procedure for certain GE plants that met
the eligibility criteria described in the
regulation. Rather than using
customized requirements, like the
permit conditions used for the
permitting procedure, the notification
procedure uses generalized performance
standards that are described in the
regulation itself. The use of the
performance standards that do notvary
from one notification to the next is one
of the ways that the more rapid
administrative turnaround was
achieved. In some ways, the term
“notification" has been misleading to
the public, since they do not realize that
sending a notification does not mean
automatic authorization by APHIS.
APHIS reviews notifications to verify
that the GE plant meets the eligibility
criteria, and also evaluates whether the
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60016 Federal Register/ Vol. 73, No. 197 /Thursday, October 9, 2008 /Proposed Rules
proposed importation, interstate
movement or environmental release can
bo done in a manner that meets the
performance standards described in the
regulation. In many ways, these APHIS
evaluations for notifications are very
similar to those done for permit
applications, but the notification
procedure relics on applicants agreeing
to meet the performance standards
described in the regulation rather than
submitting an application for APHIS
review describing the specific measures
they will employ for the activity (as is
the case for permits). With permits, but
not with notifications. APHIS can
accept the proposed measures or add to
them and the result is a set of binding
customized permit conditions.
Because the notification procedure
uses only the performance standards in
the regulations, it is more
administratively streamlined, but the
general nature of the standards has
made it difficult for APHIS inspectors to
determine if a notification holder is in
compliance and can also make
enforcement more difficult. For
example, under the current regulations,
one of the performance standards for
notifications relevant to environmental
releases states that: “The field trial must
be conducted such that (1) the regulated
article will not persist in the
environment, and (2) no offspring can
be produced that could persist in the
environment.” Conversely, specific
conditions which APHIS places on
permits are unambiguous, easy to verify
at inspection, and easier to enforce. A
specific permit condition that could be
used to address just part of the
performance standard described above
might read: “After final harvest of the
GE corn plants covered under this
environmental release permit, the site
will be monitored every 4 weeks for the
emergence of volunteer corn seedlings
for one year, and any emerging
volunteer plants will be devitalized
before they produce pollen. Records of
the monitoring and management of
volunteers must be maintained by the
permit holder and made available to
APHIS upon request.”
APHIS employs performance
standards in many of its regulations,
where appropriate. For example, we
propose to employ a performance
standard in another part of this
proposal, container requirements for
shipments of GE organisms. In that case,
it is possible to employ a
straightforward standard that the
container must not break or leak when
subjected to ordinary handling in
transportation. The use of performance
standards under the notification
procedure has some benefits, such as
providing the responsible person with
flexibility in how the standard is met,
e.g.. allowing for appropriate change in
protocols used during the growing
season. However, there are some
disadvantages in not specifically
enumerating the specific measures that
constitute compliance with the
regulations. The permitting procedure
does not have this disadvantage,
because the permit conditions specify
which actions need to be taken by the
responsible person to in compliance.
APHIS considered revising the
performance standards and retaining the
notification procedure, but this would
not have remedied its shortcomings,
especially the lack of specificity that is
a necessity of using broadly applicable,
performance standards in the
regulations.
Under the proposed regulations where
all authorizations will be done under a
permitting procedure, the permit
conditions will provide more specific
information about what procedures the
permit holder must follow in order to be
in compliance. In the proposed rule, we
are describing in detail the types of core
permit conditions that will bo imposed,
plus the additional permit conditions
that the Administrator can place upon
the permit holder in order to make it
unlikely that actions under the permit
woiild result in the introduction or
dissemination of a plant pest or noxious
weed.
In view of the above discussion,
APHIS has determined that it would
have more flexible, risk-appropriate
oversight, bolter regulatory enforcement
and improved transparency if all
regulated importations, interstate
movements, and releases into the
environment arc authorized under the
permitting procedure. The use of the
ponnitling procedure in lieu of
notifications is also necessary for APHIS
to address some of the
recommendations arising from the OIG
Report and the provisions of the 2008
Farm Bill. For example, the OIG
recommendations have led to proposed
provisions in the regulations that will
enable APHIS to add permit conditions
to require additional reports during the
course of an environmental release, the
submission of notices to APHIS if the
permit holder decides not to conduct
the environmental release, and 7-day,
pre-plant notices in the case of GE
plants engineered to produce
pharmaceutical or industrial substances.
The last recommendation is already
being implemented as a permit
condition, because all of these
authorizations are done under the
permitting procedure. The OIG
recommendations cannot be
implemented under the notification
procedure, because under the current
regulations APHIS does not have the
ability to attach conditions to
notifications. This provides additional
justification for APfilS to propose the
elimination of the notification
procedure. The APHIS proposal to
eliminate the notification procedure is
an effecti\re way to address several of
the provisions of the Farm Bill, such as
the changes to the requirements for
recordkeeping and reporting.
2. Revisions to Permit Procedures
APHIS proposes to reorganize the
regulations to improve the clarity of the
permit application and evaluation
procedures. The proposed change is
more a reorganization than substantive
change, and should enhance the
transparency of the regulations to the
public. The permitting procedure will
continue to identify and obtain
information relevant to evaluating the
risks associated with a proposed
importation, interstate movement, or
release into the environment, and
determine and document whether, and
under what conditions, the activity
should be allowed. The proposed
regulations related to the issuance of
permits are divided into two sections.
The first is proposed § 340.2, Procedure
for permits, which describes permit
types, the procedure for permit
application (including information
requireraonts), and the Agency’s
administrative actions for permits. The
second is proposed §340,3, Permit
conditions, which describes the general
types of conditions that APHIS may add
to a permit, and the obligations of the
responsible person after permit
issuance.
APHIS is proposing explicit
procedures for amendment, transfer of
responsibility, and revocation of permits
in order to establish clear regulatory
procedures that can increa.se efficiency
yet maintain adequate safety. Currently
the APHIS administrative practices to
amend, transfer, and revoke permits
have not been explicit in the regulation,
and this addition will provide increased
transparency and efficiency.
The proposed changes organize the
regulations to more clearly reflect the
procedural steps in the application,
evaluation, and issuance of a permit (see
Figure 1). First, the different types of
permits (importation, interstate
movement, and environmental release)
are described in § 340.2(b), a.s are new
subcategories of environmental release
permits. Second, the types of
information that must be submitted with
a permit application are described in
§,340. 2(c). The permit type, as well as
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Federal Register/Vol. 73, No. 197/Thursday, October 9, 2008/Proposed Rules 60017
the nature of tlie environmental release
(if the permit is for a release), affect the
application information requirements.
Third, § 340.2(d) outlines the procedural
and administrative steps of issuing a
permit. Finally, the attachment of
conditions to permits, which is also
dependent upon permit type and release
category, is described in § 340.3. Each of
these permit-related s«rtions of the
proposed regulations is discussed
below.
Figure 1. Schematic of activities
associated with issuance and
enforcement of permits, showing
associated sections of the proposed
regulation,
Permit Types and Environmental Release Categories (§ 340, 2(b))
1
Application Information Requirements, by Type (1340.2(c))
1
Peitnit Evaluation Procedures (§ 340.2(d))
i
Assignment of Permit Condition.s (§ 340.3)
Compliance, Enforcement, and Remediation Activities (§ 340.7)
3. Permit Types and Environmental
Release Categories (§ 340.2(b))
As discussed above in the background
section, APHIS currently uses two
procedures — notification and permits —
to authorize the importation, interstate
movement and release into the
environment of GE organisms
considered to bo regulated articles
under this part. The permitting
procedure can be used for all regulated
articles, but Ilia notification procedure
can be used only for certain GE plants
that meet the eligibility criteria
described in the regulations. Whereas
permits are issued with explicit permit
conditions which must be mot by the
permit holder, notifications have
generalized “performance standards"
described in die regulation and
therefore do not vary from one
notification to the next. Currently,
approximately 90% of APHIS
authorizations are done under the
notification procedure.
Under the proposed system, which
would eliminate notifications, APHIS
w'ould continue to Issue three types of
permits — interstate movement,
importation, and environmental release.
The procedures for the first two types of
permits are relatively straightforward,
and the conditions usually required for
these permits address risk.s that are very
similar from one shipment to another.
We propose only minor adjustments to
the prot:edures for interstate movement
and import permits. In general,
deliberate release of GE organisms into
the environment presents a greater risk
of introducing or disseminating plant
pests and noxious weed.s, and thus
requires more careful oversight, than
shipments of GE organisms into and
across the country in secure containers.
Of the three permit types, only
environmental release permits would be
differentiated into broad risk-related
categories by the Administrator. This
categorization would occur prior to the
detailed and specific APHIS evaluation
of an individual permit application.
Table 2 summarizes the relationship of
the three permit types and categories
that pertain to environmental release
permits.
Table 2— Proposed Permit Types and Categories for Environmental Release Permits
Type
Use
For securely moving a GE organism Into the
United States.
For securely moving a GE organism from any
State into or through any other State.
For releases into the environment, outside the
constraints of physical containment that are
found In a laboratory, contained green-
house, fermenter, other contained structure,
or secure shipment.
Release Category E (non-plants)
’ In some cases, an environmental release permit may also incorporate permits for imp<Mtalion or interstate movement when such movements
are incidental to the environmental release.
The proposed .sorting system for
environmental release permits includes
five categories: Four for releases of GE
plants (Categories A-D) and one for
releases of all other GE organisms
(Category E). Releases of GE non-plant
organisms (Category E) would be placed
into a single category and reviewed on
a case-by-case basis. APHIS considered
the creation of smaller risk-related
subcategories for non-plants, but APHIS
has received too few permit applications
to warrant the creation of these smaller
groupings. Releases of plants would be
grouped into four categories, as
described below.
APHIS considered a tiered permitting
system which would sort proposed
environmental releases of plants into a
number of risk-based categories. Lowest
risk releases would he assigned to Tier
1, slightly higher risk releases in Tier 2.
and so on. In such a system, tier
assignment is analogous to a risk rating.
In developing the specifics of
implementing such a system in the
regulations, however, APHIS found that
it was challengii^ to pre-assign all
conceivable releases into tiers
representing discrete levels of risk.
There are a large number of risk factors
that contribute to the overall risk
associated with any given release. These
factons include reproductive biology and
growth habit of the .species, potential for
gene flow to other species, phenotype
engineered into the organism,
familiarity with the genetic material
used, safety of any expressed products,
scale of the release, location, duration,
experience, and compliance history of
the applicant, proximity to threatened
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60018 Federal Register/ Vol. 73, No. 197/Thursday, October 9, 2008 /Proposed Rules
and endangered species, and other
factors.
Sorting proposed releases considering
ail relevant factors would lead to an
unwieldy system with many risk-based
categories, and would essentially
require a hill risk assessment prior to
assigning a proposed release to the
appropriate risk category. Consequently,
it would be nearly impossible for
applicants and the public to predict the
risk tier to which a proposed release
would be assigned.
APHIS proposes that the permitting
system for environmental release
permits would assign releases into
administrative categories based upon
two primary risk-related factors
described below, so that the categories
would identify the general types of
releases of plants which share broadly
similar risks and management issues.
This initial administrative sorting
would be followed by an evaluation that
fully characterized the risk of the
proposed release, which would then be
the primary basis for adding necessary
permit conditions. APHIS concludes
that such a system could appropriately
sort most releases into groupings that
are alike enough that they could usually
bo treated similarly initially, in terms of
application information requirements
and evaluation of potential risks. In
most cases the initial groupings would
also result in a similar level of oversight
of the release and conditions attached to
the permit-but any final determination
of the permit category, oversight and
permit conditions would depend on the
results of the APHIS evaluation.
Using this approach, there is no prior
conclusion that every release within the
same category poses the same level of
risk. Likewise, releases in different
categories do not necessarily pose
greatly different risks. For this reason,
APHIS would not refer to these
groupings as “tiers,” as this implies an
incremental increase in risk from tier to
tier, but would instead label them as
“categories” which are lettered and not
numbered.
APHIS developed the proposed
sorting scheme by first examining the
types of releases that typically are
authorized under its current regulations.
APHIS then modified the categories to
make them more explicitly connected to
plant pest and noxious weed risks.
The two primary factors APHIS
identified as most relevant to define its
sorting system for environmental release
permits were the (1) ability of the
unmodified recipient plant species to
persist in the wild and (2) potential of
the engineered trait to cause harm,
injury, or damage, as described in the
definitions of plant pest and noxious
weed. Secondary factors, w^hich in some
instances may change the initial
cat^orization, include: how the
recipient plant is commonly used (e.g.,
as a food or feed crop); the impact of the
engineered trait on the fitness of the GE
plant: and, the degr^ of uncertainty
associated with the trait and its possible
impacts.
Regarding the persistence factor,
APHIS proposes to group plant species
according to the risk of persistence of
the plant or its progeny in the
environment without human
intervention. Based upon the growth
habit of the plant species and presence
of wdld relatives in the United Slates,
APHIS proposes to sort all plants into
four groups, listed in ordw of increasing
persistence risk:
• Low: Populations of the recipient
plant are unlikely to persist in the
environment without human
intervention, and the recipient plant has
no interferlile wild relatives in the
United Stales. Examples include corn,
soybeans, and cotton (except in certain
areas).
• Moderate: Populations of the
recipient plant are known to be weakly
persistent in the environment without
human intervention, or the recipient
plant has interfcrtile wild relatives iii
the United States. Examples include
alfalfa, beets, canola, rice, and tomato.
• High: Populations of the recipient
plant are known to be strongly
persistent in the environment without
human intervention, or the recipient
plant has interferlile wild relatives in
the United Stales which are aggressive
colonizers, Examples include creeping
bentgrass, poplar, sorghum, and
sunflower.
• Severe: The recipient plant is a
Federally-listed noxious weed or is
known to be similarly aggressive in its
ability to colonize and persist in the
environment without human
intervention. Examples include hydrilla
and kudzu.
These aspects of plant biology and
growth habit are broad indicators of the
increasing likelihood that the plant or
its progeny can reproduce and spread
without human intervention.
“Interferlile wild relatives” includes
both wild relatives in the traditional
sense, as well as feral populations of the
same species pereisting outside
agroecosyslems. The distinction
between “weakly persistent” and
"strongly persistent,” is intended to
mean survival without human
intervention for one or very few
generations (weakly persistent) versus
several to many generations (strongly
persistent). APHIS will clarify which
species fall into each group by
publishing lists in guidance.
Similarly, with regard to the factor for
potential harm caused by introduced
traits, APHIS proposes to group traits
engineered into plants into four simple
groupings based upon the definitions of
plant pest and noxious weed. The
groups are listed in order of increasing
potential hazard of the engineered trait:
• Low:
o Any new proteins or substances
produced are unlikely to be toxic or
otherwise cause serious harm to
humans, vertebrate animals, or
invertebrate organisms upon
consumption of or contact with the
plant or plant parts; and
o No morphological changes which
could cause mechanical injury or
damage; and
O Introduced sequences are known
not to result in plant disease, and
confers no or very low increased disease
susceptibility.
An example would include
expression of well characterized
proteins known not to be toxic or
harmful, such as a marker gene that
does not pose a food or feed safety
concern, or expression of viral genes
where it is demonstrated that no protein
is produced
• Moderate:
o Any new proteins or substances
produced are unlikely to be toxic or
otherwise cause serious harm to humans
or vertebrate animals upon consumption
of or contact with the plant or plant
parts ; or
o Novel resistance to the application
of an herbicide; or
o Has novel ability to cause
mechanical injury or damage; or
0 Produces proteins or substances
that are associated with plant disease
that are not prevalent or endemic in the
area of release, or that confer an
increased susceptibility to disease.
Examples include expression of now
CRY proteins, .mechanisms of herbicide
tolerance (e.g., CP4-EPSPS, which
confers giyphosate tolerance), and
production of viral movement proteins.
• High:
o Any new proteins or .substances
produced may be toxic or to otherwise
cause serious harm to himians or
vertebrate animals, upon consumption
of or contact with the plant or plant
parts; or
o Produces an infectious entity which
can cause disease in plants.
Examples include mercury hyper-
accumulators or production of some
pharmaceulical compounds.
• Severe:
Any now proteins or substances
produced are known or likely to be
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Federal Register/ Vol. 73, No. 197/Thursday, October 9, 2008/Proposed Rules 60019
highly toxic or fatal to humans or
vertebrate animals, upon consumption
of or contact with the plant or plant
parts.
These aspects of the engineered trail
are related to harms or damages
associated with plant pests or noxious
weeds. This takes into consideration (1)
the harmfulness of any substances
produced, (2) the possibility of creating
morphological changes that would
cause physical injury, and (3) the
likelihood of increasing plant disease,
cither due to risk of creating novel pests
or increased inoculum source. Novel
resistance to an herbicide is included in
the “moderate” category due to the
impacts the trait could have on the
ability to manage the plant or its
progeny.
The proposed use of plant growth
habit and trait harm or injury as the two
main factors for the initial sorting of
environmental releases into categories
uses the two factors to roughly
approximate “exposure” and “hazard.”
respectively. Thus, using a combination
of these two factors alone, we propose
the following initial sorting of plant-trait
combinations into release permit
categories (see Table 3). Once
environmental releases of GE plants
have been sorted into the permit
categories shown in Table 3, we will
review and evaluate the information
submitted by the applicant to determine
oversight and permit conditions. The
information requested from applicants
will not be limited to these factors and
is, in fact, designed to allow us to
evaluate any of the risks associated with
noxious weeds and plant pests. In some
instances, our review may result in a
change to the release category
assignment of a GE plant.
Table 3— Initial Sorting Into Administrative Permit Categories (A. B, C, and D) for Environmental Releases
OF GE Plants, Based Upon Persistence Risk of the Recipient Plant Species and Potential Harm or Dam-
age OF THE Engineered Trait
Persistence*
1 Potential harm or damage of engineered trait
Low
Moderate ;
High
Severe
Low
A
A
C
D
Moderate
A
B
C
D
High ...
B
B
C
D
Severe
D
D i
D
D
* Persistence risk of the recipient plant species.
The sorting system above presumes
that there is sufficient scientific
information available about the GE plant
to support the categorization. For
example, the phenotype conferred by
inserted sequences and the growth habit
of the plant species in the U.S. must be
woll-characlerizod and based upon
direct empirical observation of the
genetic construct in the recipient plant
species. In cases where less (or nothing)
is known about phenotype of the
engineered trait in the recipient plant
species-such as inference based upon
sequence similarity, protein structure
modeling, or observation of the genetic
construct in other species-the release
category may be changed (from A to B
or B to C) as a result of this uncertainty.
Similarly, lack of familiarity with the
plant species’ beha^dor in the U.S. or the
techniques needed to mitigate the
likelihood of its persistence could also
change the release category.
APHIS considered whether to adjust
the categories table to acknowledge that
an engineered trait could affect
(enhance or detract from] the other
factor axis, namely the persistence risk
of the nomnodified recipient plant.
Engineered trails such as resistance to
biotic or abiotic stresses could
theoretically increase the fitness of the
plant, and thereby increase the
likelihood that it will persist in the
environment without human assistance.
Considering the range of persistence
risks posed by all of the different plant
species sorted into any one of the
proposed groupings, however, APHIS
has concluded that in most instances
the engineered trait would not alter the
likelihood of persistence enough to
warrant a change in initial release
category. However, in cases where the
engineered trail significantly alters plant
growth habit, metabolism, or
reproduction to increase the likelihood
of persistence in the environment,
APHIS could change the release
category accordingly. Examples of such
changes might include converting an
annual species to a perennial or
converting a plant with C3 metabolism
to crassulacoan acid metabolism (CAM).
The proposed category system should
provide a simple, transparent way for
APHIS review information in
applications to initially sort releases
into broad, risk-related categories,
which can then be more efficiently
assessed for the actual risks posed by
the release. However, it should be
emphasized that the categories are
intended only for initial sorting, and
other factors arc taken into account in
the APHIS evaluation when determining
the specific permit conditions.
APHIS intends that release Category A
will be associated with a level of
regulatory oversight similar to
environmental release notifications
under the current system, and
Categories B and C with a level of
regulatory oversight similar to various
permits that have been issued under the
current system. However, it will bo
much clearer to the public what types
of oversight will be applied broadly
within each category. As we discussed
above, oversight and permit conditions
with each category will be similar,
though not necessarily identical, for any
plant within the category, Category D
was created to acknowledge the
possibility that some proposed releases
may pose a very high risk of introducing
a highly persistent or harmful plant into
the environment, To date, APHIS has
never been requested to allow releases
that would fall into this category. If an
applicant were to propose a Category D
release, APHIS would only authorize
such releases after imposing extremely
strict levels of oversight akin to high
security quarantine far exceeding that of
Category C that would ensure that the
GE plants could not persist in the
environment. The information
requirements, permit conditions, and
general levels of oversight ossociated
with each release Category arc discussed
below.
This simple sorting system places GE
plants into categories and provides a
relatively clear, simple rationale for
placement in a given category. What
follows is a series of illustrations of
common plant-trait combinations and
the release categories to which they
would be assigned;
• Category A:
o Bt corn producing CRYlab toxin.
The plant is unlikely to persist in the
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60020 Federal Register/ Vol. 73, No. 197/Thursday, October 9, 2008 /Proposed Rules
environment and the safety of the
protein has been as.sessed by the EPA.
o Soybeans engineered with
glyphosate tolerance conferred by CP4-
EPSPS. While herbicide tolerance poses
a “moderate” hazard, soybean has no
interfertile wild relatives in the U.S..
• Category B:
Corn producing a new CRY protein.
The plant is unlikely to persist and the
novel CRY protein is likely to be toxic
to some species that live or feed on the
plant (normally Category A), but its
food/feed safety is only inferred from
similarity to other CRY proteins.
o Random “knock-out” or antisense
libraries of soybean lines. While the
lines may not likely produce novel
proteins or substances (Category A),
because of the uncertainty associated
with the impacts of genetic engineering
on these lines, they would be treated as
Category B. Well-characterized lines
taken from such libraries that do not
produce new proteins would likely be
treated as Category A.
0 Kentucky bluegrass engineered
with glyphosate resistance conferred by
CP4-EPSPS, Herbicide resistance is a
"moderate” hazard and bluegrass has
interfertile wild relatives in the U.S.
o Pines producing an enzyme to
enhance paper production. Pines are
persistent and have interfertile wild
relatives in the United States.
• Category C:
o Poplar engineered to produce
enzymes for heavy metal
bioreniediation,
• Category D;
<7 Any Federally listed noxious weed
that has been genetically engineered;
any GE plant producing a vertebrate
toxin.
Permits for Environmental Releases of
Plants Making Pharmaceutical and
Industrial (PMPI) Compounds
APHIS considered whether to
continue to issue environmental release
permits for GE plants engineered to
produce pharmaceutical and industrial
compounds if the GE plant species is
the same as, or sexually compatible
with, a species commonly used for food
or feed. APHIS concludes that the
proposed permitting procedure and the
u.se of stringent permit conditions can
continue to effectively minimize the
risks that may be associated with the
environmental release of such GE
plants. APHIS will continue to impose
permit conditions that take into account
the issues related to the safety of
proteins or other substances that these
plants have been engineered to produce.
Based upon APHIS experience to date,
many releases of GE plants producing
pharmaceutical or indiistrial substances
would fall in Category C, and would
carry the same level of oversight as
current permits for PMPI.
4. Permit Application Information
Requirements {§ 340.2(g))
In the proposed regulations, we
provide greater detail about the basic
application information requirements
that need to be addressed in all permit
applications, as well as additional basic
information required for each permit
typo and the categories in the case of
environmental release permits. Under
the current regulation, certain areas
where APHIS routinely needs
information from the applicant do not
become apparent until the applicant
submits the permit application (and
APHIS subsequently follows up for
additional information). Some of the
information requirements related to
recordkeeping, reporting, and
contractual arrangements among the
permit holder and agents are new to the
regulation and reflect, in part, certain
provisions of the 2008 Farm Bill and
also align with recommendations of
USDA’s OIG 2005 Report. For example,
the OIG recommendations have led to
provisions that will enable APHIS to
require geographic t:oordinates for the
locations of environmental releases.
The differences between the
information required for an application
under the current regulations versus the
proposed regulations may be seen by
comparing current § 340.4 to proposed
§ 340.2(c). Both the current and
proposed application procedures
require information characterizing the
nature of the GE organism, including
detailed molecular biology information
about the expre,ssion of the introduced
genetic material. They also both require
information about the typo of movement
and/or release planned. The proposed
rule requires more detail in some of
these areas, and more description of the
applicant’s plans and methods to
prevent unauthorized releases, and to
respond to unauthorized releases if they
occur. This information is used in part
by APHIS to formulate the specific
permit conditions. In cases where the
permit is for environmental release, and
would be in permit categories C or D
according to the table in § 340.2(b)(3), a
greater level of detail would be required
for almost all aspects of the activity,
including the recipient organism, the
inserted gene(s), site location and
management practices, and training and
communication among the permit
holder and agents involved in the
activity covered under the permit. This
information would also address the
capability of the organism to persist or
spread in the environment, or include
details about how the engineered trails
might be harmful.
5. Permit Conditions (§340.3)
Conditions are specific practices or
requirements that an applicant must
follow upon issuance of a permit Under
the current regulation, the permit
conditions are described in the same
section as the permit procedure itself. In
the proposed revision, the permit
conditions are enumerated in a separate
section {§ 340.3) to accommodate the
additional details to describe conditions
for the throe permit types as well as the
categories of environmental release
permits.
The use of permits and permit
conditions gives APHIS and the
responsible person a clearer
understanding as to what actions must
be taken for the permit holder to comply
with the regulation. In the proposed
regulation, APHIS has strived to provide
as much transparency and predictability
as possible about permit conditions
while retaining sufficient flexibility so
that the regulations will be adaptable in
a broad range of cases.
Permits will be i.ssued with the core
permit conditions described in
§ 340. 3(a}, which are a minimum set of
basic conditions for importation,
interstate movement, and relea.se. The
Administrator may add to these
conditions additional or expanded
conditions when necessary to make it
unlikely that actions under the permit
would result in the introduction or
dissemination of a plant post or noxious
weed.
The Administrator will assign the
permit conditions in a manner that is
commensurate with the rivsk of the
individual proposed movement or
release. Additional or expanded permit
conditions may include, but are not
limited to, specific requirements for:
reproductive, cultural, spatial, temporal
controls; monitoring; post-termination
land u.se; site security or access
restrictions: and management practices
such as training of personnel involved
in the release.
The proposed description of permit
conditions elaborates on the "standard"
permit condition.s found in the current
reguhitions, and the additional detail is
designed to better communicate with
potential applicant.? what the
requirements are likely to be for their
particular permit, and will better
support administration of the program,
including compliance and enforcement.
In the current regulation, only
“standard” permit conditions are
described, and APHIS has the authority
to place other conditions upon the
permit as deemed nece.s.sar5' by the
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Federal Register/Vol. 73, No. 197/Thursday, October 9, 2008/Proposed Rules 60021
Adminislrator. The proposal for permit
conditions will be more transparent to
the public and this transparency will
better facilitate planning by researchers,
especially those who have not
previously received permits from
APHIS.
The proposed required core permit
conditions consolidate six primary areas
addressed in different parts of the
current regulations to ensure
compliance with the regulation and to
make it unlikely that the permitted
activity will result in the introduction
and dissemination of a plant pest or
noxious weed: Identity, shipment,
unauthorized dissemination,
communication and training, records,
reports and notices. APHIS intends the
list of specific condition areas we
propose in § .140.3 to be used for all
permits we issue as they apply to
importation, interstate movement, and
release into the environment. The
required permit conditions listed in
§ 340.3 represent the permit conditions
that we propose to apply for any type
of permit. Listing them in the
regulations should provide applicants
with the ability to plan their activities
with knowledge of the primary
requirements for ail activities that
would have to be met to comply with
the regulations.
For environmental release permits,
proposed § 340.3(a)(4KiiiKF) would also
require the permit holder to notify
APHIS seven days prior to initiation of
the release if the release is Category C
or D. For all Categories, permit holders
are required to notify APHIS if they do
not conduct the release.
The current regulations require
environmental release permit holders to
.submit field test reports to APHIS
within 6 months after termination of a
field test. Under proposed § 340.3(a), the
requirement simply states that the
responsible person shall submit reports
to APHIS at the times specified in the
permit conditions and containing the
information specified in the permit
conditions.
APHIS is also propo.sing revision of
the regulations to clarify the procedure
it would use for amendment of permit
conditions, transfer of a permit to a
different responsible person, and
revocation of an existing permit. Each of
these additions to the regulations reflect
current administrative practices and the
incorporation of these into the
regulations will make the overall system
more transparent.
Currently. APHIS attaches conditions
to permits at the moment the permit is
issued to the applicant. Under the
current regulations, the permitting
procedure does not include a formal
acknowledgement from the applicant
prior to permit issuance that they are
aware of and consent to the permit
conditions. To verify that applicants are
aware of and willii^ to abide by the
conditions, APHIS proposes to add an
additional administrative step in the
permit procedure in § 340.2(d)(6) to
support administration of the program.
We are proposing to require that
applicants agree prior to permit
issuance that they will comply wdth all
the permit conditions. Eventually,
APHIS would build this feature into the
existing ePermits system, and in the
interim it would provide alternative
mechanisms, such as e-mail
communications, to implement this step
of the permitting procedure,
APHIS is also proposing to clarify in
§ 340.2(h) of the regulations the
procedure to be used when amendment
of existing permit conditions is sought
by the responsible person or required by
APHIS, as well as the procedure for
transfer of an existing permit to a
different responsible person.
As with the current regulations,
APHIS is retaining the flexibility to
modify permit conditions as needed
under individual circumstances.
Proposed §340.3 will increase
transparency, yet still allow sufficient
adaptability of the regulations for the
full range of permit applications APHIS
expects to receive today and in the
future. APHIS recognizes that
transparency and predictability for
applicants must be balanced with
maintaining Agency flexibility and
adaptability for years to come under
these regulations. APHIS encourages the
public to comment on the choices we
arc proposing here, and we welcome
suggestions for alternative approaches.
APHIS is proposing to revise the
current sections of the regulation,*? for
container requirement.? for shipments of
GE organisms (§ 340.8) and marking and
identity requirements for imports of GE
organisms (§340.7). Rather than the
highly prescriptive approach in the
current regulation, we will use an
approach that is performance based and
can be adapted to the activity that is
being performed. This should provide
greater efficiency for the public as well
as APHIS, yet still achieve the necessary
level of containment during shipments.
We have reorganized this information in
the regulations so that the requirements
are as.sociated with the related activity
under the proposed regulation. For
example, the shipping requirements for
interstate movements under the
conditional exemption have the
requisite shipping conditions stipulated .
in the section for conditional
exemptions. Likewise, the shipping
conditions for import and interstate
movement permits have been placed in
the section for permit conditions, rather
than retaining them in a separate section
as in the current regulations. The
performance-based standard.? we are
proposing incorporates a simple
performance standard in our proposed
definition of .secure shipment, discussed
below: “Shipment of a package of
sufficient strength and integrity to
withstand leakage of contents, shocks,
pressure changes, and other conditions
incident to ordinary handling in
transportation.” APHIS is also
proposing to require applicants to
provide their proposed methods of
secure shipment, and APHIS will
specify the methods of secure shipment
as a permit condition.
APHIS proposes to eliminate the
marking and identity requirements for
imports of GE organisms as a separate
section of the regulations (current
§ 340.7), As with the container standard
issue discussed above, appropriate
labeling and related requirements would
be highly individual depending on the
organism, type of permit, and other
conditions.
APHIS is proposing to include
relevant tribal officials when it provides
copies of permit applications to state
regulatory officials. The current
regulations state that APHIS provides
this information to state regulatory
officials.
6. Elimination of Courtesy Permits
APHIS is also proposing to eliminate
the issuance of courtesy permits.
Courtesy permits have been part of the
regulations since their inception in
1987, but in an effort to better allocate
APHIS resources, APHIS is proposing to
remove this regulatory feature, The
current regulations provide the ability
for APHIS to issue “court©.sy permits,”
in order to facilitate the movement of
organisms which are outside the scope
of those regulations, but whoso
movement might otherwise be hindered
because of their similarity to organisms
regulated under these regulations. The
issuance of courtesy permits has
generated confusion in the public and
especially in the research community.
The application form for courtesy
permits is identical to the application
for other type,? of permit,?, and the
courtesy permit itself looks like other
permits, This has led to the wide.spread
misunderstanding by some researchers
that courtesy permits are actually
required for the movement of certain
organisms, or that issuance of a courtesy
permit removes the requirement for
applicants to have other authorizations
which may be required, under plant
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60022 Federal Register/Vol, 73, No. 197/Thursday, October 9, 2008/Proposed Rules
pest regulations such as those found at
7 CFR part 330. APHIS commits
significant resources to the issuance of
these courtesy permits for the
movement of organisms w^hich are not
subject to the provisions of part 340.
APHIS will work with researchers and
relevant government regulatory officials
to facilitate the transition.
APHIS will also be available for
consultation by persons who formerly
used courtesy permits and other persons
moving similar non-regulated articles, to
discuss how to facilitate their
movement. We also encourage the
public to comment on the proposed
elimination of courtesy permits and
how APHIS should work with persons
moving organisms for which we might
formerly have issued courtesy permits.
C. Conditional Exemptions From Permit
Requirement (§340.4)
The PPA allows the Secretary to
create “exceptions” to the permit
requirement when the Secretary deems
that a permit is not necessary. That Is,
the.so regulated activities are allowed,
under certain conditions, without
seeking prior authorization via permit
The current APHIS regulations contain
such PPA exceptions, but they are
referred to as ‘’exemptions” in the
regulations. The current regulations
include conditional exemptions from
the requirement for interstate movement
permits. These conditional exemptions
were established in the regulations
during the first few years after the
regulations were first promulgated. The
last conditional exemption was
established in the regulations in 1990
for the interstate movement of GE plants
of the species Arabidopsis tbaliana as
long as the conditions described in the
regulations are met.
In its proposed revision to the
regulations, APHIS is retaining the
existing conditional exemptions from
interstate movement. We are also
proposing a new regulatory procedure
that would enable APHIS to approve
new conditional exemptions more
efficiently than using the procedure of
notice and comment rulemaking for
each individual exemption. This can be
a transparent and efficient way to
provide regulatory relief. This new
procedure for approving conditional
exemptions is described in § 340.5, and
it incorporate.s transparent steps
including scientific review, public
input, and adaptability when APHIS
establishes the conditions relevant to
the specific conditional exemption.
Conditional e.xemptions, by their nature,
will always include conditions and
continued APHIS oversight to ensure
that the conditions are met.
The current r^ulations provide for
conditional exemptions from the
requirement for permits for the
interstate movement of certain GE
strains of the microorganisms
Escherichia coli, Saccharomyces
cerevisiae, and Bacillus subtilis, and the
plant Arabidopsis thaliana in § 340.2(b),
and these conditional exemptions are
being retained under the proposed
regulations. Conditional exemptions
from permit have been part of the
regulations since the first exemption
was established in 1988 (for the
interstate movement of certain GE
microoi^anisms). with the addition of
another conditional exemption, through
rulemaking, in 1990 for certain types of
GE Arabidopsis thaliana, one of the
most commonly used plants for
scientific studies and which is
frequently distributed among
researchers. The essential conditions for
each of these conditional exemptions
address the following; (1) Species of the
GE organism, (2) the types of genetic
modifications that are allowed or
prohibited for the GE organism, and (3)
the manner in which the GE organism
is shipped interstate. The existing
conditional exemptions for the
interstate movement of microorganisms
were based on APHIS’ conclusion that
the exemption from the requirement for
permits for interstate movement of these
microorganisms would “not pre.sent a
risk of the introduction or dissemination
of a plant pest” (53 FR 12910, p. 12910).
The existing conditional exemptions
for E. coh. Bacillus subtilis,
Saccharomyces cerevisiae and
Arabidopsis thaliana are being retained
in the proposed regulations. APHIS has
no information that would indicate tliat
such conditional exemption would bo
result in the introduction and
dissemination of a plant pest or noxious
weed. The text of the conditional
exemption is being updated to place the
shipping requirements with the other
conditions associated with the
exemption, in.stead of the current
regulatory organization that has the
shipping requirements in a separate
section of the regulation.
In addition to the existing conditional
exemptions, APHIS is proposing a
transparent and efficient petition
procedure in § 340.5 whereby the
Administrator may approve additional
conditional exemptions from permit
without havii^ to amend the
regulations. This procedure would
provide for a scientific review by APHIS
as well as the opportunity for public
review and comment on the scientific
basis for the proposed exemption and
the conditions associated with the
exemption. The proposed procedure
would provide an adaptable means of
ensuring that the regulatory oversight is
proportional to the risks posed by
specific activities with GE organisms.
Proposed § 340.5 describes the
procedure whereby a petitioner would
seek a determination by the
Administrator that the importation,
interstate movement, and/or release into
the environment of a GE organism is not
subject to the requirement to have a
permit under this part. We propose that
the Administrator’s decision to approve
an exemption would be based upon a
determination that the exemption from
the requirement for a permit, when
conducted wnth the associated
conditions, is unlikely to result in the
introduction or dissemination of a plant
pest or noxious weed. APHIS
anticipates that creating thi.s new
petition procedure to allow approval of
additional conditional exemptions
would enhance its ability to cu.stomize
regulatory oversight to be proportional
to any risks associated with importation,
interstate movement, or release into the
environment of a GE organism.
Under the proposed procedure,
petitioners have the flexibility to
propose various typos of conditional
exemptions from the requirement for a
permit: The proposal can be for on© or
more permit typos (importation,
interstate movement, or release into the
environment), In addition, the petitioner
can propose the relevant conditions,
The Administrator may approve the
proposed conditional exemption as
submitted in the petition, or tho
Administrator may impose alternatives
to the requested exemption and
conditions. The Administrator would
review the scientific information and
evaluate potential risks relevant to the
proposal, then make the relevant
documents (proposal and any
supporting information) available to the
public for review and comment prior to
the Administrator’s decision.
The information needed for a petition
for conditional exemption would
depend on the nature of the exemption,
requested and the proposed conditions
for exemption. For example, conditional
exemptions for the interstate movement
of narrowly-defined groups of organisms
with restrictive associated conditions
might require considerably less
information to jmstify than exemptions
for broadly defined groups of organisms
or less restrictive associated conditions.
In making its determination, APHIS
would consider all relevant information,
including information in the scientific
literature, copies of unpublished
studies, and reviews by other regulatory
agencies.
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APHIS foresees many advantages to
the proposed procedure, including
scientific rigor, public involvement, and
regulatory efficiency. APHIS would
continue to provide to the public the
relevant scientific information under
consideration, its environmental
analysis, and the rationale for its
determination. The public would also
retain its ability to provide comments to
the agency prior to a decision approving
a new exemption. APHIS decisions
regarding these newly approved
conditional exemptions would be
published in the Federal Register and
maintained on a list accessible to the
public.
In evaluating whether to approve a
new conditional exemption, APHIS
would carefully consider issues related
to enforceability of the conditional
exemption when proposing to approve a
conditional exemption. Unlike permit
conditions, which are binding on the
specific responsible person, the
conditions associated with the
exemption would apply to anyone who
conducts the activity under the
conditional exemption, Before granting
such a conditional exemption, APHIS
would take into consideration the
likelihood that such conditions would
be followed and the comsequences if
th^ are not.
Conditional exemptions could be
used, for example, for the importation of
certain GE commodities, A person could
petition for an exemption from ail
permits for shipments of a particular GE
commodity grain under the condition
that the grain is not grown, but will only
be moved for direct use as food. feed, or
for processing. The proposed procedure
to approve new exemptions would be
sufficiently adaptable that it can
consider approving exemptions for the
shipment of certain GE commodities
that would take into account any
conditions necessary to make it unlikely
to result in the introduction and
dissemination of plant pests or noxious
weeds,
APHIS considered proposing specific
criteria in the regulations that the
Agency would use when evaluating
potential risks of imported GE
commodities which are viable
propagules such as grains like corn,
wheal, etc. APHIS considered that .such
a criterion-based system in the
regulations might allow APHIS to
conduct expedited review's of imports
that met the specified criteria. APHIS
considered criteria .such as w'helher the
GE plant had undergone a safety review
in a foreign country, whether APHIS
had granted nonregulated .status to
something similar, and the likelihood
that the commodity could be propagated
(seeds, fruit with seeds, nonviable
products like flour, etc.).
However, at this time APHIS is not
proposing such criteria in the
regulation. APHIS does not rule out the
possibility of developing such a
criterion-based system in the future. We
welcome comments from the public on
this issue.
We are also proposing regulator^'
procedures whereby the Administrator
may revoke any exemption under this
part after it is approved. As proposed,
the Administrator may revoke any
exemption if the Administrator receives
information subsequent to approving
the exemption and makes a
determination based upon this
information that the circumstances have
changed such that the exemption is
likely to result in the inlroduclion or
dissemination of a plant pest or noxious
weed. A revocation may not be
appealed. However, any person may file
a new petition in accordance w-ilh
§ 340.5 regarding the same or similar
organisms covered by the exemption if
new information relevant to the
revocation becomes available.
In addition to this procedure for
completely revoking an exemption so it
w'ould be unavailable for use by any
person, we propose to add a provision
in paragraph (e) of the conditional
exemptions section, § 340.4. under
which the Administrator may revoke the
right of an individual person to use an
exemption without revoking the
exemption for other persons. The
Administrator could revoke an
individual’s right to use an exemption
after determining that the person or any
agent of the person has failed to comply
at any time with any provision of this
part.
D. Petitions for Nonregulated Status
(§340.5)
The current regulations include a
procedure by which anyone may
petition APHIS to grant “nonregulated
status” to a GE organism, which means
it would no longer be subject to the
regulations in part 340. This
nonregulated status is different from
that of regulated articles that might be
conditionally exempt from the
requirement for a permit when moved
interstate (following the conditions
specified in the regulations).
Published APHIS decisions made
under the current regulations have used
different ways to express the basic
standard “unlikely to pose a plant pest
risk” in determining whetlier to grant
nonregulated status to a specific GE
organism. In its determinations, APHIS
has conveyed the basic standard of
"unlikely to pose a plant pest risk” by
concluding that the GE organism ‘‘poses
no more of a plant pest risk than its non-
genetically engineered counterpart,”
“will not pose a plant pest risk”; or that
there is “no plant pest risk," or “no
direct or indirect plant pest effects.”
Regardless of the phrases used In its
determination of nonregulated status to
date, APHIS has applied the same basic
evaluation criteria to each
determination to conclude that the GE
organism is unlikely to pose a plant pest
risk and therefore is not subject to the
part 340 regulations.
APHIS is proposing revisions to
§ 340.6 that will clarify the petition
procedure, information requirements for
petitions, and the standard upon which
the Administrator will make a
determination that a GE organism is
approved for nonregulated status. Under
the current regulations, the basic
standard for a determination of
nonregulated status of a GE organism
has been related to plant pest risk. In
§ 34Q.6(b)(4) of this proposed rule, we
are proposing to apply a similar basic
standard derb'ed from the proposed
regulatory scope in § 340.0(a). namely,
whether the GE organism is unlikely to
be 3 plant pest or noxious weed,
The current regulations also have a
provision at § 340.6 to extend a
determination of nonregulated status
and grant nonregulated status to a GE
organism based on the similarity of the
GE organism to an antecedent GE
organism that has already granted
nonregulated status {§ 340.6(e)
“Extensions to determinations of
nonregulated status”). This provision
has been in the APHIS regulations since
1997 and has been used fifteen times to
grant nonregulated status to additional
GE plants based on similarity to their
antecedents. This existing "extension
procedure” wa.s designed for APHIS to
take into account the previous
evaluation conducted by APHIS and
thereby afford the potential for
expedited evaluations of a petition for
extension. The extension procedure has
some administrative aspects which are
streamlined but in practice the APHIS
scientific reviews for extensions are
similar to those of the antecedent
organism.
Some members of the public have
misunderstood the nature of the
extension procedure, believing that
APHIS has not conducted a thorough
scientific review. Some members of the
public; have misconstrued the term
“extension” to conclude that an
extension would extend the duration of
nonregulated status (nonregulated status
is not granted with an expiration date).
For these reasons. APHIS is proposing
to eliminate the extension procedure in
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the regulation. APHIS sees no advantage
to retaining the distinction in the
regulations between reviews for
antecedents and reviews for subsequent
petitions for extensions. Because the
proposed revisions for petition for
nonreguiated status provdde a high
degree of flexibility, a separate
extension procedure is not needed in
the regulation, Review of petitions
under the proposed regulations will rely
on previous evaluations of similar GE
organisms when they exist. APHIS
foresees that some evaluations for
nonreguiated status may require less
lime if previous evaluations have
addressed the issues relevant to a new
petition for nonreguiated status.
In § 340.6 we propose some revisions
to the information that the
Administrator may require a petitioner
to submit in consideration of the
particular petition. In the current
regulation, the information needs are
described largely with respect to
evaluating GE plants, but APHIS
foresees that other GE organisms may
also be suitable candidates. This
provision may become more important
as new commercial applications of
biotechnology emerge and new types of
information are needed to properly
assess the risks associated with new
types of GE organisms. In all of the
nonreguiated status requests processed
to date, the subject organisms and the
alterations involved did not present
unanticipated or completely novel
approaches and APHIS was able to
make a determination based on
information in the petitions. When
needed, APHIS obtained additional
information from petitioners, in a
consultation process .similar to the one
proposed.
We are also propo.sing a regulatory
procedure whereby the Administrator
may revoke a previous approval of
nonreguiated status. This is consistent
with the existing regulations and
policies that the Administrator may
place a deregulated GE organism back
under the regulations if the
Administrator concludes that the GE
organi-sm poses a plant pest risk, As
proposed, the Administrator may revoke
any approval of nonreguiated status if
the Administrator receives information
subsequent to approval that the GE
organism is likely to be a plant pest or
noxious weed. If the Administrator
revokes an approval for nonreguiated
status, the Administrator may approve
for the same GE organism an exemption
from the requirement for permit in
accordance with § 340,5. The
revocation, its effective date, and the
reasons for it will be published in the
Federal Register. A revocation may not
be appealed. However, any person may
file a new petition in acrardance with
§ 340.5 or § 340.6 regarding the same or
similar organisms covered by the
revocation if new information relevant
to the revocation becomes available.
Treatment of GE Organisms That Have
Been Granted Nonr^ulated Status
Although the APHIS evaluations of
GE plants that would be conducted
under the proposed r^ulatory changes
will evaluate some additional factors
because of consideration of noxious
weed risks, APHIS nonetheless
considers this proposed revision to be
sufficiently consistent with the criteria
evaluated in making determinations of
nonreguiated status to date under the
current regulations. For this reason.
APHIS Is proposing that all previous
determinations of nonreguiated status
made since the early 1990s under the
part 340 regulations will be
automatically approved for
nonreguiated status under the revisions
proposed here. The history of safe use
of these nonreguiated GE plants in
agriculture in the United States and
other countries gives APHIS confidence
that it is appropriate to retain
nonreguiated status under the revised
regulations for all those GE plants
which have been granted nonreguiated
status under the existing regulations.
Many of these GE plants have been
incorporated into plant breeding
programs and been used to develop
hundreds of crop varieties that have
been widely and safely used in
agriculture around the w'orld.
We also note that although the
addition of the term “noxious weed” is
new to the proposed regulation,
previous evaluations for determinations
of nonreguiated status considered the
concept of plant post risk in a broad
context that included consideration of
potential weediness. The evaluations
considered, inter alia, whether the
unmodified plant was a weed, whether
the GE plant was a wood, and whether
the interbreeding of the GE plant with
sexually compatible plant species
would result in offspring that would be
weeds. In each case in which APHIS
granted nonreguiated status to date,
APHIS reached the conclusion that in
each in.stance that the potential for
\veediness wa.s unlikely to occur. In the
case of .some petitions for nonreguiated
status in which the GE plants were
engineered with sequences derived from
plant viruses, APHIS also considered In
its reviews whether the genetic
modification was unlikely' to result in a
new plant pest, in this case a plant virus
(through mechanisms such as
recombination or transencapsidation).
E. Compliance, Enforcement, and
Remedial Action (§340.7)
1. Ensuring Compliance With Permits
and Exemption Activities
In recent years, APHIS has
strengthened Us program in order to
improve permit holders’ compliance
with the regulations, to augment the
approaches used to prevent or remediate
potential risks to plant health, and to
utilize appropriate enforcement
strategies. This proposal provides an
opportunity to set forth the compliance
and enforcement requirements and the
tools and administrative practices
APHIS may employ as part of an
integrated approach to prevent the
introduction or dissemination of plant
pests and noxious weeds, and to
support overall administration of the
program. These matters are addressed in
proposed §340.7, “Compliance,
enforcement, and remedial actions.”
These proposed regulatory changes also
reflect certain provisions of the 2008
Farm Bill and align with
recommendations of USDA’s OIG.
APHIS seeks to clarify that it will use
the full range of enforcement authorities
and penalties granted under the PPA, As
described above, APHIS issues permits
with specific conditions or requirements
placed upon the responsible person.
Proposed §340.7 clarifies the
requirement for compliance with these
conditions, as well as the approaches
available to APHIS to verify compliance.
Such conditions may include
requirements for the responsible person
to establish and maintain records
related to (he permit, as well as allowing
APHIS to review those records. This
section underscores APHIS’ ability to
conduct inspections and audit records
related to the regulated activities.
In this proposed rule, the
requirements for record retention are
being increased. Records indicating that
a GE organism that was imported or
moved interstate reached its intended
destination must be retained for at least
2 years after completion of importation
or interstate movement, and all other
records must be retained for at least 5
years after completion of all obligations
required under a reie\'ant permit or
exemption. APHIS is also proposing
changes to the nature of the records that
are required, a topic discussed in greater
detail in section E of this document, “E.
Papei-work Reduction Act.” Changes
include a requirement to maintain
records for activities done under a
conditional exemption, as well as
contracts and other information related
to agreements botw'een the responsible
person and all agent.s that conduct
activities subject to this part.
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Federal Register/Vol. 73, No. 197/Thursday, October 9, 2008/Proposed Rules 60025
In a previous section of this proposal
we discussed the types of records
proposed as core permit conditions in
§ 340.3. We also propose to add certain
recordkeeping requirements to § 340.7
that would apply not just to responsible
persons exercising permits, but to all
responsible persons and their agents
engaged in the importation, interstate
movement, or release into the
environment of any GE organism that is
subject to this part, including persons
utilizing the conditional exemptions
from permits.
In recent years, APHIS has accrued a
great deal of experience in enforcing the
regulations and investigating possible
violations of them. This experience has
helped us identify specific types of
records that may not bo required by the
current regulations, but that arc
necessary for effective enforcement of
the proposed regulations.^ For example,
in investigations of field trials we have
found that we could not always obtain
detailed maps for each planting area
used during each season of the trial.
This information is important for the
efficient enforcement of the regulations.
We also found that sometimes records of
actual field trial operations over time
were not sufficient to confirm that the
procedures, equipment, and safeguards
APHIS approved for a field trial were
actually employed, That is, while
existing records could generally confirm
plans to use, for example, certain
cleaning equipment or procedures at
certain intervals, or to conduct plantings
on certain dates, the records did not
confirm that plans were actually carried
out on the approved dates. We also
found that records for some field trials
did not identify which staff members or
contractors were responsible for
performing which duties, eilh{5r during
a field tost or in the event of an
unauthorized release that triggered the
field test contingency plan, When
responsibilities cannot be linked to
specific individuals, it makes it very
difficult to investigate pos.sible
violations. Another gap in necessary
records we discovered through
experience was the absence of clear
written records of the responsibilities of
different organizations, when several
different entities were involved in a
field trial. During investigations we may
* Datails of invB.stigations thist havs led APHIS to
propose expanded records requirements may bo
found in the ‘'I.cs.sons Learned" docmnenl cited
above, and in inve.sligation report documonls on the
APHIS Web site, e.g., "2007 Report of Libertyl.ink
Rico incidents" lhttp://www.apht>iM‘scin.§(!v/
neiv’:room/contenl/2007/10/content/prinlable./
HiceRepairtJO-2007.pdfj and "Transcript of
Technical Briefing oji Rice Investig.sl.ion” {http://
wwwMsda.sov/wps/porta!/!ut/p/ S.7 p_A/7 OJOB
?conlenlidonh'=ztrue&-conltmlid-200?/10/0283.Kin!].
need to review not only any written
contracts, but also any written
agreements among re^archers,
developers, or other parties that are
sharing performance of tasks required
by the permit for a field trial.
The proposed r^ulations would
allow APHIS to require these types of
records. As APHIS considered the types
of records needed to support the
regulations it tecame apparent that
regulations could not specify in a "one
size fits all" fashion all record
requirements that might be needed.
Therefore, we propose to add those
detailed record requirements of truly
general applicability in §340.3 and
§ 340.7. However, we also propose in
§ 340.3 that we would continue to
impose any necessary additional record
requirements appropriate to each permit
situation as individual permit
conditions.
Proposed § 340.7 also outlines the
po.ssible consequences of failure to
comply with the regulations, including
denial of future permits; revocation of
current permits; destruction, treatment,
and removal of GE organisms: issuance
of penalties; and a means to settle
alleged civil violations prior to the
issuance of an administrative complaint.
Under this proposal, every person
whose activities are within the scope of
the regulations must comply with all the
requirements of this part. Moreover, a
responsible person can be held liable for
the violation of any requirement of this
part by any agent working for the
re.sponsible person (including persons
contracted to conduct or carry out the
environmental release on their own or
on lca.sed properties).
We propose to address remediation
authority and procedures to a greater
degree of detail than the current
regulations. In proposed §§ 340.7(e) and
(g) we explicitly state that the APHIS
Administrator has the authority to take
remedial actions in the event that an
incident requires such actions. We also
specify that the APHIS Administrator
has the authority to order remedial
action by others. These orders could
take the form of an Administrative
Order, Emeigency Action Notification,
or similar regulatory instrument.
Additional information about these
typos of orders and related procedures
are provided in administrative guidance
on the APHIS Web site. The
consequence for failure to abide by the
orders of the Administrator is also
described in proposed §340.7, linking
remediation to enforcement.
Finally, APHIS has clarified in the
proposed regulations that in the event of
a permit revocation, it may act or order
action of the responsible person in the
handling of the organisms, articles, or
means of conveyances.
2. Low Level Presence of Regulated GE
Plants in Seed or Grain
On March 29, 2007, APHIS published
a Federal Register notice titled “Policy
on Responding to the Low-Level
Presence of Regulated Genetically
Engineered Plant Materials” (72 FR
14649-14651; Docket No. APHIS-2006-
0167. This notice described how APHIS
responds when low levels of regulated
GE plant materials occur in commercial
seeds or grain that may be used for food
or feed. This issue was also addressed
in the DEIS in Issue 7. Both of those
documents described how APHIS has
addressed these occurrences in the pa.st,
and how the Agency intends to address
them in the fiiture, We are proposing to
amend the current regulations to
explicitly incorporate APHIS’ low' level
presence policy,
As described in the DEIS, APHIS
proposes to establish criteria under
which the occurrence of a low level
presence (LLP) of GE plant materials in
seeds or grain may not be cause for
agency remedial action. APHIS would
still retain discretion to order corrective
Of remedial actions in situations (hat
meet the non-actionable criteria, when
the Administrator determines remedial
action is needed to make the LLP
unlikely to result in the introduction or
dissemination of a plant pest or noxious
weed. We propose to list criteria and
describe possible enforcement actions in
the regulations to improve transparency
regarding how APHIS would respond to
LLP in most instances. APHIS will not
predetermine a specific level that is
considered non-actionable as far as
taking some remedial and/or
enforcement action because this
determination should always be made
ca.se-by-case. These criteria are intended
to apply only to APHIS’ decision to take
or order remedial action in the event
that LLP occurs. The proposed criteria
arc listed within the section describing
the Administrator’s ability to take or
order remedial actions. Regardless of
whether APHIS considers the LLP
actionable with regard to remediation,
any violations of the regulations or
permit conditions could still result in
any of the compliance and enforcement
actions listed in the regulations,
including imposing civil penalties.
APHIS i.s proposing a new provision
in the regulations that would reflect the
current policy cited above. The
provision dcsscribes the criteria APHIS
will use when determining that a LLP
event would be non-actionable with
regard to remediation, namely w’-hen the
criteria support a conclusion that the
790
60026 Federal Register/Vol. 73, No. 197/Thursday, October 9, 2008/Proposed Rules
LLP is unlikely to result in the
introduction or dissemination of a plant
pest or noxious weed. Because the
criteria are safety-based, they will bo
used for incidents of low level presence
originating domestically (o.g., from field
testing] as well as any low level
presence that might be detected in
import shipments that may contain
organisms subject to regulation.
APHIS also considered two additional
criteria, which wc have not adopted in
the proposed rule. First, we considered
a criterion that would require that the
genetic material be introduced into the
plant using a method that has been
demonstrated to result in integration of
the new sequences into the plant
genome, as defined in §340.1. We did
not include this criterion in our
proposal because its relevance in the
LLP context is unclear. A second
criterion considered was that the genetic
material engineered into the GE plant
does not encode substances with w'hose
function APHIS is unfamiliar. APHIS
did not adopt this criterion since it is
redundant with the proposed criteria
that will be used, i.e., that the function
of the introduced genetic sequences is
known and that key food safety issues
have been addressed.
The DEIS, in Issue 7, Alternative 3,
proposed that APHIS would also
consider the LLP safety criteria when
deciding whether to issue a permit for
environmental release, and what type
and severity of permit conditions to
a.s8ign to the release permit. In its
evaluation of permit applications,
APHIS does plan to refer to the LLP
criteria, as described above.
F. Administrative Changes
1. Confidential Business Information
APHIS is propovsing a now § 340.8 to
provide further guidance on the manner
in which confidential business
information (CBI) will be addressed in
the implementation of these regulations.
This change will support the overall
administration of the program. The
proposed § 340.8 cites the relevance of
the Freedom of Information Act (FOIA)
and exemptions from releasing
information pursuant to FOIA, namely,
5 U.S.C. 552{bK4), and states that APHIS
may exempt hum disclosure to the
public trade secrets and commercial or
financial information obtained from a
person that are privileged or
confidentiai. Proposed § 340.8 also
states how persons wishing to protect
confidential business information
should communicate with APHIS in
permit applications, petitions, or other
submissions to APHIS.
2. Time Frames for APHIS Action on
Permit Applications and Petitions
Current regulations specify time
frames within which APHIS must take
certain actions, such as issuing permits,
acknowledging notlHcations or issuing
decisioi^ on petitions to grant
nonregulated status. APHIS experience
in the last several years has shown that
the time required to complete these
actions has increased beyond the time
frames originally stipulated in the
regulations in 1987 (permits) and 1993
(petitions for nonr^ulated status). As
staled in the current regulation, APHIS
is obligated to give its reply in the
stipulated time, even if required
procedures are not yet complete.
Therefore, APHIS proposes to include in
§ 340.2(d) of the regulations a statement
that APHIS will generally respond in
the time frames indicated. APHIS
believes it is important to continue to
meet the indicated time frames
whenever possible, but the most
important thing is to communicate the
actual status of reviews and procedures
with applicants rather than be obligated
to reach a decision in a certain number
of days despite the complexities
involved with a review. APHIS is
particularly seeking comment on this
proposed change from persons with
experience under the current time
frames.
3. Duration Period for Permits
Under the current regulations.
notifications for environmental release
and interstate movement are valid for
one year, and the duration period for a
permit issued for an environmental
release is not specified. Currently
Interstate movement permits are only
valid for one year from the dale of
issuance, and a new import permit must
be obtained for each imported shipment.
APHIS will continue to retain the
flexibility of the permitting procedure to
authorize environmental release permits
that can be effective for any appropriate
time period. In some cases, it may be
most efficient to authorize
environmental release permits that are
valid for more than a single year. In
such c;ases, APHIS can retain adequate
oversight by performing periodic
Inspections and requiring periodic
reports. Experience has revealed
situations where field tests lasting more
than one year are essential. For
example, some environmental releases
of GE fruit trees may take several years
to evaluate the fruit production that
often does not begin for several years
after planting.
In order to provide greater flexibility
and efficiency, APHIS is also proposing
to eliminate the current restrictions in
the regulation on the duration of
permits for interstate movement and
importation. Tlie proposed regulations
will remove the requirements that
interstate movement permits are only
valid for one year from the date of
issuance, and that importation permits
must be obtained for each individual
importation. These changes should give
APHIS the flexibility to issue these
permits with suitable durations to meet
the individual circumstances.
G. Definitions and Miscellaneous
Changes
APHIS proposes to change certain
definitions in § 340,1 of the regulations,
to add certain new definitions, and to
remove definitions for terms that are
defined in the PPA or that no longer
appear in the regulations.
Revised Definitions
APHIS proposes to change the
definitions of the following terms in
§340.1:
Release into the environment would
read "Dispersal beyond the constraints
of a contained facility or secure
shipment. Synonymous with the term
environmental release.”
Secure shipment is a new term
defined below. By adding reference to
secure shipment in this definition, wo
clarify the distinction between
environmental release and shipments
for importation and interstate
movement; any such movements which
are not done by secure shipment
constitute an environmental release.
Responsible person would read “The
person who has control and will
maintain control over a GE organism
during its importation, interstate
movement, or release into the
environmont and assures compliance
with all conditions contained in any
applicable permit or exemption as well
as other requirements in this part. A
responsible person shall be at least 18
years of age and be a legal resident of
the United States or designate an agent
who is at least 18 years of age and a
legal resident of the United States.” The
change from the former definition is the
addition of "at least 18 years of ago,”
added to prevent possible enforcement
difficulties.
New' Definitions
APHIS proposes to add definitions of
the following new terms;
Confidential business information,
CBI would read "Information such as
trade secrets or commercial or financial
information that may be exempt from
disclo.sure under Exemption 4 of the
Freedom of Information Act (FOIA),
791
Federal Register/ Vol. 73, No. 197/Thursday, October 9, 2008 /Proposed Rules 60027
because disclosure could reasonably be
expected to cause substantial
competitive harm. USDA regulations on
how the agency will handle CBI and
how to determine what information may
be exempt from disclosure under FOIA
(5 U.S.C. 552) are found at 7 CFR
§ 1.12,” We propose to add this
definition because APHIS has often
been asked to clarify %vhat is and is not
CBI, and how it is handled. The
definition describes typical types of CBI,
and the language in proposed § 340.8
describes how persons submitting
documents to APHIS can request that
identified information be treated as CBI.
There is also additional guidance on CBI
contained in administrative guidance on
the APHIS Web site regarding document
preparation for part 340 requests.
However, it is important to realize that
in actual situations where someone
submits a FOIA request for particular
information, the APHIS FOIA Officer
makes the ultimate determination as to
whether particular information shall be
released, in accordance with the
standards of FOIA, Executive Order
12600, and 7 CFR 1.12.
Contingency plan would read “A
written plan stating how the responsible
person will respond in the event of the
unauthorized environmental release of
GE organisms.” We propose to define
this new term to describe a document
mentioned in both the permit
application information requirements
section (§ 340.2(c)) and the permit
conditions section (§ 340.3).
Exempt, exempted, exemption would
read ‘‘A determination by the
Administrator that the importation,
interstate movement, and/or release into
the environment of an organism or class
of organisms described iii § 340.0(a) is
not subject to the requirement to have
a permit under this part. An exemption
from one typo of permit (e.g., interstate
movement) does not remove remaining
obligations to obtain other permits
under this part,” We propose to add this
definition for the term exemption to
refer to situations where a regulated
movement is exempt from the
requirement for a permit. The proposed
definition is based on language in Sec.
41l(b){l) of thePPA (7 U.S.C. 7711(c)),
titled “Exception to permit
requirement,” which authorizes the
Secretary to issue regulations to allow
the movement of specified plant pests
without further restriction if the
Secretary finds that a permit is not
necessary.
Noxious weed would read "Any plant
or plant product that can directly or
indirectly injure or cause damage to
crops (including nursery’’ stock or plant
products), livestock, poultry, or other
interests of agriculture, irrigation,
navigation, the natural resources of the
United Stertes, the public health, or the
environment.” This is the definition for
noxious weed found in the PPA.
Recipient oiganism would read “The
organism that will receive the genetic
material from a donor organism in the
process of genetic engineering (once the
organism is engineered it is referred to
as the genetically engin^red (GE)
organism).” This definition is needed to
properly distinguish organisms and
their traits in comparisons of GE
organisms to the same organisms prior
to transformation.
State or tribal wgulatory official
would read “State or tribal official with
responsibilities for plant health, or any
other duly designated State or tribal
official, in the State or on the tribal
lands where the importation, interstate
movement, or release into the
environment is to lake place.” This term
Is used in reference to consultations
with States and tribes under the
regulations.
Secure shipment would read
“Shipment in a container or a means of
conveyance of sufficient strength and
integrity to withstand leakage of
contents, shocks, pressure changes, and
other conditions incident to ordinary
handling in transportation.”
We propose to add the following two
definitions to make it clear that, when
the Administrator authorizes it, a
signature required under the regulations
may be an electronic signature and a
written document required under the
regulations (e.g., a permit application)
may be an electronic document.
Signature, signed would read “The
dhscrete, verifiable symbol of an
individual which, when affixed to a
writing with the knowledge and consent
of the individual, indicates a present
intention to authenticate the writing.
This includes electronic signatures
when authorized by the Administrator.”
Write, writing, written would read
“Any document or communication
required by this part to be in writing
may also provided by electronic
communication when authorized by the
Administrator.”
Deletion of Definitions
We propose to remove the following
definitions from the regulations;
courtesy permit, expression vector,
introduce or introduction, regulated
article, stably integrated, vecior or
vector agent, and well-characterized and
contains only non-coding regulatory
regions.
These definitions would be removed
because the terms would no longer be
used in the regulations. We propose to
eliminate the terra regulated article
partly because the use of the term
“article” in current part 340 is not
consistent with usage in the PPA, which
uses the term article to mean “any
material or tangible object that could
harbor plant pests or noxious weeds" —
that is, things like packing materials,
shipping containers, commodities,
etc. — and not a plant pest or noxious
weed itself. Under the current
regulation, however, regulated article
refers exclusively to certain GE
organisms. Furthermore, under both the
PPA and part 340, “articles” are not
regulated, but rather their importation,
inter-state movement or environmental
release is regulated. For these reasons,
the term “regulated article” in the
current regulations is both inconsistent
with the terminology of the PPA and
difficult for the public to comprehend.
We also propose to remove the
definition for introduction. APHIS
currently uses the term in part 340 to
denote certain kinds of activities that
fall within the scope of the regulation,
namely importation, interstate
movement, and release into the
environment. The PPA, however, does
not specifically define the term
introduction. Therefore, to avoid
confusion, instead of using the term
introduction to define the different
types of regulated activities, APHIS will
instead refer to these specific activities
themselves in the regulations, namely,
the importation, interstate movement
and release into the environment.
Miscellaneous Changes
We also propose to make minor
miscellaneous changes to the
regulations to improve their clarity and
remove redundancies. For example, in
addition to adding the definition for CBI
divseussed above, we are consolidating
requirements concerning CBI, formerly
contained in several sections of the
regulations, into proposed § 340,8.
IV. Required Analyses
A. National Environmental Policy Act
On January 23, 2004 (69 FR 3271).
APHIS published a notice of intent to
prepare a draft environmental impact
statement (DEIS) in accordance with the
National Environmental Policy Act in
connection with the regulations at 7
CFR part 340 and potential changes to
those regulations. This notice identified
potential issues and alternatives to be
studied and requested public comment
to shape the scope of the DEIS.
On July 17, 2007, APHIS pubii.shecl
the DEIS evaluating regulatory
alternatives under consideration and
solicited public comment on the DEIS
792
60028 Federal Register/VoL 73, No. 197/Thursday, October 9, 2008/Proposed Rules
{72 FR 39021-39025). The
Environmental Protection Agency
published a separate notice on July 13,
2007, soliciting public comment on the
DEIS (72 FR 38576-38577). The notices
sought comments on the quality of our
analysis of potential environmental
effects of the alternatives under
consideration, and also sought views on
how each alternative would affect areas
such as the overall effectiveness of our
biotechnology program, its operational
efficiency, industry compliance issues,
or other issues that would be associated
with the implementation of an
alternative.
The major elements of this proposed
rule were accurately described in the
alternatives contained in the DEIS and
their potential environmental effects
were analyzed in the DEIS. Table 4
below provides a comparison between
the proposed changes to part 340 and
the DEIS. We received numerous
comments on the DEIS, which will be
discussed folly when we publish a final
environmental impact statement (FEIS).
The DEIS and the comments on it were
used by APHIS to inform decision
makers and aid the design of this
proposal. Information the DEIS
comments, along with infonnalion from
many other sources, including certain
provisions of the 2008 Farm Bill and
recommendations from USDA’s OIG,
was used to inform the drafted of this
propo.sed rule about the issues
perceived to be involved in and
addressed by the rulemaking. We will
respond to all DEIS comments in detail
in the FEIS since the a^ncy action
{revising the regulations in part 340) is
still subject to change based on
comments and information received on
this proposed rule, and thus we cannot
provide definitive and final comment
responses until we issue the FEIS and
the final rule.
Consideration of the DEIS comments
led APHIS to refine and reorganize some
of the regulatory alternatives it
considered. Therefore, the presentation
and discussion of the alternatives
proposed in this proposal do not exactly
match those described in the DEIS. The
differences are primarily a matter of
reorganizing and realigning some
material and their corresponding
regulatory alternatives, using more
descriptive terms in some criteria listed
in the alternatives, and choosing
between regulatory alternatives that fall
within the analysis of the DEIS.
Accordingly, the DEIS is still consistent
and applicable as an analysis of the
potential environmental effects of the
proposed action. However, we are
interested in receiving comments on
whether any of the proposed regulatory
alternatives in this document do not
appear to have been adequately
addressed within the DEIS.
Table 4 — Summary of Proposed Changes to the Regulations and Relationship to DEIS
Summary of proposed substantive changes to the regulation
DEIS issue
Redescription of which GE organisms are subject to the regulations.
2 (DEIS
or 3.
DEIS alternative
preferred alternative)
Deletion of the list of plant pest taxa in the regulations and the petition procedure to amend the
list.
Clarification that APHIS has the authority to regulate nonliwng materials through permH condi-
tions in cases where such materials may pose a risk as a noxious weed.
Revision of the application information requirements and permit conditions for all permit types.
Elimination of the current notification procedure for importation, interstate movement, and re-
lease into the environment of certain types of GE plants (permitting procedure will be used in-
5 2 (DEIS preferred alternative).
2 4 (DEIS preferred attsmalive).
Revision of the permitting system for environmental releases:
• Subdivision Into 5 categories of permits tor environmental releases (4 for GE plants. 1 for
other QE organisms).
• Continue strict permit conditions for environmental releases of GE plants engineered to
produce compounds intended for pharmaceutical or industrial uses.
Continued use of permits with appropriate conditions for single or muHipie year releases.
Creation of new administrative procedures in permiliing: (1) The explicit agreement of the re-
sponsible person to comply with regulatory requirements of the permit, (2) amendment of ex-
isting permit conditions, (3) transfer of permits to a different responsible person, and (4) rev-
ocation of a permit.
Elimination of the prescribed shipping container provisions in favor of a performance based ap-
proach specified as permit conditions for importation and interstate movement.
Revision of the existing conditional exemptions for interstate movement such that the shipping
standard Is part of the exemption. Addition of a recordkeeping requirement for persons using
the existing conditional exemptions.
Elimination of the option for APHIS to issue courtesy peimlts tor importation, interstate move-
ment, and environmental release of QE organisms w^ich are not subject to the regulation.
Creation of a pefition procedure for the Administrator to approve additional conditional exemp-
tions from the requirement for a permit, This also includes a description of administrative
steps if Administrator revokes an exemption, amends the conditions of an exemption, or pro-
hibits a person from using a conditional exemption.
Clarification and revision of the existing petition procedure for determining nonregulated status,
including elimination of the procedure to extend a previous determination of nonregulated sta-
tus. and a description of the administrative steps if Administrator revokes nonregulated status.
Clarification of the actions the Administrator may take related to compliance, enforcement, and
remediation.
Clarification of APHIS approach to the low level presence of regulated GE plants in seed or
grain.
Definition of Confidential Business Information (CBI) and description of artninistrative practices
for CBI,
2
10
7
4 (DEIS preferred alternative).
2 (DEIS preferred alternative).
1 (No action alternative).
2 (DEIS preferred alternative).
2 (DEIS preferred alternative).
1 (DEIS No Action alternative).
3 (DEIS preferred alternative).
793
Federal Register/ Vol. 73, No. 197 /Thursday, October 9, 2008 /Proposed Rules 60029
We received approximately 23,000
comments on the DEIS, of which more
than 22,000 were variations of several
form letters. There were also several
lengthy and detailed evaluations of
environmental, scientific, legal, cultural,
and economic issues raised by the DEIS.
APHIS took all comments related to
regulatory changes under consideration
as we developed the content of this
proposed rule, and altered a number of
preliminary ideas for the proposal based
on comments, We will fully summarize
and address the comments received on
the DEIS in a Final Environmental
Impact Statement to be prepared in
conjunction with the publication of a
final rule, In addition to specific DEIS
issues that were discussed above in the
Preamble, the following section
summarizes and discusses those
comments on the DEIS that were most
directly related to the regulatory
alternatives discussed in this proposed
rule and the ways in which these
comments affected development of the
proposal.
Many DEIS commenters addressed
how the regulations should use the PPA
authorities regarding noxious weeds,
plant pests, and biological control
organisms. Most comments on the DEIS
that addressed this issue stated that
APHIS should expand the scope of its
regulatory program beyond plant pests
to include lioth noxious weeds and
certain biological control organisms,
consistent with all of the regulatory
authorities of the PPA. The following
opinions were expressed regarding PPA
authority regarding noxious weeds and
the meaning of the PPA definition of
noxious weed.
Very few commenters suggested that
APHIS biotechnology regulations
should implement the PPA’s noxious
weed definition in its broadest possible
sense. One coramenler suggested that
APHIS broadly interpret the phrase
“other interests of agriculture,” in the
PPA definition of noxious w’eed such
that APHIS would con.sider a plant to be
a noxious weed if it poses solely
economic harm, i.e., in the absence of
physical harm. As explained previously
in this proposal, .such an interpretation
is not consistent with the PPA, nor with
the manner in which APHIS~PPQ has
implemented the noxious weed program
pursuant to the PPA. Many commenters
suggested that APHIS needed clear
regulations or policies to describe how
it will be evaluating whether GE plants
pose threats .as noxious weeds. APHIS
agrees and has framed this proposal to
clarify the issue for the public.
Some commenters stated that APHIS
should acknowledge limits to its
consideration of potential damage? to
public health in APHIS r^ulations, and
the noxious weed definition should not
be interpreted so broadly as to provide
APHIS with the legal responsibility or
authority to determine the food safety of
GE crops or to prevent GE crops from
entering the food supply. The
commenters stated that Congress clearly
intended the FDA to be responsible in
this area.
We agr^, and this proposal
acknowledges FDA authority in the food
safety area. However, it is important that
the regulatory procedures in each
agency dovetail and support each other
where agency mission areas come in
contact. This proposal recognizes this
need for mutual ^ency support. When
a permit for environmental release,
importation, or interstate movement of a
new GE organism is submitted to
APHIS, we would evaluate whether
there are any signs that the
environmental release, importation, or
interstate movement of the organism
could present risks to the public health.
If APHIS is concerned that there may be
food safety risks associated with the GE
organism, w'o would contact FDA. The
decision on whether or how to regulate
food and feed from the GE organism to
address food and feed safety risks would
then be FDA’s. On the other hand, it is
also likely that existing food safety
evaluations will prove to be useful and
relevant to APHIS evaluations of a GE
organism. Food safety concerns are one
of several factors APHIS would take into
account w'hen considering, for example,
what types of permit conditions are
needed for the environmental release of
a GE organism, or whether activities
associated with the organism should
qualify for an exemption from the
permit requirement.
Several commenters staled that under
the current regulations APHIS has
always considered noxious weed risk, or
at least “weediness.” We agree that in
practice, when APHIS assesses a GB
plant it has always evaluated the
potential weediness of the GE plant in
relation to its plant pe.st potential. In the
context of the PPA, “weediness" is more
properly a noxious weed risk
characteristic than a plant pest one, and
the proposed revision of the regulations
will more clearly align the regulations
with the plant pest and noxious weed
risk pursuant to the PPA. Current
APHIS regulations and guidance
directly address the importance of
including weediness when evaluating
risks associated with GE organisms. For
example, when the petition procedure
to grant nonregulated status was added
to part 340 in 1993, the traits APHIS
listed for evaluation explicitly included
“weediness of the regulated article” (see
current §340, 6(c)(4)).
Several DEIS commenters addressed
what characteristics should trigger
regulation of a GE organism, or put
another way, how to set the scope of
organisms subject to regulation. In the
DEIS, APHIS explored many options
including continuing to make its
decisions primarily based upon the
transformation event (also sometimes
referred to as the individual transformed
line, transgenic line orGE line). Some
members of the public refer to this as an
event-by-event approach. It is
sometimes contrasted with a “trait-
based” approach that focuses more on
the resulting trail or phenotype of the
GE organism. In a trait-based approach,
a regulatory decision for an organism
engineered for one phenotype would
apply equally to other GE organisms if
they had the same phenotype or trait,
regardless of whether they were
engineered with the same genes. APHIS
invited comment on the relative merits
of the event-by-event approach and the
trait-based approach. The current
regulations do not limit .APHIS to one
approach or the other. Many readers
equated “event-by-event” with a
“process-based” system and likewise
equated “trait-based" regulation with a
“product-based” system. Thus many
comments focused on the relative merits
of a product-based system versus a
process-based system.
Some suggested that the trigger be
"process-based”, i.e., the process of
modifying the organism by recombinant
DNA techniques would be the
determinant. Others suggested the
trigger be “product-based”, i.e., the
nature of the resulting product
(organism) would be the determinant for
whether the organism would be subject
to the regulation. Many of the comments
were not actually related to the basis for
the trigger, but rather to the focus of the
risk assessment, with most stating that
the risk assessments should be based on
the biology of the organism (product-
based), not the technique by which it
was made (process-based). One
commenter believes that the process of
genetic engineering is a useful trigger,
but once regulated, the characteristics of
the GE organism .should dominate
APHIS considerations of safety.
Those supporting a process-oased
approach for identifying which
organisms should be subject to
regulation stated that each GE organism
can have unintended as ivell as
intended changes, and that these
unintended changes to the organism
would require that each individual
resulting from genetic engineering must
be assessed on a case-by-case basis.
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60030 Federal Register/ Vol. 73, No. 197 /Thursday, October 9, 2008/Proposed Rules
Some coramenters also suggested that
this approach of APHIS assessment of
each individual GE organism better
protects the environment and human
health than an approach that focuses
primarily on the trait(s} of the GE
organism.
Some comraenters against process-
based approach .stated that this
approach is illogical, on the one hand,
to regulate a plant species with no
known risks only because GE
techniques were used to modify it,
whereas on the other hand the same
plant species modified by other
techniques faces no additional
regulatory requirements from APHIS.
Those supporting a product-based
regulatory approach stated that it would
be aligned with the preponderance of
scientific opinion on the issue, that the
characteristics of the organism should
lake precedence over tlie technique of
genetic modification in the APHIS
assessment of the organism, APHIS
agrees that any evaluation of risk should
be based on the biology of the product.
Several commenters suggested that
the definition of regulated article would
have to be reexamined and possibly
redefined to reflect changes in the PPA.
Commenters also stated that the term
regulated article was problematic
whether linked to specific taxa in
§ 340.2, under the current regulations,
or linked to plants produced by
particular technologies. These
commenters emphasized that actions
under the regulations usually amount to
an investigation of whether an article
(GE organism) needs to be regulated,
and that predefining the subject of the
investigation as a regulated article
strongly implies that a decision has
been made to require some regulatory
oversight.
The projposod elimination of the term
“regulateci article” would facilitate a
clearer understanding that it is not the
GE organism that is regulated, but rather
the importation, interstate movement, or
release into the environment of the GE
organism,
APHIS determined that eliminating
'‘introduction’’ as a defined term would
facilitate clearer understanding that the
activities subject to the regulations are
in fact importation, interstate
movement, and release into the
environment.
In the DEIS, APHIS discussed the
need to regulate nonliving products of
GE organisms. The preferred alternative
was to have a procedure to regulate non-
viable material only in certain rare
circum.stanc8S when it might pose a
risk. Most of the DEIS comments
addressing this issue agreed that APHIS
should regulate nonviable GE plant
material only in certain circumstances,
ba.sed on the risks posed. The few
comments that provided greater detail
identified toxicity risks and possible
persistence in the environment of toxic
nonviable plant parts or debris as the
most significant risk associated with
nonliving GE products. A few
commented also stated fiiat adding a
clear definition of “nonliving” or
“nonviable” would aid the regulations.
APHIS has responded to these
comments in this proposal by not
usually regulating nonliving GE
products, and by providing that when
anj' control is needed over such a
product that is associated with a living
GE organism which is covered by a
permit, due to toxicity or other risks,
such controls would be included as
permit conditions in permits issued for
the associated living GE organism. We
propose to provide for this by adding
the following sentence to paragraph (b)
of § 340.3, Permit conditions: “The
Administrator may also assign permit
conditions addressing nonliving
materials associated with or derived
from GE plants when such conditions
are needed to make it unlikely that the
nonliving materials would pose a
noxious weed risk.”
We received one DEIS comment
directly addressing the issuance of
courtesy permits. This comment
supported retaining use of courtesy
permits, and stated that courtesy
permits facilitate the importation of GE
Drosophila melanogaster strains by the
research community and also ease the
workload for APHIS. The continued
issuance of courtesy permits diverts
Agency resources unnecessarily from
organisms that are within the scope of
the regulations. We intend to help
develop informational materials for the
research community and other agencies
that are aware of courtesy permits to
clarify that such permits are not
required, and to explain this to any
persons who contact us requesting
courtesy permits in the future.
Several DEIS comments addressed the
notification procedure and supported
eliminating it. Some comments
suggested that the types of organisms
formerly eligible for the notification
process should instead be handled
through a two-tiered permitting process,
with experimental permits for field
trials and commercial permits for GE
crops that are to be sold in commerce.
Other comments suggested that while
some organisms might require permits
with minimal conditions rather than
notifications, others with even lower
risks could be exempted from permit
requirements. These latter comments
also generally su^ested that some of the
criteria in the current regulations u.sed
to determine eligibility for the
notification process could be preserved
in the new regulations as criteria to
identify organisms that should be
exempted from the requirement for a
permit. One commenter stated that since
the current “notification” process
involves acknowledgment by APHIS
and conditions as well as notification,
changing to a system of low risk permits
would be a de facto acknowledgment of
the current process. To address the.se
issues, APHIS is proposing to eliminate
notifications and to handle regulated GE
organisms that previously would have
been eligible for notifications through a
permitting procedure.
We received a few comments on the
DEIS generally related to procedures for
reviewing permit applications.
Comments stated that the role of Slates
in reviewing or approving permit
applications for GE crops has been very
important and useful under the current
regulations, and should continue in
future regulations. Comments also
stated the importance of scientific
integrity in the review process, and
emphasized the importance of
coordinating with other agencies
(particularly FDA and EPA review)
when issues within their mission area
arise during APHIS review of
applications.
The proposed changes to the permit
application procedure address these
concerns. States would have a
continuing role in application review
that is very similar to their existing role,
and we have been increasing
interactions with the relevant tribal
authorities in recent years,
Several comments were peripherally
related to the DEIS issue of whether
APHIS should establish standard or
general permit condition,<5 or what they
should require. These comments
emphasized that the purpose of permit
condition.? is to control risks not
otherwise controlled, and that permit
conditions must be developed in
response to careful consideration of the
risks presented by the particular
permitted activity. One comment .stated
that APHIS should not require permit
conditions that have the primary
purpose of preventing crops from
entering the food supply, because
APHIS doe.s not have the legal authority
or scientific expertise to set them.
We have taken these views into
account in designing this proposed rule.
Proposed § 340.3 describes ihe core list
of general conditions that APHIS would
impose on all permits as well as
additional conditions for specific types
of permits. APHIS is also making it clear
that APHIS may also add other specific
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Federal Register/VoL 73, No. 197/Thursday, October 9, 2008/Proposed Rules 60031
conditions to a permit upon its
issuance. Conditions are specific
practices or requirements that an
applicant must follow upon issuance of
a permit, Conditions are added as a
consequence of the APHIS evaluation in
order to make it unlikely that actions
under the permit would result in the
introduction or dissemination of a plant
pesl or noxious weed.
Several DEIS comments stressed that
APHIS needs to do more to ensure that
the permit conditions it sets are actually
followed and enforced. The changes to
permit procedures proposed for §340.2
contribute to that goal by obtaining
written agreement from the responsible
person that he or she, and all of their
agents, must comply with all of the
permit conditions before issuance of the
permit.
Almost all DEIS comments on
containers or marking and identity for
regulated articles supported
performance standards for containers,
Most of these commenters made the
point that performance criteria are
generally more adaptable and efficient
than prescriptive criteria. Some slated
that shipping research organisms
interstate in enclosed containers is a
low-risk activity that i.s very unlikely to
result in release, establishment or harm.
Some commenters stated that the type
of container indicated by performance
standards must be appropriate to the
level of risk in the tiered permit system
for the shipped GE organism. One
commentor requested that APHIS make
its container standards consistent with
the International Air Transporters
Association (lATA) requirements for
shipping.
The way this proposed rule deals with
container standards is consistent with
the above DEIS comment.s.
Most of the commenters addressing
tiered or categorized permit systems
.supported APHIS establishing a tiered
permitting system for plants based on
criteria that included risk and other GE
organism characteristics. However,
commenters also stressed that risk
categories should be based on a trait by
species approach, not on the basis of
individual transformed plant line
(referred to as “evont-by-event” in sonm
of the comments). Some commenters
advised against using limited broad
based categories that include many
different species with different biologies
and different risk factors. Several stated
the importance of evaluating permit
applications on a caso-by-case basis, to
avoid the risk that categorizing permit
types could result in approval of risky
releases that were inadvertently seen as
“routine categories.”
Several commenters slated that a
tiered permitting system should be
flexible and allow consideration of any
factors that seem relevant, or allow
reclassification of a GE plant from one
tier to another based on additional
characterization information and agency
familiarity with the GE plant. Some
commented opposed the development
of a tiered risk-based permitting system
because each transformation event can
have unintended effects that must be
assessed on a case-by-case basis, rather
than through predefined categories. We
have addressed these views in this
proposed rule by changing the permit
tier system described in the DEIS to a
proposed permit application
categorization system that is more
flexible than the system de.scribed in the
DEIS.
In the DEIS, APHIS considered
whether to continue to issue
environmental release permits for GE
plants engineered to produce
pharmaceutical and industrial
compounds if tlie GE plant species is
the same as, or sexually compatible
with, a species commonly used for food
or feed. APHIS concludes that the
permitling procedure with its stringent
permit conditions can continue to
effectively minimize the risks that may
bo associated with the environmental
release of such GE plants. APHIS will
continue to impose appropriate permit
conditions that lake into account the
issues related to the public safety of
proteins or other substances that these
plants have been engineered to produce.
Numerous commenters supported
banning the outdoor production of
pharmaceuticals and industrial
substances in food and feed crops. Some
stated that food crops .should not be
used for the production of
pharmaceuticals and industrial
.substances.
Some commenters staled that GE
plants u.sed for the production of
pharmaceuticals and industrial
substances should be evaluated by
criteria that are different from those
used to evaluate crops intended for
food. Other commenters slated that if
such GE industrial plants were made
from food crop species, or could spread
genes to food crop species, they should
be evaluated based on food safety risk,
not the industrial product’s function,
and approved only if they pose no food
safety risks. However, willv regard to
evaluating food safety, several
commenters also stated that FDA should
be the agency evaluating these risks.
We have not seen evidence suggesting
that these types of organisms present
unique or uncontrollable risks, or risks
higher than those that may be associated
with many other uses for GE plants. Our
approach in this proposed rule
addresses the other concerns cited by
DEIS commenters.
Many commenters were concerned
that the outdoor cultivation of GE plants
producing pharmaceutical and
industrial compounds could be a source
of gene flow to nearby non-GE plants or
result in the co-mingling of grain with
related crop species intended for food or
feed. Risks associated with this scenario
may be abated by either of two means;
( 1 ) Preventing such gene flow or co-
mingling from occurring, or (2)
establishing that if such gene flow or co-
mingling to other plants does occur, it
does not present an unacceptable risk of
introducing or disseminating a noxious
weed.
Such gene flow can be minimized or
substantially prevented through permit
conditions developed for environmental
releases of GE pharmaceutical or
Industrial plants. In many ca.ses the
genetic and phenotypic characteristics
of the organism also serves to
discourage .survivability of the plant
away from the intended site as well as
gene flow to other plants. During the
review prior to permit issuance, APHIS
would also always consider the effects
if the GE plant were likely to spread
widely, or if large-scale gene flow to
other plants occurred. A permit for an
environmental release would not be
approved if APHIS concluded there was
a likelihood of such events causing any
of the types of harm as described in the
noxious weed definition.
One DEIS comment on the issue of
multiple-year permits stated that
compliance agreements should be used
instead of actual multiple-year permits.
Another suggested that multiple-year
permits should be limited to trait/crop
combinations not intended for feed or
food use. In contrast, another comment
.stated that APHIS should con.sider
allowing multi-year permits for any
product, not just GE pharmaceutical or
industrial plants.
Several commenters stated a risk-
based opposition to multi-year permits
and stated that crops engineered to
produce pharmaceuticals or industrial
compounds should alw'ays be regulated
under an annually-reviewed permit
system.
This proposed rule addresses the risk-
ba.sed concerns cited by commenters in
the proposed processes for issuing
permits and granting exemptions,
discussed elsewhere in this document.
We propose to allow multi-year permits
for any type of regulated activity, when
wa determine that appropriate risk-
related conditions can be prescribed for
those activities. We have not seen any
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60032 Federal Register/ Vol. 73, No. 197/Thursday, October 9, 2008/Proposed Rules
convincing evidence, in DEIS comments
or elsewhere, that limiting use of multi-
year permits to certain types of
organisms would reduce risk or
otherwise serve the purpose of the
regulations.
Of the approximately 67 comments
received by APHIS on the interstate
movement exemptions discussion in the
DEIS, 30 comments appear to support
APHIS' preferred Alternative 2, under
which APHIS would exempt from
permit requirements for interstate
movement a class of GE plants or
organisms that are well-studied and
present little or no environmental risk,
as is currently done for Arabidopsis.
However, many of these commenters
suggested that APHIS choose an
approach that combined this with one
or more of the other Alternatives.
Several commenters stated that the
regulations should provide a procedure
for APHIS to consider additional
exemptions from interstate movement
restrictions on a case-by-case basis.
APHIS has concluded that the most
appropriate proposal for the regulations
at this time is to provide a clear and
adaptable procedure whereby it would
use a caso-by-case approach to consider
the merits of new exemptions from the
requirement for a permit. The
procedure, described In proposed
§ 340.5, would allow for a transparent
procedure in which APHIS would
evaluate the proposed exemption, and
the public would have an opportunity to
review APHIS’ evaluation and provide
comments prior to APHIS decisions on
individual cases, The proposed
procedure should provide the benefit of
transparency and scientific rigor while
affording a more streamlined and cost-
efficient procedure that would not
require formal amendment of the
regulations when each new exemption
is approved.
Several DEIS comments addressed
what criteria in the regulations the
Agency could use to determine the level
of risk assessment applied to imported
GE commodities which are viable
propagules. They fell into Iwm general
groups. Both groups stated that any
expedited review or exemption for GE
commodity imports needed to be
granted based on a review of risk and a
determination that the importation
presented no significant risks. Beyond
that, one group emphasized that
commodity imports were in general
inherently safe, and such an expedited
system would be appropriate and would
also greatly facilitate international trade.
The other group was skeptical about
inherent safety of GE commodities and
suggested that exemptions should only
be offered when there are procedures
ensuring that the commodities are made
non-viable or safeguards are in place to
ensure that propagation will not occur.
Some comments in this group also
stated that such exemptions should not
be granted for a GE commodity from any
country until APHIS has confidence that
the country has robust regulatory
guidelines and assessment standards
with strong, reliable science and
trustworthy regulatory oversight,
equivalent in effectiveness to the U.S.
system.
One comment included a general
statement that it was important that a
petitioner for deregulation or exemption
should work closely with APHIS to
develop and evaluate the management
plan under which the subject GE
organism W'ould be grown if deregulated
or exempted. APHIS agrees that its
regulatory approach should include
working closely with petitioners on
their proposals for exemption,
especially if management plans are part
of the requisite conditions. APHIS
would retain some degree of oversight
and could restrict movements of a GE
oiganism such that the exemption and
its conditions are unlikely to result in
the introduction or dissemination of a-
plant pest or noxious weed. The
proposed procedure to approve
additional conditional exemptions is
sufficiently adaptable even when the
exemption is for all forms of movement
(I.e., importation, interstate movement,
and environmental release).
Very few DEIS comments directly
addres,sed enforcement and compliance.
A few comments stated li»at APHIS
regulatory oversight and enforcement of
its regulations in the past have been
insufficient and have provided
inadequate containment of GE crops.
This proposed rule would strengthen
enforcement and compliance and
enhance the effectiveness of the
regulations.
Comments on the discussion in the
DEIS of low level presence ranged from
suggestions that APHIS should
completely prevent such incidents by
banning all outdoor growth of GE plants
to suggestions that LLP is a minor
problem needing only minimal controls,
and does not warrant an increased
regulatory burden to control a minor
risk. Some commenters stated that the
preferred alternative in the DEIS
accepted loo high a level of risk. The.se
commenters generally preferred DEIS
alternative 4, which would impose very
strict permit conditions on all
environmental releases to reduce the
likelihood of LLP events. Most
commenters agreed that APHIS should
adopt an LLP policy that recognizes the
wide variety of risk levels associated
with such Incidents, and that beyond
applying general criteria APHIS should
investigate each unauthorized release
individually and determine actions
based on the facts surrounding each
incident. Some commenters staled that
any LLP policy should clearly state that
even if an incident w^as found to be non-
actionable (i.e., not requiring remedial
action), persons involved would still be
subject to enforcement actions such as
civil penalties if violations of the
regulations occurred.
APHIS has considered all these views
in the development of thi.s proposed
rule and has attempted to find a
reasonable balance. It is not warranted,
or practical, to implement a “zero
tolerance” LLP policy. Instead, we
propose a policy that each LLP incident
would be individually investigated, and
APHIS xvould then make a decision on
whether, or whai kind of, remedial
action is needed, In making this
detin’mination APHIS would use
established criteria to rate the risks
involved in the LLP incident. However,
these criteria would not fully determine
the APHIS response. In addition to
considering the criteria, APHIS would
evaluate any other relevant information
regarding the LLP incident and order
remedial action if it appears necessary.
Also, we propose to clearly state that
regardless of whether APHIS considers
the LLP actionable with regard to
remediation, any violations of the
regulations or permit conditions can
still result in compliance and
enforcement actions for failure to
comply with the regulations.
One DEIS comment directly
addressed timelines for APHIS to
perform permit- and petition-related
activities and urged APHIS to continue
to define specific timelines for
regulatory reviews to allow for a
predictable regulatory review .system.
The comment stated that time frames
are especially critical for field trial
permitting activities since planting
occurs during a narrow window each
year and a delay of a month or two in
a regulatory decision can result in a year
delay due to the inability to timely plant
a field trial.
We understand the concerns, and
have decided to keep the time frames in
the text of the regulations. However, as
discussed above, APHIS will view them
a.s performance goals and will generally
respond in the time frames indicated,
rather than be obligated to respond at
those times. In recent years, there has
been an increase in the time required for
APHIS review due to the increasing
complexity of issues related to
environmental effects, new traits, and
unfamiliar species. In addition to
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Federal Register/ Vol. 73, No. 197 / Thursday, October 9, 2008/Proposed Rules 60033
retaining general time frames in the
regulations, APHIS intends to discuss
time frames with each applicant early in
the application process, and to the
extent possible give the applicant
reliable time estimates based on the
nature and complexity of the particular
application and current APHIS activities
and resources that are expected to affect
the application review,
B. Executive Order 12866 and
Regulatory Flexibility Act
This proposed rule has been reviewed
under Executive Order 12866. The rule
has been determined to be significant
for the purposes of Executive Order
12866 and, therefore, has been reviewed
by the Office of Management and
Budget.
We have prepared an economic
analysis for this proposed rule, which is
summarized below. Copies of the full
economic analysis are available by
contacting the person listed under FOR
FUR-mEB INFORMATION CONTACT or on the
ReguIations.gov Web silo (see
ADDRESSES above for instructions for
accessing Regulations.gov). The analysis
provides a cost-benefit analysis, as
required by Executive Order 12866, and
an analysis of the potential economic
effects of this final rule on small
entities, as required by the Regulatory
Flexibility Act.
Background
The adoption of genetically
enginoored (GE) crops by farmers
worldwide has become increasingly
widespread. The United States,
Argentina, Brazil, Canada, and China
are the major CE crop adopters. In 2008.
92 percent of soybean, 80 percent of
corn, and 86 percent of cotton acreages
planted in the United States were
genetically engineered (USDA NASS,
2008), In addition to the major field
crops. GE varieties of papaya, yellow
squash, and zucchini were available for
commercial production in 2008.
Worldwide plantings of transgenic
crops grew by 12 percent in 2007,
reaching 282.4 million acres in 23
counlriesS growing biotech crops in
2007, including 12 developing
countries. Over the next decade, use of
these “first-generation” GE crops, which
carry trails such a.s insect resistance and
herbicide tolerance, should continue to
grow while a second generation of crops
promises new applications and traits
such as improved drought tolerance,
biofuel-related enhancements, and
quality and nutritional traits.^
Global Statu.s of Coniinert;ializRd Biotech/GM
Crops, ISAAA Briefs 37-2007, 35-2006, The
International Service for the Acquisition of Agri-
Biotech Applications. Cornel! University.
The benefits associated with the use
of some GE crops already in production
include higher yields, lower pesticide
costs, and overall savings in
management time. There are also
environmental benefits from reduced
pesticide use. Attempts have been made
to quantify the benefits that have
occurred as a result of the adoption of
GE crops and, according to a recent
survey, farm-level net economic benefits
worldwide from the adoption of GE
crops were estimated to be $7 billion in
2006 (Brookes and Barfoot 2008). Total
net benefits, 1996-2006, were estimated
to Ixi S34 billion. Of this total estimated
net welfare gains, the United States
experienced the largest benefit, with
$15.8 billion; followed by Argentina,
$6.6 billion; China, $5.8 billion; and
Brazil, $1.9 billion (Brookes and Barfoot
2008). U.S. farmers’ welfare gains from
the adoption of biotechnology ranged
from 29 to 42 percent of total net
welfare gains (Price et al. 2005; Falck-
Zepeda, Traxler, and Nelson 2000).
"rhe high rate of GE crop adoption by
farmers has been driven by an increase
in consumption of product developed
with the use of GE techniques. However,
studies that quantify consumers’
benefits from the use of biotechnology
are limited, as most studies tend to
focus on the direct adopters of
biotechnology, i.e.. the producers. Price
et al (2006) found consumers do benefit
from the adoption of Bt cotton.
Overall, consumers’ gains from the
adoption of various GE crops have been
estimated to range from 4 to 1 7 percent
of total net welfare gains (Price et al.
2005; Falck-Zepeda, Traxler, and Nelson
2000).
Crop producers and consumers are
not the only beneficiaries of recent
advances in biotechnology. The
providers of biotechnology have also
benefited from the increased adoption of
GE products. Intellectual property right
laws have offered incentives for the
private sector to invest in research and
development of GE products, and as a
result, plant breeding expenditures have
largely shifted from the public to the
private sector (FugUe 2006). As private
research spending has increased, so has
the number of firms engaged in this type
of research. However, consolidation and
mergers during the 1990’s resulted in an
industry dominated by large companies.
Currently, 80 percent of biotech traits
tliat have been approved are owned or
co-owned by four firms (Bayer Crop
Science, DuPont, Monsanto, and
Syngenta) or their sufeidiaries
(Kalaitzandonakes, Alston, and Bradford
2007).
With regard to the beneficial effects
for the environment of GE plants in
commercial production, their
production has resulted since 1996 in
decreases in the use of pesticides by 286
million kg and in the use of herbicides
by 51 million kg (Brookes and Barfoot
2008), These declines represent 7.9
percent reductions. In terras of
greenhouse gases, one study estimated
cultivation using no-tillage systems
associated with GE crops modified for
herbicide tolerance to reduce fuel use by
32.52 liters/ha (89 percent) compared to
conventional methods, and 14.7 liters/
ha (76 percent) compared to reduced
tillage methods (Jasa 2002). An
American Soybean Association .survey'*
showed significant reductions in tillage,
and therefore in fuel use, by growers of
glyphosate-tolerant soybeans. The fuel
reductions were estimated as 1.26
gallons per acre, or, for the 56 million
acres of glyphosate-tolerant soybeans
planted in 2001, 70 million gallons of
fuel saved and associated greenhouse
gas emissions avoided. These fuel-use
reductions translate into reductions of
carbon dioxide emissions of 89.44 kg/ha
and 40.43 kg/ha. respectively. Overall in
2006, the total carbon dioxide savings
associated with the use of GE crops
were 1.2 billion kg. This is equivalent to
removing 540,000 cars from the .streets
for a year.
Benefits of the Proposed Rule
The proposed rule would provide
benefits by establishing more efficient
regulation of GE organisms and
activities subject to part 340 and by
continuing to provide a high level of
protection against risks associated with
these organisms and activities. Benefits
would also include improved public
understanding of and confidence in
APHIS’ biotechnology regulatory
responsibilities, and improved clarity
and transparency of the regulatory
process. Several amendments of the
propOvSed rule would improve the
efficiency of APHIS’ biotech regulatory
process. Particular proposed changes
that should improve the efficiency of
the regulations include the elimination
of courtesy permits and the
establishment of a procedure to evaluate
and grant requests for new exemptions
from the requirement that GE organisms
have a permit to be imported, moved
interstate, or released into the
environment.
Approving new exemptions could be
done without amending the regulations,
resulting in considerable time savings
'•Cited in Fawcett, Richard and Towery. Dati,
Con.servatioii Tillage and Plant Biotechnology; How
New Tetdinologies (Ian Improve the Environment
By Reducing the Need to Plow. Conservation
Technology Information Center, West Lafuyi^tte,
Indiana.
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60034 Federal Register/ Vol. 73, No. 197/Thursday, October 9, 2008 /Proposed Rules
for regulated parties and reducing
APHIS’ rulemaking costs. Persons using
an exemption would also avoid the
costs and delays associated with
obtaining a permit for each new planned
mov'ement or release of a GE organism
covered by the exemption.
APHIS commits considerable
resources to issuing courtesy permits
not actually required by or needed to
implement the part 340 regulations.
These courtesy permits have been
issued to facilitate the movement of GE
organisms that are but whose movement
may be hindered due to their similarity
to organisms that are subject to part 340.
By improving public awareness that
such organisms do not need a permit
and eliminating the courtesy permit
process APHIS would improve
efficiency and reduce its regulatory
workload, and save time for regulated
entities who would no longer make
unnecessary courtesy permit requests.
The Agency currently issues
environmental release permits,
including permits that are used for
production of pharmaceutical and
industrial compounds sold in
commerce. In general, permits for
releases of plants producing
pharmaceutical or industrial
compounds have been limited to a one-
year duration. However, the proposed
regulations provide a more useful and
efficient approach to setting appropriate
risk-related conditions in multi-year
environmental release permits. Under
the proposed system, APHIS would
likely increase issuance of multi-year
environmental release permits, thereby
reducing the time the regulated entities
need to spend submitting applications
as well as the time APHIS spends
reviewing the permit applications.
APHIS^biotechnology operations
would be aided by more clarity in terms
of required data submissions and
administrative procedures. More detail
is provided regarding what applicant
information is required for each permit
application type, and how application
information relates to the proposed new
permit categories for environmental
release permits. These changes, along
with more clearly defined categories for
the environmental release permits,
would polentialiy reduce the time some
entities, large or small, spend on an
application or petition process.
Increased efficiency benefits may be
most helpful to smaller companies and
public sector entities, where GE
research is generally conducted on a
much smaller scale than that of large
agri-business enterprises,
The proposal includes provisions to
require necessary recordkeeping and
reporting but to fine-tune this burden
through particularized permit
conditions to require only what is
needed to ensure regulatory compliance
based on individual cases. This should
contribute to greater efficiency.
The proposed rule’s greater clarity
and transparency is expected to enhance
the gener^ public’s perception of
APHIS regulation in this area, with
associated benefits from increased
support of and compliance with the
regulations.
In addition to the information
provided in the regulations, APHIS
proposes to develop new guidance
documents to assist In the preparation
and submission of applications.
Costs of the Proposed Rule
There are several cost areas associated
with the proposed rule. Costs associated
with the proposed rule that regulated
entities would incur include costs of
learning and adapting procedures to
changed requirements, providing more
or different information in permit
applications, and additional
recordkeeping for some entities. The
additional recordkeeping burden is
discussed below in (he Paperwork
Reduction Act section. Annual costs
resulting from the additional
recordkeeping may be estimated as the
salary and associated costs for 640
additional hours of recordkeeping
divided among 160 respondents.
Many provisions of Ine proposed
regulations arc revisions of the cuirent
regulations, and it is not expected that
familiarization costs would be
substantial. However, estimates of these
costs are not available and therefore
APHIS invites public comment on the
costs the regulated community may
incur with respect to rule
familiarization and changes to their
application .systems.
Costs to APHIS are currently incurred
in the regulatory assessment and review
of submitted materials. Because the new
permit process is largely similar to the
current process, it Ls expected that
ongoing permit processing costs to
APHIS would remain essentially
unchanged. As a start-up cost to change
the permit system to accommodate
requirements of the proposed rule,
APHIS may potentially incur a ono-time
additional cost of $500,000. However
the current system is adaptable to the
new regulations and it is not anticipated
tliat tlvere would be any efficiency loss
during the transitional period. APHIS
would also potentially incur
incremental costs conducting outreach
activities for the proposed rule,
developing guidance documents to
ensure that the regulated community is
familiar with the requirements of the
rule, and providing staff training that
may be necessary. Because of the new
definition of the scope of the
regulations, APHIS may devote more
re.sourccs to consultations with
regulated parties if they request
consultation to determine whether
particular GE organisms are or are not
subject to the regulations. Such
consultation should decrease after the
first year or twm of implementation, as
such determinations of regulated status
accumulate and become the basis for
guidance of general applicability.
Initial Regulatory Flexibility Analysis
In accordance with the Regulatory
Flexibility Act. of 1980 (Pub. L. 96-354),
this analysis considers the economic
impact of the proposed rule on small
businesses, small organizations, and
small governmental jurisdictions.
Section 603 of the Act rrjquires that the
initial regulatory flexibility analysis
(IRFA) be made available for public
comments. This section addresses the
IRFA requirements, as stated in Sections
603(b) and 603(c) of the Act.
Reasons Action Is Being Considered
APHIS is taking action to amend 7
CFR part 340, which was promulgated
in 1987 under the authority of the
Federal Plant Pest Act of 1957 and the
Plant Quarantine Act of 1912, These
acts were subsequently subsumed
within the Plant Protection Act (PPA) of
2000, and the proposed revisions would
bring part 340 in alignment with this
Act. Advances in biotechnology and
accumulation of oversight experience by
APHIS have also made it necessary to
revise and update the regulations, and
in addition, the 2008 Farm Bill (The
Food, Conservation, and Energy Act of
2008) enacted most recently contains
provisions that need to bo incorporated
into the proposed rule. The proposed
changes would improve the regulatory
process by providing greater
transparency, flexibility, and efficiency.
Objective and Legal Basis for the Rule
The objectives of this rule are to
amend part 340 to provide consistency
with the PPA authorities and to
incorporate updates and improvements
to provide a more efficient regulatory
process while controlling potential risk
to plant health and the environment.
The PPA authorizes the Secretary of
Agriculture to implement programs and
policies designed to prevent the
introduction and spread of plant pests
and diseases. Specifically, the Secretary
of Agriculture is given the authority
under the PPA to prevent the
importation or dissemination of plant
pests and noxious weeds. To do so, the
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Federal Register/ Vol. 73, No. 197/Thursday, October 9, 2008/Proposed Rules 60035
Secretary may regulate the importation,
interstate movement, and release into
the environment of any plant, plant
product, biological control organism,
noxious weed, article, or means of
conveyance that could potentially
spread plant pests or noxious weeds.
Description and Estimate of the Number
of Small Entities Regulated
The proposed rule may affect a wide
range of public and private
biotechnology research facilities, GE
crop and seed production, food
processors, grain processors, and paper
producers that fall into various
categories of the North American
Industry Classification System (NAICS).
For the purpose of this analysis and
following the Small Business
Administration (SBA) guidelines, the
potentially affected entities are
classified within the following sectors;
Agriculture, Forestry, Fishing and
Hunting (Sector 11), Manufacturing
(Sectors 31-33), Wholesale Trade
(Sector 42), Retail Trade (Sector 44 and
45), Transportation (Sectors 48 and 49),
and Professional, Scientific and
Technical Services (Sector 54).
For the Agriculture, Forestry, Fishing
and Hunting sector, the subsectors of
Crop Production, Animal Production,
Forestry and Logging, and Support
Activities for Agriculture and Forestry
are potentially affected by this rule, The
proposed rule may affect a wide range
of establishments in the Crop
Production category. Establishments in
this category are considered small by
SBA standards if annual sales are not
more than S0.75 million. According to
the 2002 Census of Agriculture, 97
percent of the farming businesses are
considered small, Potentially affected
crop-producing industries, with their
NAICS codes in parenthB.se». are as
follows; Soybean Farming (111110);
Oilseed Farming (except soybean)
(111120); Dry Pea and Bean Farming
(111130); Wneat Farming (111140); Corn
Farming (111150); Rice Farming
(111160): Oilseed and Crain
Combination Farming (111191); All
Other Grain Fanning (111199); Potato
Farming (111211); Other Vegetable
(except potato) and Melon Farming
(111219); Orange Groves (111310);
Citrus (except orange) Groves (111320);
Apple Orchards (111331); Grape
Vineyards (111332); Strawberry Farming
(111333); Berry (except Strawberry)
Farming (111334); Tree Nut Farming
(111335); Fruit and Tree Nut
Combination Farming (111336); Other
Noncilrus Fruit Farming (111337);
Mushroom Production (111411); Other
Food Crops Grown Under Cover
(111419); Nursery and Tree Production
(111421); Floriculture Production
(111422); Tobacco Farming (111910);
Colton Farming (111920); Sugarcane
Farming (111930); Hay Farming
(111940); Sugar Beet Farming (111950);
Peanut Farming {111960); and All other
Miscellaneous Crop Farming (111970).
Some aspects of animal production
may be affected because some GE plants
are used for animal feeds and may have
enhanced nutritional value or other
benefits. In terms of animal production,
potentially affected entities include
ones within the following industries:
Beef Cattle Ranching and Farming
(NAICS 112111); Cattle Feedlots (NAICS
112112); Hog and Pig Farming (NAICS
112210); Sheep Farming (NAICS
112410); Goat Fanning (NAICS 112420);
and Apiculture (NAkS 112910). Except
for Cattle Feedlots, entities in all of
these industries are considered small by
SBA standards if annual sales are not
more than $0.75 million. Cattle Feedlot
establishments are considered small by
SBA standards if annual sales are not
more than $2 million. According to the
2002 Census of Agriculture. 93 percent
of Cattle Feedlot businesses, 99 percent
of Beef Cattle Ranching and Farming
businesses, 81 percent of Hog and Pig
Farming businesses, 99 percent of Sheep
and Goat farming businesses, and 99
percent of Apiculture businesses are
considered small.
For the Forestry and Logging
subsector the potentially affected
establishments are classified within
Timber Tract Operations (NAICS
1131 10); Forest Nursery and Gathering
of Forest Products (NAICS 113210): and
Logging (NAICS 113310).
Establishments in the category of
Timber Tract Operations and Forest
Nursery and Gathering of Forest
Products are considered small by SBA
standards if annual sales arc not more
than $6.5 million and establishments in
the category of Logging are considered
small if employment is not more than
500. According to the 2002 Survey of
Busine.ss Owners, 99 percent of
establishments in the Logging category
are considered small. Neither the
Census of Agriculture nor the Economic
Census tracks revenue for
establishments classified within Timber
Tract Operations and Forest Nursery
and Gathering of Forest Products.
In terms of Support Activities for
Agriculture and Fore.stry. the potentially
affected establishments are classified
within Cotton Ginning (NAICS 11511);
Soil Preparation, Planting, and
Cultivating (NAICS 115112); Crop
Harvesting (NAICS 115113); Postharvesl
Crop Activities (NAICS 115114); Farm
Management Services (115116) Support
Activities for Animal Production
(NAICS 115210); and Support Activitie.s
for Forestry (NAICS 115310).
Establishments in these categories are
considered small by SBA standards if
annual sales are not mare than S6.5
million. However, neither the Census of
Agriculture nor the Economic Census
reports revenue for these
establishments.
Entities that may be directly affected
by the proposed rule in the
Manufacturing Sector are classified
within Ethyl Alcohol Manufacturing
(NAICS 325193): Pesticide and Other
Agricultural Chemical Manufacturing
(NAICS 325320): Pharmaceutical
Preparation Manufacturing (NAICS
325412); and Medicinal and Botanical
Manufacturing (NAICS 325411),
Establishments in the Ethyl Alcohol
Manufacturing category are considered
small if they employ not more than
1,000 persons and those in the category
of Pesticide and Other Agricultural
Chemical Manufacturing (NAICS
325320) are considered small if they
employ not more than 500 persons. For
both the Pharmaceutical Preparation
Manufacturing (NAICS 325412): and
Medicinal and Botanical Manufacturing
(NAICS 325411) categories,
establishments are considered small if
they employ not more than 750 persons.
According to the 2002 Economic
Census, 98 percent of the establishments
in the Chemical Manufacturing Sector
had fewer than 500 employees and 99
percent had fewer than 1000, Therefore,
businesses in the chemical
manufacturing are predominantly small
by SBA standards,
In terms of Wholesale Trade, entities
that would bo potentially affected may
be found in the following categories:
Fre.sh Fruit and Vegetable Merchant
Wholesalers (NAICS 424480): Other
Grocery and Related Products Merchant
Wholeklers (NAICS 424490); Grain and
Field Bean Merchant Wholesalers
(NAICS 424510); Other Farm Product
Raw Material Merchant Wholesalers
(NAICS 424590); Farm Supplies and
Merchant Wholesalers (NAICxS 424910);
and Flower, Nurseiy Stock, and Florists’
Supplies Merchant Wholc>salers (NAICS
424930). EstablishmenLs in the above
categories are considered small by SBA
standards if they employ not more than
100 persons. According to the 2002
•Survey of Business Owners, 97 percent
of the establishments in this categofy
employed fewer than 100 people and
are considered small by SBA standards.
Retail Trade, establishments that
would be affected by the rules are in the
following categories: Nursery and
Garden Centers (NAICS 444220);
Supermarkets and Other Grocery Stores
(NAICS 443110): Fruit and Vegetable
800
60036 Federal Register/ Vol. 73, No. 197 /Thursday, October 9, 2008/Proposed Rules
Markets (NAICS 445230): All Other
vSpedalty Food Stores (NAICS 445299);
Food (Health) Supplement Stores
(NAICS 446191): Warehouse Clubs and
Superstores (NAICS 452910); and Florist
(NAICS 453110). Establishments in the
Nursery and Garden Center, Fruit and
Vegetable Markets. All other Specialty
Food Stores, Food (Health) Supplement
Stores: and Florist categories are
considered small by SBA standards if
annual sales are not more than S6,5
million. Supermarkets and Other
Grocery Stores are considered small by
SBA standards if annual sales are not
more than S25 million. While the
Economic Census reports total annual
sales, the Census does not provide a
breakdown of these establishments by
revenue categories.
In terms of the Transportation sector,
the potentially affected entities are in
the category Farm Product Warehousing
and Storage (NAICS 493130).
Establishments in this category are
considered small by SBA standards if
annual sales are not more than S23,5
million. However, the Economic Census
reports only total revenue for all
establishments in this category.
In terms of Profo-ssional, Scientific
and Technical Services, establishments
In the category of Research and
Development in the Physical,
Engineering, and Life Sciences (NAICS
54170) may be affected. Establishments
in this category are considered small by
SBA standards if they employ not more
than 500 persons. According to 2002
Economic Census, 82 percent of the
establishments in this category are
considered small,
Although information was not
available on the business sizes for all
potentially affected establishments,
based on the foregoing information we
can assume that the majority of the
entities that may be affected by the
proposed rule are small by SBA
standards.
Given the aforementioned, a review of
entities that have made application
requests to APHIS shows that of the 420
applicants for the last 6 years, 263 were
universities and colleges and public and
private research institutions. The
remainder of the applicants fall under
various NAICS cla.ssificalion codes
specified above but given time
constraints their business size could not
be readily determined. We w'ere able to
ascertain that the 263 institutions (63
percent) are large by SBA standards as
they fall under NAICS code 54170
Research and Development in Physical
Science. Establishments in this category
are considered small by SBA standards
if they employ not more than 500
persons. Even though the 2002
Economic Census suggests that 82
percent of the establishments in this
category are considered small, the
majority of applicants to APHIS are
large by SBA standards.^
Description and Estimate of Compliance
Requirement
The proposed rule would require
additional and modified information
collections through recordkeeping,
reporting, and notifications to APHIS
when certain events occur. The
proposed application process requires
certain new information. The current
and proposed rules both require
submission of reports following an
environmental release or field test, but
the proposed requirement is more
specific about the contents of such
reports. Both the current and proposed
rules require APHIS to be notified if an
unauthorized release occurs or if during
release the GE organism is found to have
cbaracterivStics substantially different
from those anticipated by the permit.
The proposed rule is more specific
about the types of records that must be
kept for importations, interstate
movements, and environmental
releases, where the current regulations
left more of these details to be specified
only in permit conditions. In terms of
record retention requirements, the
proposed rule spells out a 2-year
retention for records indicating that a
GE organism imported or moved
interstate reached its intended
destination, and a 5-year retention for
all otlier required records. By providii^
more specific information on what
records are required, the proposed rule
should alleviate some current burden
that may result from persons keeping
unnecessary records. In addition, APHIS
has established the Biotechnology
Quality Management System (BQMS),
which is a voluntary compliance
assistance unit within USDA APHIS.
BQMS would facilitate the regulatory
efforts of USDA APHIS by conducting
outreach activities and providing
compliance assistance to the regulated
community. This would lessen any
burden of the proposed rule to the
regulated commimity.
Duplication, Overlap, and Conflict With
Existing Rules and Regulations
APHIS has identified areas w^here the
proposed rule will need to be closely
coordinated with other Federal rules
and statutory authorities. Coordination
Isas been an important aspect of the
daily implementation of the current
^ Tht! size detenninalion was made asing publii;
iiiformation about these entities. This information
wa.s primarily retained from the entities' Web sites.
regulation, and APHIS foresees
additional areas for coordination under
the proposed rule. In particular, APHIS
will coordinate with the Food and Drug
Administration (FDA) and the
Environmental Protection Agency
(EPA). FDA regulates GE organisms
under the authority of the Federal Food,
Drug and Cosmetic Act and the Public
Health Service Act (42 U.S.C. 262 ei
seq.), as appropriate. The EPA regulates
plant-incorporated protectants under
the Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA) and certain
biological control organisms under the
Toxic Substances Control Act (TSCA).
As examples of areas that need
coordination, some of the plant-
incorporated protectants regulated by
EPA are also subject to APHIS
requirements under the PPA. Also, FDA
is the primary U.S. agency re.sponsib]e
for ensuring the safety of commercial
food and food additives, and FDA
authority extends to any nonpe.sticidal
substance that may be introduced into a
new GE plant and that is expected to
become a component of food, The
proposed regulations would clarify the
regulatory scope and procedures used
by APHIS relative to these other
agencies and improve the coordination
process.
Significant Alternatives to the Rule
APHIS considered several significant
alternatives during development of this
proposed rule. We have compared the
selected alternatives to others that were
not selected to evaluate their feasibility
and to consider whether any
alternatives provide ways to minimize
significant economic impacts on small
entities. We have not Identified any
selected alternative that imposes
disproportionate costs on small
businesses, or any non-selected
alternative that would both achieve the
regulatory purposes and reduce costs for
small businesse.s.
The selected alternative regarding the
scope of the regulatory oversight was to
add considerations of noxious weed risk
in addition to evaluating plant pest
risks, and to use genetic transformation,
coupled with a determination by the
Administrator as to whether a GE
organism met certain risk-based criteria,
as the trigger for regulation. Other
alternatives considfjred included
continuing to base the scope of
regulation only on plant pest risks, or
trying to develop a set of solely trait-
based criteria that could be used to
predict what articles would be regulated
without the need for determinations by
the Administrator. The first of the.se
alternatives could have resulted in costs
from damages caused by a GE plant with
801
Federal Register/VoL 73, No. 197/Thursday, October 9.
noxious weed aspects that was not
regulated under the plant pest risks
standard. The second alternative was
not considered technically feasible, and
could also have resulted in costs for
persons who erroneously decide their
GE plant is not within the scope of the
regulations, but are overruled by a later
determination by the Administrator that
the GE plant is regulated.
The selected alternative for providing
transparenc}' and predictability to the
permitting system was to establish
permit categories for environmental
relea.ses of plants based on newly
devised criteria. We also considered
evaluating all requests for
environmental release permits on a
case-by-case basis, without categories.
This alternative would have resulted in
less predictability for applicants, and
likely would have increased their costs
for information collection because
applications known to be in a particular
category can contain less information
about non-relevant areas.
The selected alternative regarding the
duration period for permits was to make
multi-year permits for interstate
movement and importation more
feasible by removing the one-year limit
for interstate movement permits and the
requirement to obtain a new importation
permit for each imported shipment. We
also considered alternatives to maintain
either the current or aiternative specific
time limits for such permits. These
alternatives would have resulted In
additional costs for applicants who
would have to reapply for permits,
rather than having tne original pemtit
issued with an appropriate duration.
C. Executive Order 12372
This program/activily is listed in the
Catalog of Federal Domestic Assistance
under No. 10,025 and is subject to
Executive Order 12372, which requires
intergovernmental consultation with
State and local officials, (See 7 CFR part
3015, subpart V.)
D. Executive Order 12988
This proposed rule has been reviewed
under Executive Order 12988, Civil
justice Reform. If this proposed rule is
adopted: (1) No State or local law.s or
regulations would be preempted by thi.<!
rule; (2j no retroactive effect will be
given to this rule: and (3) administrative
proceedings will not be required before
parties may file suit in court challenging
this rule.
E. Paperwork Reduction Act
In accordance with section 3507(d) of
the Paperwork Reduction Act of 1995
(44 U.S.C. 3501 et seq.], the information
collection or recordkeeping
requirements included in this proposed
rule have been submitted for approval to
the Office of Management and Budget
(OMB). The information collection or
recordkeeping requirements in current 7
CFR part 340 have been approved under
OMB Control No. 0579-0085. Please
send written comments to the Office of
Information and Regulatory Affairs.
OMB, Attention: Desk Officer for
APHIS, Washington, DC 20503. Please
state that yom comments refer to Docket
No. APHIS-2008-0023. Please send a
copy of your comments to: (1) Docket
No. APHlS-2008-<l023, Regulatory
Analysis and Development, PPD,
APHIS, Station 3A-03.8, 4700 River
Road Unit 118, Riverdale, MD 20737-
1238. and (2) Clearance Officer, OCfO.
USDA, room 404-W, 14th Street and
Independence Avenue SW.,
Washington, DC 20250. A comment to
OMB is best assured of having its full
effect if OMB receives it within 30 days
of publication of this proposed rule.
This proposed rule contains certain
Information collection and
recordkeeping requirements that would
apply to persons and their agents
engaged in the importation, interstate
movement, or release into the
environment of any GE organism that is
subject to the regulations. The majority
of the requirements would apply to
persons moving GE organisms under a
permit issued by APHIS, but some
requirements also apply to persons
engaged in regulatory activities with GE
organisms even when no permit is
required, e.g., when they are exempted
from the interstate movement permit
requirement.
The proposed information and
recordkeeping requirements are found
in § 340.3, Permit conditions, and in
§340.7, Compliance, enforcement, and
remediai action. Permit conditions for
individual permits issued under the
regulations may also require that certain
records relevant to the particular
movement must be kept.
The proposed permit conditions for
shipments imported or moved interstate
include maintaining records of the same
types of information that the current
regulations require to be on the package
labeling of such shipments (nature and
quantity, sender, destination, permit
number, etc.) We believe that most
persons shipping or importing GE
organisms already maintain such
records as part of normal business
practices.
The proposed permit conditions for
environmental releases include keeping
records of ail protocols or guidelines
used to direct any environmental
release. The current regulations already
require persons conducting an
2008 /Proposed Rules 60037
environmental release under permit or
notification to create and submit to
APHIS a field test report, and in many
case.s the protocol or guidelines would
normally be included in these field
reports. This-proposed change would
require that the protocols or guidelines
be kept in all cases as distinctly
identifiable records, which may cause
some increase in recordkeeping burden.
In some particular environmental
release cases where higher risk levels
make it necessary, the proposed rule
would allow APHIS to add a special
permit condition requiring the permit
holder to maintain and make available
to APHIS written manuals or protocols
describing how specified permit
conditions will be met. such as
management practices used for the
environmental release, training,
communications, and identity
preservation systems. This would be
used in cases where it is deemed
necessary to provide specific guidance
in addition to the proposed general
condition for all permits (i.e., that the
holder must keep records related to
permitted activities of sufficient quality
and completeness to demonstrate
compliance with all permit conditions
and requirements under this part).
Another proposed permit condition
would require permit holders to develop
and keep a written contingency plan to
respond to any unauthorized
environmental release. Both ofthe,se
recordkeeping requirements would be
added because some researchers or
developers were found to be unclear
about what management and
communications practices were needed
to prevent unauthorized releases, and
also about their respon-sibilities and the
measures they must lake in the event of
an unauthorized release.
The proposed procedure to apply for
an environmental release permit
requires applicants to submit a great
deal of information characterizing the
nature of the GE organism, the type of
movement and release planned, plans
and methods used to prevent
unauthorized releases, and other
matters. Most of the same information Is
obtained through the current
application process, which allows the
Administrator to require an applicant to
submit any additional information that
is needed for adequate evaluation of the
application. The proposed application
procedure is more specific in de.scribing
what information is required, and may
result in a slight increase in the amount
of information submitted with the
average application.
The reporting burden for permit
holders under the proposed rule would
be similar to the burden under the
802
60038 Federal Register/Vol. 73, No. 197/Thursday, October 9, 2008/Proposed Rules
current regulations. In both cases they
must submit reports of all field tests to
APHIS, report any unauthorized
releases, and submit any additional
reports required as individual permit
conditions in their permits.
The current regulations do not specify
record retention periods, although some
permits APHIS issued included specific
retention requirements as permit
conditions. This proposal would require
that records associated with an
importation or interstate shipment must
be retained for at least 2 years after
completion of the movement, and all
other records {e.g., regarding
environmental releases) must be
retained for at least 5 years after
completion of all obligations required
under a relevant permit or exemption.
We are soliciting comments from the
public (as well as affected agencies)
concerning our proposed information
collection and recordkeeping
requirements. These comments will
help us:
(1) Evaluate whether the proposed
information collection is necessary for
the proper performance of our agency’s
functions, including whether the
information will have practical utility;
(2) Evaluate the accuracy of our
ostimalo of the burden of the proposed
information collection, including the
validity of the methodology and
assumptions used;
(3) Enhance the quality, utility, and
clarity of the information to bo
collected: and
(4) Minimize the burden of the
information collection on those who are
to respond (such as through the use of
appropriate automated, electronic,
mechanical, or other technological
collection techniques or other forms of
information technology: e.g., permitting
electronic submission of responses).
Estimate of burden: Public reporting
burden for this collection of information
is estimated to average 2 hours per
response.
Bespondents: Public and private
biotechnology research facilities, GE
crop and seed producens, food
processors, grain processors, and paper
producers that fall into various
categories of the North American
Industry Classification System.
Estimated amnia] number of
respondents: 160 .
Estimated annual number of
responses per respondent: 2.
Estimated annual number of
responses: 320.
Estimated total annua! burden on
respondents: 640 hours.
Copies of this information collection
can be obtained from Celeste Sickles,
the Agency Information Management
Specialist, at (301) 851-2908.
F. E-Govemment Act Compliance
The Animal and Plant Health
Inspection Service is committed to
compliance with the E-Govemment Act
to promote the use of the Internet and
other Information technologies, to
provide increased opportunities for
citizen access to Government
information and services, and for other
purposes. For information pertinent to
E-Govemment Act compliance related
to this proposed rule, please contact
Mrs. Celeste Sickles, the Agency
Information Management Specialist, at
(301) 851-2908.
List of Subjects in 7 CFR Part 340
Administrative practice and
procedure, Biotechnology, Genetic
engineering. Imports, Packaging and
containers, Permits, Plant diseases and
pests, Noxious weeds, Transportation.
Accordingly, we propose to revise 7
CFR part 340 to read as follows;
PART 340— IMPORTATION,
INTERSTATE MOVEMENT, AND
RELEASE INTO THE ENVIRONMENT
OF CERTAIN GENETICALLY
ENGINEERED ORGANISMS
Sec.
340.0 Scope and general restrictions.
340.1 Definitions.
340.2 Procedure for permits.
340.3 Permit conditions.
340.4 Conditional exemptions from the
requirement for a permit For intenstate
movement.
340.5 Petition for new conditional
exemptions from the requirement for a
permit.
340.6 Petition for nonregulated status.
340.7 Compliance, enforcement, and
remedial action.
340.8 Confidential busine.ss information.
340.9 Costs and charges.
Authority: 7 U.S.C. 7701-7772 and 7781-
7786; 31 U.S.C. 9701: 7 CFR 2.22, 2.80, and
371.3.
§ 340.0 Scope and general restrictions.
(a) In order to prevent the
unauthorized introduction or
dissemination of a plant pest or noxious
weed, no person shall import, move
interstate, or release-into the
environment genetically engineered
organisms described in paragraph (b) of
this section, unless the importation.
inter.staf«? movement, or release into the
environment:
(1) Is authorized under a permit
issued by the Administrator in
accordance with § 340.2, or
(2) Is exempt from the requirements
for a permit in accordance with § 340.4
or § 340.5, or
(3) Is approved for nonregulated
status in accordance with § 340.6 or has
previously been approved for
nonregulated status pursuant to former
regulations under this part, or
(4) Is excluded in accordance with
paragraph (d) of this section.
(b) Genetically engineered organisms
W'hose importation, interstate
movement, or release into the
environment is subject to the
regulations in this part are:
(1) Genetically engineered plants if:
(1) The unmodified parent plant from
which the GE plant was derived is a
plant post or noxious weed, or
(ii) The trait introduced by genetic
engineering could increase the potential
for the GE plant to be a plant pest or
noxious weed, or
(iii) The risk that the GE plant poses
as a plant pest or noxious weed is
unknown, or
(iv) The Administrator determines
that the GE plant poses a plant pest or
noxious weed risL
(2) Genetically engineered non-plant,
non-vertebrate organisms if:
(i) The recipient organism can directly
or indirectly injure, cause damage to, or
cause disease in plants or plant
products: or
(ii) The GE organism has been
engineered in such a way that it may
increase the potential for it to be a plant
pest: or
(iii) The risk that the GE organism
poses as a plant pest is unknown, or
(iv) The Administrator determines
that the GE organism poses a plant post
risk.
(3) Opportunity to consult APHIS.
Any person may contact APHIS to
di.scuss how the criteria of this
paragraph apply in the case of a
particular GE organism or group of
organisms.
(c) The Administrator may issue
permits for the importation, Interstate
movement, or release into the
environment of certain genetically
engineered organisms described in
paragraph (a) of this section. Tho.se
permits may include such requirements
or conditions as the Administrator
deems nec;e.ssary to prevent the
unauthorized introduction or
dissoraination of a plant pest or noxious
weed. The Administrator may also
designate certain exemptions from the
requirement to obtain permits. The
Administrator may also approve for
nonregulated status a genelicaliy
engineered organism described in
paragraph (a) of this section for which
a determination has been made by the
Administrator that the organism is
unlikely to bo a plant pest or noxious
weed.
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Federal Register/ Vol. 73, No. 197 /Thursday, October 9, 2008 /Proposed Rules 60039
(d) Genetically engineered
microorganisms that are regulated as
biological control organisms under the
Federal Insecticide, Fungicide, and
Rodenticide Act are not subject to the
regulations in this part. Genetically
engineered microorganisms where the
recipient microorganism is not a plant
pest and which has resulted from the
addition of genetic material from a
donor organism where the material is
well characterized and contains only
non-coding regulatory regions are not
subject to the regulations in this part.
§340.1 Definitions.
Terms used in the singular form in
this part shall be construed as the
plural, and vice versa, as the case may
demand. The following terms, when
used in this part, shall be construed,
respectively, to mean:
Administrator. The Administrator of
the Animal and Plant Health Inspection
Service (APHIS) or any other employee
of APHIS to whom authority has been,
or may be, delegated to act in the
Administrator’s stead.
Anima! and Plant Health Inspection
Sfiivice (APHIS). An agency of the
United States Department of
Agriculture.
Confidential business information,
CBi Information such as trade secrets or
commercial or financial information
that may be exempt from disclosure
under Exemption 4 of the Freedom of
Information Act (FOIA), because
disclosure could reasonably be expected
to cause substantial competitive harm.
USDA regulations on how the agency
will handle CBI and how to determine
what information may be exempt from
disclosure under FOIA (5 U.S.C, 552)
are found at 7 CFR 1.12.
Contained facility, contained
structure. A physical structure designed
to minimize release into the outdoor
environment. Examples of contained
structures include, but are not limited
to, laboratories, containment
greenhousOxS, bioreactors, and
fermenters.
Contingency plan. A written plan
staling how the responsible person will
respond in the event of the
unauthorized environmental release of
GE oiganisms.
Donor organism. The organism from
which genetic material is obtained for
transfer to the recipient mganisra in the
process of genetic engineering.
Environmental release. See definition
of Release into the environment.
Exempt, exempted, exemption from
permit. A determination by the
Administrator that the importation,
interstate movement, and/or relea.se into
the environment of an organism or class
of organisms described In § 340.0(a) is
not subject to the requirement to have
a permit imder this part. An exemption
from one type of permit (e.g., interstate
movement) does not remove remaining
obligations to obtain other permits
under this part.
Genetic engineering. The genetic
modification of organisms by
recombinant DNA techniques.
Genetically engineered, GE. A term
applied to organisms that have been
produced by genetic engineering, e.g.,
GE organisms, GE plants.
Import and importation. To move
into, or the act of movement into, the
territorial limits of the United States.
Inspector. Any employee of the
Animal and Plant Health Inspection
Service, U.S. Department of Agriculture,
or other penson, authorized by the
Administrator, in accordance with law
to enforce the provisions of this part.
Interstate movement. Movement from
any State into or through any other
State.
Means of conveyance. Any personal
property used for, or intended for use
for, the movement of any other personal
property. This specifically includes, but
is not limited to, automobiles, trucks,
railway car-s, aircraft, boats, freight
containers, and other means of
transportation.
Nonregulatod status. A determination
by the Administrator that an organism
described in § 340.0(a) is not subject to
any of the regulatory requirements of
this part.
Noxious weed. Any plant or plant
product that can directly or indirectly
injure or cause damage to crops
(including nursery stock or plant
products), livestock, poultry, or other
interests of agriculture, irrigation,
navigation, the natural resources of the
United Slates, the public health, or the
environment.
Organism. Any active, infective, or
dormant stage or life form of an entity
characterized as living, including
vertebrate and invertebrate animals,
plants, bacteria, fungi, mycoplasraas,
mycoplasina-like organisms, as well as
entities such as viroids, viruses, or any
entity characterized as living, related to
the foregoing.
Permit. A written authorization by the
Administrator for the importation,
interstate movement, and/or release into
the environment of a GE organism under
this part.
Person. Any individual, partnership,
corporation, company, joint venture,
society, association, or other legal
entity.
Plant. Any plant (including any plant
part) for or capable of propagation,
including trees, tissue cultures, plantlet
cultures, pollen, shrubs, vines, cuttings,
grafts, scions, buds, bulbs, roots, and
seeds.
Plant pest. Any living stage of any of
the following that can directly or
indirectly injure, cause damage to, or
cause disease in any plant or plant
product: A protozoan, a nonhuman
animal, a parasitic plant, a bacterium, a
fungus, a virus or viroid, an infectious
agent or other pathogen, or any other
living stage similar to or allied with any
of these organisms.
Plant product. Any flower, fruit,
vegetable, root, bulb, seed, or other
plant part that is not included In the
definition of plant; or any manufactured
or processed plant or plant part.
Recipient organism. The organism
that will receive the genetic material
from a donor organism in the process of
genetic engineering (once the organism
is engineered it is referred to as the
genetically engineered (GE) organism).
Release into the environment.
Dispersal beyond the constraints of a
contained facility or secure shipment.
Synonymous wdth the term
environmental release.
Responsible person. The person who
has control and will maintain control
over a GE organism during its
importation, interstate movement, or
release into the environment and
assures compliance with all conditions
contained in any applicable permit or
exemption as well as other requirements
in this part. A responsible person shall
be at least 1.8 years of age and be a legal
resident of the United States or
designate an agent who is at least 18
years of age and a legal resident of the
United Slates.
Secure shipment. Shipment in a
container or a means of conveyance of
sufficient strength and integrity to
withstand leakage of contents, shocks,
pressure changes, and other conditions
incident to ordinary handling in
transportation.
Signature, signed. The discrete,
verifiable symbol of an individual
which, when affixed to a writing with
the knowledge and consent of the
individual, indicates a present intention
to authenticate the writing. This
includes electronic signatures when
authorized by the Administrator.
State. Any State of the United States,
the District of Columbia, American
Samoa, Guam, Northern Mariana
Islands, Puerto Rico, the Virgin Islands
of the United States, and any other
Territories, Possessions, or Districts of
the United States.
State or tribal regulatory official. State
or tribal official with responsibilities for
plant health, or any other duly
designated State or tribal official, in the
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60040 Federal Register/ Val. 73, No. 197 /Thursday, October 9, 2008 /Proposed Rules
State or on the tribal lands where the
iraportalion. interstate movement, or
release into the environment is to take
place.
United States. All of the States,
Write, writing, written. Any document
or communication required by this part
to be in writing may also be provided
by electronic communication when
authorized by the Administrator.
§ 340.2 Procedure for permits.
(a) General A permit is required for
the importation, interstate movement, or
release into the environment of any GE
organism that is subject to this part, as
described in §340.0, The responsible
person seeking a permit for the
importation, interstate movement, or
release into the environment of such
organisms shall submit a written
application for a permit to APHIS in
accordance with paragraph {cj of this
section and obtain the permit prior to
the importation, interstate movement, or
release into the environment.
(b) Types of permits. The
Administrator may issue the following
three typos of permits under this part.
(1) Import permit. Import permits are
for secure shipment via any means of
conveyance from outside the United
States into contained facilities within
the United States.
(2) Interstate movement permit.
Interstate movement permits are for
secure shipment via any means of
conveyance Itom a contained facility in
any State into or through any other State
to another contained facility.
(3) Environmental release permit.
Environmental release permits are for
the environmental release of GE
organisms. In cases in which
importation and interstate movements
will occur incidental to an
environmental release, the importation
and interstate movements will also be
authorized under the environmental
release permit.
(c) Permit application information
requirements. Applicants must submit
to APHIS sufficient information about
the specific nature of the GE organism
and the particular proposed permit
conditions, so that the Administrator is
able to consider whether the proposed
importation, interstate movement, or
release into the environment is likely to
result in the introduction or
dissemination of a plant pest or noxious
weed. The basic information required in
permit app]ication,s is described in this
paragraph. The type and level of detail
needed for the Administrator to issue a
permit may vary by type of permit. For
environmental releases, application
information will be used to sort
proposed releases of GF, organisms into
administrative categories described in
paragraph fd) of this section. Applicants
sliouid consult with APHIS prior to
applying for permits in order to obtain
further guidance as to what additional
information the Administrator may
require to be submitted with the
application.
(1) Information required in all permit
applications. Each application must
include all of the following information,
and any other information specified for
individual types of permits as described
in this paragraph:
(i) The name, title, and contact
information {e.g., mailing address, e-
mail, telephone and fax numbers) of the
responsible person;
(ii) The type of permit sought
(importation, interstate movement, or
environmental release, and if the permit
is for environmental release, which
category):
(iii) Information necessary to identify
and characterize the GE organism(s) for
which a permit is sought, including:
(A) The scientific names of all donor
and recipient species plus any
designations used for the GE
organlsm(s} (e.g., strain, line, variety);
(B) The form of the GE organism (e.g.,
seeds, rootstocks, tubers, spores, larvae,
eggs) and the amount (e.g., numbers,
total weight or volume): and a
description of any biological material
accompanying the GE organism under
permit {e.g,, culture medium, or host
organisms, etc.):
to The anticipated phenotype of the
GE organism and the nature of the
inserted sequences or other genetic
modification intended to confer the
phenotype:
(D) Intended uses of the GE organism
after the termination of the importation,
interstate movement, or environmental
release (e.g., contained research in
laboratories or containment
greenhouses, culturing, propagation,
breeding, processing for analysis or
manufachire, sale and distribution far
consumption); and
(E) Description of how the GE
organism wi)l be marked, labeled, or
otherwise identified during the
importation, interstate movement, or
environmental release;
(iv) The proposed time frame
(estimated start and duration) within
which the lmporlation(s), interstate
niovement(s) or environmental
release(s) will occur;
(v) Description of how permit
requirements will be communicated to
persons having contact with the GE
organism under permit;
(vi) Description of any training given
to persons having contact with the GE
oi^anism under permit, including but
not limited to detailed information on
how this training will facilitate
compliance with conditions imposed
under the permit and any other
regulatory requirements under this part;
and
(vii) A certification statement signed
by the responsible person that certifies
that the application information is
correct.
(2) Additional information required in
all applications for imporiation permits,
interstate movement permits, and all
environmental release permits that
include importation or interstate
movement.
(i) The localion(s) of the origin(s) and
destination(s), including information on
the addresses, and contact details of the
sender{s) and recipient(s), if different
from the responsible person.
(ii) A description of the method of
secure shipment.
(iii) A description of the manner in
which packaging material, shipping
containers, and any other material
accompanying the GE organism will be
disposed.
(3) Additional information required in
all environmental release permit
applications. Information should
address the persistence risk and
potential harm of the GE organism in
the environment, including but not
limited to:
(i) A description of how the
phenotype of the GE organism differs
from the phenotype of the recipient
organism, particularly with respect to
potential interactions with and its
likelihood of persistence in the
environment,
(ii) The location and size of all
proposed release sites, including area,
geographic coordinates, addresses, and
contact information of a person at each
release site, if different from the
responsible person, Include information
about the ecology and agronomy of each
site, including but not limited to;
(A) Presence of any wild or cultivated
species that are sexually compatible
with the GE organism;
(B) Presence of any Federally-listed
threatened or endangered species that
could interact with the GE organism
during the release:
(C) Presence of any designated critical
habitat, or habitat proposed for
designation, in the area of the relea,se
site: and
(D) Land use history of the site and
adjacent areas.
(iii) A description of the site
management practices and control
procedures designed to make it unlikely
that there will be unauthorized
introduction or dissemination of the GE
organism beyond the proposed area and
805
Federal Register/ Vol. 73, No. 197/Thursday, October 9, 2008/Proposed Rules 60041
the permit time frame of release. Each
of the descriptions shall include:
(A) Description of the methods and
stages of transport of the GE organism
from a contained facility to the
environmental release site, and any
storage methods used at the site;
(B) Description of methods of
planting, inoculation, or release; any
reproductive or cultural controls;
methods of treatment and harvest used
for the GE organism; and a proposed
plan for monitoring the site for pe.sts,
diseases, and effects on other organisms
during the time the GE organism is
released;
{C| Description of the methods and
stages of transport of the GE organism
from release site back into contained
facilities, or methods of devitalization at
the site(s) of the environmental release;
(D) Description of the cleaning,
disinfection, or other methods used to
make it unlikely that unauthorized
dissemination of the GE organism into
the environment could occur via means
of conveyance and other articles {e.g.,
planters, harvesters, containers);
(E) Description of any post-release
land use practices, including any
monitoring plans to ensure that the GE
organism or Us progeny are unlikely to
reproduce and disseminate in the
environment after the termination of the
release {o.g., managing volunteer
plants); and
(F) Description of the contingency
plans associated with the release.
(d) Administrator action on permit
applications. An initial review should
generally be completed by APHIS
within 15 days of the receipt of the
application for importation or interstate
movement permits, and within 30 days
for environmental release permits. An
application will be considered complete
when the Administrator determines that
it includes all information required by
this section and any additional
information that the Administrator
determines is needed for review, ff
necessary after its initial evaluation of
an application. APHIS will notify the
applicant in writing if the submitted
application information is incomplete,
and the applicant will be provided the
opportunity, without prejudice, to
revise the application information to
meet the needs for administrative
processing and scientific review. Once
the Administrator has determined that
an application is complete, the
Administrator will commence review.
The APHIS review should generally be
completed within 60 days after it is
determined to be complete for
importation and interstate movement
permits, and within 120 days after it is
determined to be complete for
environmental release permits.
(I) Administratii^ categories for
environmental mleases. "Ihe
Administrator will use the following
categories to efficiently administer the
program and tailor regulatory oversight
in a manner that is commensurate with
risk. Environmental releases of GE
plants are assigned to one of four
categories (A-D), using the factors
described in (i-iv). A fifth category (E)
is for environmental releases of all non-
plant organisms; applications in this
category will be reviewed on a case-by-
case basis.
(1) Initial sorting into categories. The
Administrator will use the following
factors to initially sort environmental
releases into administrative categories.
{Aj Persistence of the nonmodified
plant, ranked as fonow.s:
(J) Low: Populations of the recipient
plant are unlikely to persist in the
environment without human
intervention, and the recipient plant has
no inlerfertile wild relatives in the
United States.
(2) Moderate: Populations of the
recipient plant are known to be weakly
persistent in the environment without
human intervention, or the recipient
plant has inlerfertile wild relatives in
the United Stales.
(3) High: Populations of the recipient
plant are known to be strongly
persistent in the environment without
human intervention, or the recipient
plant has interfertile wild relatives in
the United States which are aggressive
colonizers.
(4) Severe; The recipient plant is a
Federally-listed noxious weed or is
known to be similarly aggressive in its
ability to colonize and persist in the
environment w'ithout human
intervention.
(B) Potential harm or damage of the
engineered traits, ranked as follows:
(U Low: Any new proteins or
substances produced are unlikely to be
toxic or otherwise cause serious harm to
humans, vertebrate animals, or
invertebrate organisms upon
consumption of or contact with the
plant or plant parts; and
(1) No morphological changes which
could cause mechanical injury or
damage; and
(//) Introduced sequences are known
not to result in plant disease, and
confers no or very low increased disease
susceptibility.
(2) Modeiate: Any new proteins or
substances produced are unlikely to be
toxic or otherwise cause serious harm to
humans or vertebrate animals upon
consumption of or contact with the
plant or plant: or
(i) Novel resistance to the application
of an herbicide: or
(ij) Novel ability to cause mechanical
injury or damage: or
{Hi] Produces proteins or substances
that are associated with plant disease
that are not prevalent or endemic in the
area of release, or that confer an
increased su.sceptibility to disease.
(3) High: Any new proteins or
-substances produced may bo toxic or to
otherwise cause serious harm to humans
or vertebrate animals, upon
consumption of or contact with the
plant or plant parts; or
(i) Produces an infectious entity
which can cause disease in plants.
(4) Severe: Any now proteins or
substances produced are known or
likely to be highly toxic or fatal to
humans or vertobrato animals, upon
consumption of or contact with the
plant or plant parts.
(C) Environmental releases will be
initially sorted into administrative
categories A-D as shown in Table 1,
based upon the persistence risk and
potential harm described in paragraphs
(d)(l)(i){A) and (B) of this .section,
Table 1 to § 340.2(d)(1)— Initial Sorting Into Permit Administrative Categories (A, B, C, and D) for Environ-
mental Releases of GE Plants, Based Upon Persistence Risk of the Recipient Plant Species and Poten-
tial Harm or Damage of the Engineered Trait
Persistence *
Potential harm or damage of engineered trait
Low
Moderate
High
Severe
Moderate
A
B
C
D
High
B
B
c
D
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60042 Federal Register/ Vol. 73, No. 197 /Thursday. October 9, 2008 /Proposed Rules
Table 1 to §340,2{d)(l)— Intial Sorting Into Permit Administrative Categories (A, B, C, and D) for Environ-
mental Releases of GE Plants, Based Upon Persistence Risk of the Recipient Plant Species and poten-
tial Harm or Damage of the Engineered Trait— C ontinued
Persistence*
j Potential harm or damage of engineered trait
Low
Moderate
High
Severe
Severe
D
D
D
D
’ Persislence risk of the recipieni plant species.
(2) Modification of initial sorting
based upon additional considerations.
Following initial sorting using the
factors described in paragraph (l)(i) of
this section, the Administrator may
reassign the environmental release to a
different category based upon one or
more of the following factors:
(i) How the recipient plant is used;
(ii) Whether the added trait
significantly alters the persislence risk
of the GE plant;
(iii) Whether the gene function is
known and based upon empirical
observation of the added trait in the
same species: and
(iv) Any other information the
Administrator deems relevant to the risk
of introduction or dissemination of a
plant pest or noxious weed.
(3) APHIS review and assignment of
permit conditions. The Administrator
will conduct a review and assign
appropriate permit conditions so that
the proposed activity will be conducted
in a manner that makes it unlikely to
result in the introduction and
dissemination of a plant pest or noxious
weed.
(4) State or tribal review and
comment. The Administrator will
submit for notice and review a copy of
the permit application and any permit
conditions to the appropriate state or
tribal regulatory official. Comments
received from the state or tribal
regulatory official may be considered by
the Administrator prior to permit
issuance.
(5) .Site inspection. Prior to and after
permit issuance, an inspector may
inspect the sites or the means of
conveyance associated with the
proposed importation, interstate
movement, or release into the
environment. The responsible person
must allow any such inspections.
(6) Issuance of a permit. The
Administrator may issue a permit if the
Administrator concludes that the
actions allowed under the permit are
unlikely to result in the introduction or
di.ssemination of a plant pest or noxious
weed.
(i) Prior to the issuance of a permit,
the responsible person must agree in
writing, in a manner prescribed by the
Administrator, that the responsible
person and all agents of the responsible
person will comply with the permit
conditions. The Administrator will deny
the permit application if the responsible
person does not agree that both the
responsible person and all of his or her
agents will comply with all of the
permit conditions.
(ii) If a permit is issued, the permit
will include specific permit conditions
required by the Administrator in
accordance with § 340.3. If a permit is
denied, within a reasonable lime
thereafter the applicant will be informed
in writing of the reasons why the permit
was denied and will be given the
opportunity to appeal the denial In
accordance with the provisions of
paragraph (g) of this section.
(c) Denim or revocation of a permit.
Permits may be denied or revoked in
accordance with this paragraph.
(1) Denial. The Administrator may
deny an application for a permit if:
(i| The Administrator cannot
conclude based on the application that
the actions proposed under the permit
are unlikely to re.sult in introduction or
dissemination of a plant pest or noxious
weed; or
(ii) The Administrator receives
information apart from the application
tliat precludes a conclusion by the
Administrator that the actions proposed
under the permit would be unlikely to
result in the introduction or
dissemination of a plant pest or noxious
weed; or
(iii) The Administrator determines
that the responsible person or any agent
of the responsible person has failed to
comply at any time with any provision
of this part. This would include failure
to comply with the conditions of any
permit issued.
( 2 ) Revocation. The Administrator
may revoke a permit if:
(i) The Administrator receives
information subsequent to issuing a
permit and makes a determination based
upon this information that the
circumstances have changed such that
actions under the permit would be
likely to r^ult in the introduction or
dissemination of a plant pest or noxious
weed: or
(ii) The Administrator determines that
the responsible person or any agent of
the responsible person has failed to
comply at any time with any provision
of this part. This would include failure
to comply with the conditions of any
permit issued.
(f) Notice of revocation. The
Administrator may revoke, either orally
or in writing, any permit which has
been issued. If the revocation is oral, the
Administrator will communicate the
revocation and the reasons for it in
writing as promptly as circumstances
allow.
(g) Appeal of denial or revocation of
permit. Any person who has been
denied a permit or had a permit revoked
may appeal the decision in writing to
the Administrator within ten days after
receiving the written notification of the
revocation or denial. The appeal shall
state all of the facts and reasons upon
which the person relies to assert that the
permit was wrongfully revoked or
denied, The Administrator will grant or
deny the appeal, in writing, stating the
reasons for the decision as promptly ns
circumstances allow. Upon request of
the applicant, a hearing may be hold to
resolve any conflict as to any material
fact. Rules of practice concerning such
a hearing will be adopted by the
Administrator. This administrative
remedy must be exhausted before a
person can file suit in court challenging
the denial or revocation ol'a permit,
(h) Amendment or transfer of permits.
Permits issued under this part may only
be amended or transferred in
accordance with this section.
( 1 ) Amendment at responsible
person’s request. Where circumstances
have changed so that a responsible
person desires to have the permit
amended, such responsible person must
submit a written Justification and
provide supporting information to
APHIS. The Administrator will review
the amendment request, and may amend
the permit. Prior to issuance of an
amended permit, the responsible person
must agree in writing that he or she and
all of his or her agents will comply with
the amended permit and conditions.
(2) Amendment initiated by APHIS.
The Administrator may amend any
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permit and its conditions at any time,
upon determining that the amendment
is needed to make it unlikely that
actions under the permit tvould result in
the introduction or dissemination of a
plant post or noxious weed, or to ensure
that the permit is in compliance with all
of the requirements of this part. As soon
as circumstances allow, the
Administrator will notify the
responsible person in writing of the
amendment to the permit and the
reason(s) for it. The responsible person
must agree in writing to comply with
the permit and conditions as amended
before the Administrator will issue the
amended permit. If the responsible
person does not agree in writing to
comply with the amended permit and
conditions, the exi.sting permit will be
revoked.
(3) Transfer of permits. Permits Issued
through this part may only be
transferred by the Administrator in
response to a request by both the
responsible person and the proposed
transferee, or in the case of a deceased
responsible person, the deceased
responsible person’s legal representative
and the proposed transferee. Such
transfer may occur if the Administrator
determines that:
(i) The proposed transferee meets all
of the qualifications of a responsible
person under this part;
(ii) The proposed transferee has
provided adequate written assurances to
the Administrator that the proposed
transferee and all of his or her agents
will meet the terms and conditions of
the permit, including any outstanding
mitigation requirements or
commitments under this part, and that
the proposed transferee agrees to
assume all responsibility and liability
associated with permit activities and
responsibilities; and
(lii) The proposed transferee has
provided such other information as Iho
Administrator determines is necessary
to the processing of the request for
transfer of permit.
§ 340.3 Permit conditions.
(a] Core permit conditions. Permits
will be issued with the permit
conditions below, which are a minimum
set of basic conditions, The
Administrator may add additional or
expanded conditions w^hen necessary to
make it unlikely that actions under the
permit would result in the introduction
or dissemination of a plant pest or
noxious weed.
(1) Permit conditions for all permit
types.
(i) Identity. The identity of the GE
organism shall be maintained at all
times, in order to maintain control of
the GE organism, keep it distinct from
other organisms, and minimize
unintended mixing of Iho GE organism
with other organisms. Conditions for
maintaining the identity of the GE
organism include, but are not limited to:
IA) Marking, labeling, or otherwrise
identifying all GE organisms during the
course of the permit; and
(B) Having the ability to account for
all GE materials associated with the
permit.
(ii) Communication and training. The
responsible person shall effectively
communicate any and all conditions,
activities, actions, and contingency
plans associated with the permit to all
his or her agents and any other persons
participating in permit-related activities,
in order to ensure all persons comply
with all requirements under this part.
Conditions for communicating and
training include, but are not limited to:
(A) ^tablishing, implementing, and
maintaining the means to effectively
communicate to all his or her agents and
any other persons participating in
permit-related activities;
(B) Providing a copy of the permit and
conditions to all agents involved in a
permit; and
(C) Training all agents and any other
persons participating in permit-related
activities to effectively conduct tasks
required under the permit.
(iii) Records. In addition to any other
record.s required by this section or
§ 340.7(b), records, related to permitted
activities of sufficient quality and
completeness to demonstrate
compliance with all permit conditions
and requirements under this part, must
be maintained.
(iv) Notice. The responsible person
shall notify' APHIS orally within 24
hours of discovery, and subsequently in
writing within 5 business days of
discovery, in the event of an
unauthorized importation, interstate
movement, or release into the
environment of a GE organism regulated
under this part.
(2) Additional permit conditions for
interstate movement permits,
importation permits, and environmental
release permits which include either an
interstate movement or importation.
(i) Shipment. The GE organism must
be transported in such a way as to
minimize the likelihood of the
unauthorized release of the GE
organism. Conditions include, but are
not limited to:
(A) Ensuring that the GE organism is
transported in such a way that It is a
secure shipment, as defined in § 340.1;
and
(B) Treating or disposing of all
packaging material, shipping containers.
and any other material accompanying
the GE organism in such a manner as to
make it unlikely to result in the
organi,sm's unauthorized importation,
interstate movement, or release into the
environment.
(ii) Records. In addition to any other
records required by this section or
§ 340.7(b). the following records shall be
maintained:
(A) Information identifying the
general nature and quantity of the
organism being shipped;
(B) Name and address of sender,
owner, or person shipping the organism;
(C) Name, address, and telephone
number of recipient;
(D) Any invoices, packing lists, or
bills of lading used for the shipment;
(E) The shipper’s name and
identifynng shipper's mark and number;
and
(F) A description of any containers
that were used to transport the GE
organisms, and a copy of any label used
on these containers during transport.
(3) Additional pemiif conditions for
import permits, and environmental
release permits which include
importation.
(i) Port(s) of Entry. The GE organism
shall be presented for entry only at a
port(s) specified in the permit.
(ii) Records. In addition to any other
records required by this section or
§ 340.7(b}, the responsible person shall
maintain records that identify the
country and locality where the GE
organism was collected, developed,
manufactured, reared, cultivated or
cultured.
(4) Additional permit conditions for
enviionmenta/ release permits.
(i) Envifonmentoi release controls.
Sufficient controls shall be applied
during the environmental release of the
GE organism to make it unlikely to
result in the unauthorized release of the
GE organism into the environment.
Conditions include, but are not limited
to:
(A) Taking adequate precautions as
described in the permit to ensure that
the GE organism is not inadvertently
released in transit between contained
facilities and the location of
environmental release;
(B) Developing and being prepared to
implement a w'ritten contingency plan
to respond to any unauthorized
environmental release;
(C) Following any and all required
reproductive, cultural, spatial, and
temporal controls, such as isolation
di.stances, buffer zones, and flower
removal, as described in the permit, and
monitor to ensure that the controls are
maintained throughout the duration of
the release;
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(D) Cleaning equipment used in the
environmental release in order to
remove or devitalize any viable GE
organism the equipment may carry, as
described in the permit:
(E) Devitalizing or moving into a
contained facility any viable GE
material remaining at the termination of
the environmental release, when
applicable, as described in the permit;
and
(F) Managing and monitoring the area
of release after the termination of the
environmental release and removing or
devitalizing any GE organisms which
persist after the release, as required in
the permit.
(iij Records. In addition to any other
records required by this section or
§ 340.7(bl, the following records shall be
maintained for each release:
(A) All protocols or guidelines used to
direct any environmental release of the
GE organism: and
(B) All environmental release reports
for the organism. At a minimum such
reports must include the APHIS
reference number for the environmental
release, methods of observation used
during the environmental release,
resulting information, and analysis
regarding all deleterious effects on
plants, nontaiget organisms, or the
environment, and any notices sent to
APHIS of any unusual occurrence
during the environmental release.
(iii) Reports and Notices. In order for
the Administrator to monitor the
progress of the environmental release,
and to evaluate compliance with
required permit conditions, permit
conditions will include, but are not
limited to:
(A) The responsible person shall
submit periodic reports and notices to
APHIS at the times specified in the
permit and containing the information
specified within the permit; and
(B) The responsible person shall
notify APHIS orally within 24 hours of
discovery, and .subsequently in writing
within 5 business days of discovery, in
the event that the GE organism is found
to have characteristics substantially
different from those listed in the permit
or if any circumstances occur which
may increase the risk of disseminating
a plant pest or noxious w'eed.
(C) The responsible person shall
notify APHIS in writing if the
authorized release will not be
conducted.
(D) Within 28 days after the initiation
of the release, the responsible person
shall report to APHIS in writing the
final release site coordinates; number of
GE organisms actually released; any
information related to the expected
date(s) and quantities of GE organisms
for subsequent planned releases to be
done under this permit
(E) The responsible person shall
provide APHIS with a final report that
includes information related to any
occurrences during the release that
might result in the dissemination of a
plant pest or noxious weed.
(F) For categories C and D, permit
holders shall provide APHIS with
written notice no less than seven days
prior to the planned initiation of the
release.
(G) For categories C and D, permit
holders shall provide APHIS with a
report no less than 21 days prior to
release termination (e.g., harvest of GE
plants) that describes the anticipated
date(s) of termination.
(b) Standard for additional permit
conditions assigned by Administrator.
The Administrator will assign the
permit conditions described above in a
manner that is commensurate with the
risk of the individual proposed release.
Additional or expanded permit
conditions may include, but are not
limited to specific requirements for:
Reproductive, cultural, spatial, temporal
controls: monitoring; post-termination
land use; site security or access
restrictions; and management practices
such as training of personnel involved
in the release. The Administrator may
also assign permit conditions addressing
nonliving materials associated with or
derived from GE plants when such
conditions are needed to make it
unlikely that the nonliving materials
would pose a noxious weed risk.
§340.4 Conditional exemptions from the
requirement for a permit for interstate
movement.
(a) General. Certain GE organisms
described in paragraph (b) of this
section may be moved interstate without
a permit under this part, if they meet the
shipping conditions enumerated in
paragraph (c).
(b) Conditional exemptions from the
requirement for a permif for interstate
movement of certain organisms. A
permit for interstate movement will not
be required for the following genetically
engineered organisms provided that
they meet the requirements of this
paragraph and paragraph (c).
(1) Escherichia coli genotype K--12
(strain K-12 and its derivatives), sterile
strains of Saccharomyces cerevisiae, or
asporogenic strains of Bacillus subtilis,
provided that the introduced genetic
sequences:
(i) Are maintained on a
nonconjugation proficient plasmid, and
the organism does not contain other
conjugation proficient plasmids or
generalized transducing phages;
(ii) Do not cau.se the production of an
infectiou.s entity;
(iii) Are not carried on an expression
vector if the cloned genes code for:
(A) A toxin to plants or plant
products, or a toxin to organisms
beneficial to plants: or
(B) Other factors directly involved in
eliciting plant disease (e.g,, ceil wall
degrading enzymes: or
{Q Substances acting as, or inhibitory
to, plant growth regulators.
(2) Arahidopsis thaliana provided that
the introduced genetic sequences:
(i) Do not cause the production of an
infectious entity;
(ii) Are not derived from an animal or
human pathogen;
(iii) Do not encode products that are
toxic to vertebrates;
(iv) Do not encode products known to
or likely to be causal agents of disease
in vertebrates; and
(v) Do not encode products intended
for pharmaceutical or industrial use.
(c) Shipping conditions. Organisms
that meet the criteria described in
paragraph (b) of this section must be
shipped as follows:
(i) The container and means of
conveyance must provide secure
shipment to make it unlikely that the
introduction or dissemination, of the
organisms will occur while in transit.
(ii) The container must contain a
document which includes the following
written information:
(A) Names and contact details for the
sender and recipient, and
(B) A statement that the contents are
genetically engineered and are eligible
for interstate movement witliout permit
under this part, but are not exempt from
permit requirements under this part if
the organism is imported or released
into the environment;
(iii) The responsible person shall
notify APHIS orally within 24 hours of
discovery, and subsequently in writing
within 5 business day.s of discovery, in
the event of an unauthorized release
into the environment of a GE organism
regulated under this part.
(d) Revocation of an exemption from
reqiiirfiment for permit. The
Administrator may revoke any existing
conditional exemption. The
Administrator may revoke a conditional
exemption if the Administrator receives
information subsequent to approving
the conditional exemption and makes a
determination based upon this
information that the circumstances have
changed such that the conditional
exemption is likely to result in the
introduction or dissemination of a plant
pest or noxious 'weed. The revocation,
its effective date, and the reasons for it
w'ill be published in the Federal
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Register. A revocation may not be
appealed. However, any person may file
a new petition in accordance with
§ 340.5 regarding the same or similar
organisms covered by the revocation if
new information relevant to the
revocation becomes available.
(e) Revocation of a person’s use of a
conditional exemption from
requirement for permit. The
Administrator may revoke the right of
any person to use a conditional
exemption from the requirement for a
permit under this part after determining
that the person or any agent of the
person has failed to comply at any time
with any provision of this part. This
would include failure to comply with
the conditions of any permit or
exemption.
(1) Appeal of revocatioi} of a person’s
use of a conditional exemption. Any
person who has had the right to use a
conditional exemption revoked may
appeal the decision in writing to the
Administrator within ten days after
receiving the written notification of the
revocation. The appeal shall state all of
the fads arid reasons upon which the
person relies to assert that the use of the
conditional exemption was wrongfully
revoked. The Administrator will grant
or deny the appeal, in writing, staling
the reasons for the decision as promptly
as circumstances allow. Upon request of
the applicant, a hearing may be held to
resolve any conflict as to any material
fact. Rules of practice concerning such
a hearing will bo adopted by the
Administrator. This administrative
remedy must be exhausted before a
person can file suit in court challenging
the revocation.
§ 340.5 Petition for new conditional
exemptions from the requirement for a
permit.
(a) Genemi Any person may petition
to Initiate the procedure for o.stablishing
a new conditional exemption from the
requirement for a permit under
§ 340.0(b)(1) of this part. The
Administrator may initiate the
procedure without filing a petition. All
petitioms and all actions by the
Administrator to establish a new
conditional exemption will be evaluated
according to the standards for petition
approval or denial contained in
paragraph (b)(4) of this section.
(b) Petition submission and
evaluation procedure. To petilion for a
new conditional exemption from the
requirement for a permit under this part,
a petitioner must submit a written
petition to the Administrator.
(1) The petition must contain
information that supports a conclusion
lhat use of the conditional exemption is
unlikely to result in the introduction or
dissemination of a plant pest or noxious
weed. The information shall include the
following:
(i) Description of the biology of the
organism prior to generic engineering.
(ii) Detailed description of the genetic
changes made to the organism.
(iii) Detailed description of the
phenotype of the GE organism,
including known and potential
differences from the r«:ipient organism
that could change the likelihood lhat the
GE organism will pose a risk as a plant
post or noxious weed. Examples of
relevant information include, but are
not limited to:
(A) Growth habit and reproduction of
the GE organism;
(B) Potential host range or geographic
area of distribution;
(C) Potential for other oiganisms to
pose risks as plant pests or noxious
weeds if they acquire the trait from the
GE organism (e.g. via sexual
reproduction, horizontal gene transfer);
(D) Susceptibility of the GE organism
to disease or damage by pests;
(E) Pathr^enicity of the GE organism
and/or ability of the GE organism to
cause damage or injury to plants or
plant parts:
(F) Toxicity, allergenicity, and/or
ability of the GE organism to damage or
injure other organisms:
(iv) A detailed description of
proposed condition(s) to be associated
with the exemption and how the
conditions wmuld make the exemption
unlikely to result in the introduction or
dissemination of a plant pest or noxious
weed.
(v) Any relevant experimental
information, published references, or
scientific information which support the
conclusions of the petition;
(vi) All reports required under
§340.3;
(vi) Any information known to the
petitioner that the GE organism may
pose a risk as a plant pest or noxious
weed;
(vii) Any other information that the
Administrator believes to be relevant to
a determination that the proposed
conditional exemption from the
requirement for a permit for the
importation, interstate movement, or
release into the environment of the GE
organism is unlikely to result in the
introduction or dissemination of a plant
pest or noxious weed.
{viii) A signed certification by the
petitioner lhat, to the best knowledge
and belief of the petitioner, the petition
includes all information on which to
base a determination, and that it
includes all information known to the
petitioner which is unfavorable to the
petition.
(2) Insufficient information. If, upon
initial review' of the petition, the
Administrator concludes that there is
insufficient information upon which to
make a determination on the petition,
the petitioner will bo sent a written
notice indicating what additional
information may be required.
(3) Public notice. The Administrator
should generally complete the review of
the complete petition within 180 days,
then publish a notice in the Federal
Register of the availability of documents
related to APHIS' assessment of the
proposed conditional exemption. This
notice will specify that comments will
be accepted from the public on the
proposal.
(4) Petition approval or denial
standard. The Administrator will assess
the GE organism and the conditions of
the requested exemption to determine
w'hetherthe requested exemption from
a permit for importation, interstate
movement, or release into the
environment would be unlikely to result
in the introduction or dissemination of
a plant pest or noxious weed. The
Administrator will also consider
whether any conditions not contained
in the petition would be needed to
ensure that the requested exemption
would be unlikely to result in the
introduction or dissemination of a plant
pest or noxious weed. After completing
review of the available information and
any public comments received on it, the
Administrator will furnish to the
petitioner and publish in the Federal
Register one of the following responses;
(0 Approve a condiiional exemption
from requirement for a permit. The
approval of a conditional exemption
from the requirement for a permit will
state which GE organisrafs) may be
imported, moved interstate, and/or
environmentally relea,sed without a
permit under this part, as well as the
conditions relevant to the exemption.
The Administrator may also add
additional conditions not proposed in
the petition, if the Administrator
concludes that additional conditions are
needed to ensure lhat the conditional
exemption w'ould be unlikely to result
in the introduction or dissemination of
a plant post or noxious weed.
(ii) Deny a conditional exemption
from requirement fora permit. The
Administrator will deny a petition if the
Administrator cannot conclude that the
proposed exemption would be unlikely
to result in the introduction or
dissemination of a plant pest or noxious
weed. The Administrator's written
decision will set forth the reason for the
denial.
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(c) Appeal of decision. Any person
whose petition under § v340.5 has been
denied may appeal the decision in
writing to the Administrator within ton
days after receiving the written
notification of the decision. The appeal
shall state all of the facts and reasons
upon which the person relies to show
that the decision should be changed.
The Administrator will grant or deny
the appeal, in writing, stating the
reasons for the decision as promptly as
circumstances allow. Upon request of
the applicant, a hearing may be held to
resolve any conflict as to any material
fact. Rules of practice concerning such
a hearing will be adopted by the
Administrator. This administrative
remedy must be exhausted before a
person can file suit in court challenging
the decision.
(d) Amending an exemption after
approval. The Administrator may
amend conditions to any conditional
exemption approved under this -section.
The Administrator may amend a
conditional exemption if the
Administrator determines based on
information received subsequent to the
approval of the exemption that the
exemption needs to be amended to
ensure that the exemption would be
unlikely to result in the introduction or
dissemination of a plant pest or noxious
weed, and that additional conditions
can successfully mitigate that risk, The
Administrator may also amend a
conditional exemption if needed to
ensure that the exemption is in
compliance with all of the requirements
of this part. The amended conditional
exemption and the reasons for it will be
published in the Federal Register, The
addition of conditions may not be
appealed, However, any person may file
a new petition in accordance with
paragraph (a) of this section regarding
the same or similar organisms covered
by the amended exemption if new
information relevant to the amended
exemption becomes available.
(e) revocation of an exemption from
requirement for permit. The
Administrator may revoke any
conditional exemption under this
section. The Administrator may revoke
a conditional exemption if the
Administrator receives information
subsequent to approving the exemption
and makes a determination based upon
this information that the circumstances
have changed such that the conditional
exemption is likely to result in the
introduction or dissemination of a plant
pest or noxious weed. The revocation,
its effective date, and the reasoms for it
will be published in the Federal
Register. A revocation may not be
appealed. However, any person may file
a new petition in accordance with this
section regarding the same or similar
organisms covered by the revocation If
new information relevant to the
revocation becomes available.
(f) Revocation of a person's use of a
conditional exemption from
wquirement for permit. The
Administrator may revoke the right of
any person to use a conditional
exemption from the requirement for a
permit under this part after determining
that the person or any agent of the
person has failed to comply at any time
with any provision of this part. This
would include failure to comply with
the conditions of any permit or
exemption.
(!) Appeal of revocation of a person's
use of a conditional exemption. Any
person who has had the right to use a
conditional exemption revoked may
appeal the decision in writing to the
Administrator within ten days after
receiving the written notification of the
revocation. The appeal shall slate all of
the facts and reasons upon which the
person relies to assert that the use of the
exemption was wrongfully revoked. The
Administrator will grant or deny the
appeal, in writing, stating the reasons
for the decision as promptly as
circumstances allow. Upon request of
the applicant, a hearing may be held to
resolve any conflict as to any material
fact. Rules of practice concerning such
a hearing will be adopted by the
Administrator. This administrative
remedy must be exhausted before a
person can file suit in court challenging
the revocation.
(2) (Reserved)
§ 340.6 Petition for nonregutated status.
(a) Genera/. Any person may petition
to initiate the procedure for approving
nonregulated status \inder this pari for
a GE organism. The Administrator may
initiate the procedure without filing a
petition. All petitions and all actions by
the Administrator to initiate the
procedure for approving nonregulated
status will be evaluated according to the
standards for petition approval or denial
contained in paragraph (b)(4) of this
section.
(b) Petition submission and
evaluation procedure. To petition for
approval of nonregulated status, a
petitioner must submit a written
petition to the Administrator.
(1) The petition must contain
information tliat supports a conclusion
that the GE organism is unlikely to be
a plant pest or noxious weed. The
information shall include the following;
(i) Description of the biology of the
organism prior to genetic engineering.
(ii) Detailed descripliun of the genetic
changes made to the organism.
(iii) Detailed description of the
phenotype of the GE organism,
including known and potential
differences from the recipient organism
that could change the likelihood that the
GE organism is unlikely to be a plant
pest or noxious weed. Examples of
relevant information include, but are
not limited to;
(A) Growth habit and reproduction of
the GE organism:
(B) Potential host range or geographic
area of distribution:
(C) Potential for other organisms to
pose risks as plant pests or noxious
\veeds if they acquire the trait from the
GE organism (e.g. via sexual
reproduction, horizontal gene transfer):
(D) Susceptibility of the GE organism
to disease or damage by pests:
(E) Pathogenicity of the GE organism
and/or ability of the GE organism to
cause damage or injury to plants or
plant parts;
(F) Toxicity, allergenicity, and/or
ability of the GE organi,sm to damage or
injure other organisms;
(iv) Any relevant experimental
information, published references, or
.scientific information which support the
conclusions of the petition;
(v) All reports required under § 340.3;
(vi) Any information known to the
petitioner that the GE organism may
pose risk as a plant pest or noxious
weed;
(vii) Any other information that the
Administrator believes to be relevant to
a determination that the GE organism is
unlikely to be a plant pest or noxious
weed.
(viii) A signed certification by the
petitioner that, to the best knowledge
and belief of the petitioner, the petition
includes all information on which to
base a determination, and that it
includes all information known to the
petitioner which is unfavorable to the
petition.
( 2 ) Insufficient information. If. upon
initial review of the petition, the
Administrator concludes that there is
insufficient information upon which to
make a determination on tnc petition,
the petitioner will be sent a written
notice indicating what additional
information may be required,
(3) Public notice. The Administrator
should generally complete the review of
the complete petition within 180 days,
then publish a notice in the Federal
Register of the availability of documents
related to APHIS' assessment of the
proposal for nonregulated status. This
notice will specify that comments will
be accepted from the public on the
proposal.
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(4) Petition approval or denial
standard. The Administrator will assess
the GE organism to determine whether
the GE organism is unlikely to be a plant
pest or noxious weed. After completing
review of the available information and
any public comments received on it, the
Administrator will furnish to the
petitioner and publish in the Federal
Register one of the following responses;
01 Approve nonregulated status. The
approval of nonregulated status will
state which GE organism{s) have been
determined to have nonregulated status.
(ii) Deny nonregulated status. The
Administrator will deny a petition if the
Administrator cannot conclude that the
GE organism is unlikely to be a plant
pest or noxious weed. The
Administrator’s written decision will set
forth the reason for the denial.
(c) Appeal of decision. Any person
whose petition under § 340.6 has been
denied may appeal the decision in
writing to the Adrainisti'ator within ten
days after receiving the written
notification of the decision. The appeal
shall state all of the facts and reasons
upon which the person relies to show
that the decision should be changed.
The Administrator will grant or deny
the appeal, in writing, stating the
reasons for the decision as promptly as
circumstances allow. Upon request of
the applicant, a hearing may be held to
resolve any conflict as to any material
fact. Rules of practice concerning such
a hearing will be adopted by the
Administrator. This administrative
remedy must be exhausted before a
person can file suit in court challenging
the decision.
(dj jRevocah'on of nonregulated status.
The Administrator may revoke any
approval of nonregulated status of a GE
organism. The Administrator may
revoke an approval of nonregulated
status if the Administrator receives
information subsequent to approving
the nonregulated status and makes a
determination based upon this
information that the circumstance.s have
changed such that the GE organism is
likely to be a plant pest or noxious
weed. If the Administrator revokes an
approval for nonregulated status, the
Administrator may approve for the same
GE organism an exemption from the
requirement for permit in accordance
with §340.5. The revocation, its
effective date, and the reasons for it will
be published in the Federal Register. A
revocation may not be appealed.
However, any person may file a new
petition in accordance with this section
regarding the same or similar organisms
covered by the revocation if new
information relevant to the revocation
becomes available.
§ 340.7 Compliance, enfcHvement, and
remedial action.
(a) Access for inspection. Inspectors
shall have access to inspect any relevant
premises, facility, location, storage area,
waypoint, materials, equipment, means
of conveyance, and other articles related
to importation, interstate movement,
and environmental releases of GE
organisms regulated under this part,
(b) Access to audit and review
records. Inspectors shall have access to
audit and review all records required to
be maintained under this part.
(c) Required records. Responsible
persons and their agents engaged in the
importation, interstate movement, or
release into the environment of a GE
organism subject to the regulations of
this part are required to establish and
keep the following records.
(1) All records required as a condition
of a permit or a conditional exemption
approved under the procedure
described in § 340.5.
(2) Address and any other information
needed to identify all contained
facilities where the GE organism was
stored or utilized, and all locations
where the GE organism was released
into the environment;
(3j A record identifying which APHIS
permit, if any, authorized the
importation, interstate movement, or
release into the environment;
(4) A record Identifying which
exemption under this part, if any,
authorized the importation, interstate
movement, or release into tlie
environment; and
(5) Copies of contracts between the
responsible person and all agents that
conduct activities subject to this part for
the responsible person, and copies of
other records (e.g.. e-mails, telephone
records) for such agreements made
without a written contract.
(d) Record retention. Records
indicating that such a GE oiganism that
was imported or moved interstate
reached its intended destination must
be retained for at least 2 years after
completion of importation or interstate
movement, and all other records must
be retained for at least 5 years after
completion of all obligations required
under a relevant permit or exemption.
(e) Enforcement. (1) Failure of any
person to comply with any of the
requirements of this part may result in
any or all of the following:
(i) Denial of a permit request by that
person;
(ii) After the issuance of a permit,
revocation of a permit and destruction,
treatment, or removal of the GE
organism, or other measures as deemed
appropriate or necessary by the
Administrator;
(iii) Criminal and/or civil penalties,
and
(iv) Remedial or other measures as
determined appropriate and necessary
by the Administrator.
(2) The Administrator may seek a civil
penalty as well as impose and require
corrective action plans, remedial
measures or other measures as
determined appropriate and necessary
by the Administrator.
(3) Prior to the issuance of a
complaint seeking a civil penalty, the
Administrator may enter into a
stipulation in which the responsible
person agrees to lake certain remedial
actions or other measures in addition to
or in lieu of a stipulated civil penalty,
in accordance with 7 CFR § 380.10.
(f) Liability for acts of an agent. For
purposes of enforcing this part, the act,
omission, or failure of any agent for a
responsible person as defined in §340.1
of this part may be deemed also to be
the act, omission, or failure of the
responsible person.
(g) Remectial action. The
Administrator may hold, seize,
quarantine, treat, apply other remedial
measure.s to, destroy, or otherwise
dispose of any GE organisms subject to
this pari, in order to ensure the GE
organisms are unlikely to result in the
dissemination of a plant pest or noxious
weed. Accordingly, the Administrator
may order the responsible person for an
active or revoked permit or any other
person, through an Emergency Action
Notification or other administrative
order, to apply remedial measures to a
GE organism or means of conveyance
carrying a GE organism subject to
regulation by this part. The
Administrator’s determination of
whether or not to require or order
corrective and/or remedial action in a
given situation does not affect,
influence, restrict, or in any other way
limit the Administrator’s determination
on whether or not to seek criminal or
civil penaltie.? or order other
compliance or enforcement
requirements as deemed necessary or
appropriate by the Administrator to the
given situation.
(1) Faihirc of a person to comply with
the Administrator’s order for corrective
and/or remedial action authorizes the
Administrator to take corrective and/or
remedial action and recover fi'om the
person the costs of any care, handling,
application of remedial measures,
devitalization, or disposal incurred by
APHIS in connection with the corrective
and/or remedial actions taken.
(2) Low level presence (LLP) remedial
action. The Administrator may order
remedial action for any unauthorized
release into the environment of GE
812
60048 Federal Register/ Vol. 73, No. 197/Thursday, October 9,
organisms, including situations
involving a low-level mixing of GE
plants and materials subject to
regulation ’ under this part with
commercial seed and grain. In some LLP
situations the Administrator may
determine not to order remedial action,
if the Administrator determines that the
low-level mixing is unlikely to result in
the introduction or dissemination of a
plant pest or noxious weed, These
determinations \viii be made in the
same way, based on the same factors,
regardless of rvhethor the LLP originates
domestically or is found in import
shipments that may contain organisms
subject to regulation. The factors the
Administrator will consider that would
support a decision not to order LLP
remedial action include, but are not
limited to, determinations that:
{ij A GE plant of the same species
expressing nearly identical proteins or
substances has already been approved
for nonregulated status under this part;
or
(ii) All of the following statements are
tn,ie with regard to the GE plant or
plants subject to the regulations under
this part.
(A) The function of the introduced
genetic sequences is known and its
expression in the GE plant is unlikely to
pose plant pest or noxioiis weed risk;
(B) Produced genetic sequences do
not cause the production of an
infectious entity;
{Cj Any genetic sequences derived
from plant viruses are non-coding
regulatory sequences of known function;
* "Subject to regulation" may include situations
whore a GH organism granted iioiireguiated status
.subsequently had (hat .status mvoked in ac:c'ordance
with $ S4.0.a(d).
or. if sense or antisense genetic
sequences, they are derived from viruses
prevalent and endemic in the United
States that infect plants of the same host
species and do not encode a functional
noncapsid gene product responsible for
ceil-to-cell movement of the virus.
(D) The GE plant is not expected to
establish outside of a managed
ecosystem, and has no sexually-
compatible. wild relatives in the United
States;
(E) The GE plant does not produce
new substances that are known or likely
to be toxic to non-target organisms, does
not contain genetic swjuences from
animal or human pathogens, and does
not encode products known or likely to
be causal agents of disease in animals or
humans.
(F) If the GE plant is a food or feed
crop, then at least one of the following
must be true;
(J) The U.S. Environmental Protection
Agency has established a tolerance or an
exemption from tolerance for any plant-
incorporated protectant expressed by
tlie GE plant, or
[2] Key food safety issues of the new
protein or other substance have been
addressed, or,
(5) No new protein or substance is
produced.
§ 340.8 Confidential business information.
In accordance with the Freedom of
Information Act (FOIAj and exemptions
from releasing information pursuant to
FOIA, namely. 5 U.S.C. 552(b)(4).
APHIS may exempt from disclosure to
the public trade secrets and commercial
or financial information obtained from a
person that arc privileged or
confidential. Persons wishing to protect
confidential business information in
2008/Proposed Rules
permit applications, petitions, or other
submissions to APHLS under this part
should do so in the following manner.
If there are portions of a document
deemed to contain trade secret or
confidential business information, each
page containing such information must
be marked “CBI Copy." A second copy
of each such document must bo
submitted with all such CBI deleted and
marked on each page where the CBI was
deleted; "CBI Deleted.” In addition,
those portions of the document which
are deemed "CBI” must be identified in
an attachment to the document, which
also must justify how each piece of
information requested to be treated as
CBI is a trade secret or is commercial or
financial information and are privileged
or confidential.
§ 340.9 Costs and charges.
The services of the inspector related
to carrying out this part and provided
during regularly assigned hours of duty
and at the usual places of duty will be
furnished without cost.^ The U.S.
Department of Agriculture will not bo
respomsible for any costs or charges
incident to inspections or compliance
with the provisions of this part, other
than for the services of the inspector.
Dons in Washington, DC, this Ist day of
October 2008,
Charles D. Lambert,
Acting Under Secretaiy for Marketing and
EeguJatory Programs,
(FR Doc, E8-23584 Filed 10-6-08: 9:30 am]
BILUNQ CODE 3410-34-P
^ The Department's provisions relating to
overtime charges for an In.spectnr’s 8orvico.s are set
forth in 7 CFR part 354.0.
813
26832 Federal Register/ Vol. 74, No. l(W/Thureday, June 4, 2009/Notices
Regulatory Analysis and Development,
PPD, APHIS, Station 3A~03.8, 4700
River Road Unit 118, Riverdaie, MD
20737-1238. Please state that your
comment refers to Docket No. APHIS-
2008-0098.
Reading Room: You may read any
comments that we receive on this
docket in our reading room. The reading
room is located in room 1141 of the
USDA South Building, 14th Street and
Independence Avenue SW.,
Washington, DC. Normal reading room
hours are 8 a.m. to 4:30 p.m., Monday
through Friday, except holidays. To be
sure someone is there to help you,
please cal! (202) 690-2817 before
coming.
Other Information: Additional
information about APHIS and its
programs is available on the Internet at
bttp://www.aphis.usda.gov.
FOR FURTHER INFORMATION CONTACT: Dr.
Edward Jhee, Biotechnology Quality
Management System Program Manager,
Biotechnology Regulatory Services.
APHIS, 4700 River Road Unit 91,
Riverdaie, MD 20737-1236; (301) 734-
8356, edward.m.jbee®aphisMsda.gov. '
To obtain copies of the draft audit
standard, contact Ms. Cindy Eck at (301)
734-0667, e-mail:
cyntbia.a.eck®apbis.usda.gov. The draft
audit standard is also available on the
Internet at http://www.aphis.usdQ.gov/
biotochno}ogy/nBws__bqms.sbtml.
SUPPLEMENTARY INFORMATION:
Background
The U.S. Department of Agriculture’s
(USDA) Animal and Plant Health
Inspection Service (APHIS) regulates the
introduction — meaning the importation,
interstate movement, and environmental
release — of genetically engineered (GE)
organisms that are, or may be, plant
pests. Such GE organisms and products
are considered "regulated articles.”
Applicants that are issued permits or
received acknowledgment of
notifications to introduce GE organi-sms
are required to comply with all APHIS
regulations,
To enhance improvements in
compliance, APHIS initiated
development of a voluntary, audit-based
compliance assistance program known
as the Biotechnology Quality
Management System (BQMS). On
September 20, 2007, APHIS issued a
press release announcing plans to
establish a BQMS Pilot Development
Project,
APHIS selected five volunteer
participants for the pilot program after
soliciting letters of interest through a
notice published in the Federal Register
on September 2. 2008 (73 FR 51266-
51267, Docket No. APHIS-200&-0098).
The main component of the BQMS pilot
project is the draft audit standard,
which provides criteria used for the
objective evaluation of quality
management s^tems to determine if a
system will be certified as an APHIS
Biotechnology Quality Management
System durii^ the audit portion of the
pilot program. The regulatory
requirements of 7 CFR part 340 for
performance standards and permit
conditions are the foundation for the
draft audit standard.
The draft audit standard is used by
pilot participants to develop sound
management practices to enhance
compliance with the regulatory
requirements of 7 CFR part 340 for
environmental releases, importations,
and interstate movements of regulated
articles. Participants have applied the
draft audit standard to their
organization’s regulated biotechnology
program to plan, implement, document,
and examine the efficacy of quality
assurance and quality control measures
related to introductions of regulated
articles.
APHIS is soliciting comments for a
period of 60 days on the draft audit
standard currently used in the BQMS
pilot project. Within the draft audit
standard, Requirement 7 specifies that
participants address critical control
points for the introduction of regulated
articles by developing containment
procedures for regulated articles:
developing measures for the
identification of regulated articles in
storage, being moved, imported, or
transferred, and in Held locations;
developing procedures for planning and
monitoring environmental releases of
regulated articles; developing methods
for post-harvest handling activities and
methods to maintain the identity of
regulated material: developing
procedures for the devitalization and
disposition of regulated articlos; as well
as developing procedures for the
submission of regulatory compliance
incidents to the appropriate regulatory
authorities. APHIS is soliciting
comments on the draft audit standard as
a whole, and Requirement 7 In
particular.
1 . Do the critical control points in
Requirement 7 of the draft audit
standard identify all areas and elements
that organizations should focus on in
order to maintain compliance with the
regulatory requirements under 7 CFR
part 340?
2. Is the draft audit standard
consistent with current best practices
used by the regulated community?
3. Can the public identify incentives
USDA might employ to encourage
participation in the voluntary program
by commercial industry as well as
academic institutions?
4. The BQMS is designed to be
flexible according to the size of the
participating organization. Is this
flexibility apparent in the draft audit
standard?
Upon conclusion of the BQMS pilot
project, APHIS will consider all
comments received during the comment
period to revise the draft audit standard
to improve the efficacy of this project.
This feedback, as well as comments
from the participants on the pilot BQMS
project, will be used to inform the
development of a BQMS audit standard
and any future BQMS initiative. The
BQMS draft audit standard is available
for public review as indicated under the
ACH^ESSES and FOR FURTHER
INFORMATION CONTACT sections of this
notice.
Done in Washington. DC, thi.? 29th day of
May 2009.
Kevin Shea,
Acting Administrator, Animal and Plant
Health Inspection Service.
[FR Doc. E9-13053 Filed 6-3-09; 8:45 am]
BtULINC CODE 3410-34-P
DEPARTMENT OF AGRICULTURE
Animat and Plant Health Inspection
Service
[Docket No. APHiS-2007-0016J
Syngenta Seeds, Inc.; Availability of
Petition and Environmental
Assessment for Determination of
Nonreguiated Status for Corn
Genetically Engineered To Produce an
Enzyme That Facilitates Ethanol
Production
AGENCY: Animal and Plant Health
Inspection Service, USDA.
ACTION: Notice; reopening of comment
period.
SUMMARY: Wo are reopening the
comment period for a petition submitted
by Syngenta Seeds, Inc., seeking a
determination of nonreguiated status for
corn designated as transformation event
3272 and its associated environmental
assessment prepared by the Animal and
Plant Health Inspection Service under
our regulations found at 7 CFR part 340.
This action will allow intere.stcd
persons additional time to prepare and
submit comments on the petition,
environmental assessment, and the
revised plant pest risk assessment.
DATES: We will consider all comments
that we receive on or before July 6,
2009.
814
Federal Regisler/Vol. 74, No. 106 /Thursday, June
ADDRESSES: You may submit comments
by either of the following methods:
• Federal eRulemaking Porta!: Go to
http://wxvw.regulations.gov/fdmspubUc/
component/
main?main=DocketDetai!S-d=APHIS-
2007-0016 to submit or view comments
and to view supporting and related
materials available electronically.
• Postal Mail/Commercial Delivery:
Please send two copies of your comment
to Docket No. APHIS-2007-0016,
Regulatory Analysis and Development,
PPD, APHIS. Station 3A03.8. 4700 River
Road Unit 118, Riverdaie, MD 20737-
1238, Please state that your comment
refers to Docket No. APHIS-2007-0016.
Reading Room: You may read any
comments that we receive on this
docket in our reading room. The reading
room is located in room 1 141 of the
USDA South Building, 14th Street and
Independence Avenue SW.,
Washington, DC. Normal reading room
hours are 8 a.m. to 4:30 p.m,, Monday
through Friday, except holidays. To be
sure someone is there to help you,
please call (202) 690-2817 before
coming.
Other Information: Additional
information about APHIS and its
programs is available on the Internet at
nttp’J/www.aphis.usda.gov.
FOR FURTHER INTORMATION CONTACT: Dr.
Andrea Huberly, Biotechnology
Regulatory Services, APHIS, 4700 River
Road Unit 146, Riverdaie, MD 20737-
1236; (301) 734-0485, e-mail:
andrea.f.huberty^aphis.usda.gov. To
obtain copies of the petition, the draft
environmental assessment, or the plant
pest risk assessment, contact Ms. Cindy
Eck at (301) 734-0667, e-mail:
cynthia.a.eck@apbisMsda.gov. The
petition, draft environmental
assessment, and plant pest risk
assessment are also available on the
Internet at bttp://www.aphis.usda.gov/
brs/aphisdocs/05_28001p.pdf. http://
www.apbis.iisda.gov/hrs/apbisdocs/
05_26001p_oa.pdf, and http://
wwrw.aphis. usaa.gov/brs/aphisdocs/
05_28001p_ra.pdf.
SUPPLEMENTARY INFORMATtCM^: The
regulalion.s in 7 CFR part 340,
“Introduction of Organisms and
Products Altered or Produced Through
Genetic Engineering Which Are Plant
Pests or Which There Is Reason to
Believe Are Plant Pests,” regulate,
among other things, the introduction
(importation, interstate movement, or
release into the environment) of
organisms and products altered or
produced through genetic engineering
that are plant pests or that there Is
reason to believe may be plant pests.
Such genetically engineered (GE)
organisms and products are considered
“regulated articles.”
On October 7, 2005, APHIS received
a petition seekii^ a detennination of
nonregulated status (APHIS Petition No.
05-280-01p) from Syngenta Seeds, Inc.,
of Research Triangle Park, NC
(Syngenta), for com [Zea mays L.)
designated as tiansfbrmation event
3272, which has been genetically
engineered to produce a microbial
enzyme that facilitates ethanol
production. The p^ition stated that
Event 3272 com is unlikely to pose a
plant pest risk and, therefore, should
not be a regulated article under APHIS’
regulations in 7 CFR part 340,
In a notice^ published in the Federal
Register on November 19, 2008 (73 FR
69602-69604, Docket No. APHIS-2007-
0016), APHIS announced the
availability of the Syngenta petition and
a draft environmental assessment (EA)
for public comment. APHIS solicited
comments on the petition, whether the
subject corn is likely to pose a plant pest
risk, and on the draft EA. APHIS
received over 13,000 comments on the
petition, the draft EA, and the plant pest
risk assessment by the close of the 60-
day comment period, which ended on
January 20, 2009.
There were 40 comments ftom
organizations or individuals that
supported the deregulation of the Event
3272 com, Over 13,000 comments
opposed to the deregulation were
submitted. The vast majority of the
approximately 13,000 comments
opposing the deregulation were from
letters conveying essentially identical
points compiled by organizations
generally opposed to any genetic
engineering of plants. Several
individuals and organizations also
submitted documents, many popular
press articles or documents published
by those opposed to genetic engineering
of plants in general, which they assert
are relevant to this regulatory decision
for Event 3272 corn.
Most of the comments supporting
nonregulated status for Event 3272 corn
came from organizations representing
corn farmers and ethanol production
interests. These comments include state-
wide com growers’ and agribusiness
associations from at least 12 different
States where most of the nation’s corn
is grown. Several national organizations
also voiced their support for the
deregulation. The principal reasons
given by these groups are the benefits
anticipated for farmers and the ethanol
‘ To view the notice, petition, draft E.A, the plant
pest ri.sk assessment and the comments we
received, go to hUpy/wmv.regulatioas.^)v/
/rfm.spuJ)/ic/coinponenf/
main?main=!> 3 cixtDetaiIS^=APHIS- 2007 - 00 t 6 .
2009 /Notices 26833
production industry, as well as the
ability to meet biofuel production
mandates and to promote international
trading interests. While APHIS does not
determine nonregulated status for GE
oiganisms pursuant to its biotech
regulations (Part 340) based on
economic or marketing factors, the
support from farmers of corn does
suggest that individuals with a
substantial interest in the health of the
national corn crop do not perceive that
cither plant pest risks or economic/
marketing risks will arise if Event 3272
corn is granted nonregulated status.
Several of the comments provided
scientific support for the deregulation of
Event 3272 corn. Many of these
supportive statements were based on
scientific studies included in the
petition (such as evidence of decreased
water use in ethanol production,
reduced greenhouse gas emissions,
other reduced inputs in ethanol
production). There were several
comments that also provided additional
studies that would support deregulation
of Event 3272 corn on the basis of
diminished environmental impacts
compared to current ethanol production
practices. These studies supported the
findings of lowered greenhouse gas
emissions and reduced inputs, and also
suggest that there will bo no impacts on
wet distilled grains and improved dried
distilled grains, and that the Event 3272
corn is equivalent to currently grown
corn lines in other agronomic and
nutritional qualities, demonstrated
through field and feed studies.
Many of the comments that opposed
deregulation were based on general
opposition to the development and use
of GE plants, without citing or
addressing any specific environmental
issues in the EA or the pest risk
assessment for the petition for Event
3272 corn. Many of these comments
simply assert that APHIS should
prepare an Environmental Impact
Statement to fully address all the
potential issues associated with a
decision to grant nonregulated status to
Event 3272 corn without specifically
explaining what they perceive to be the
inadequacies of the draft EA’s
environmental analysis. There were
many general comments expressing
generic, nonspecific concerns over
possible gene flow, disruption to
organic farming practices, and concerns
of food and environmental safety.
Another common comment that
APHIS received regarding the
determination of nonregulated status for
Event 3272 corn is the general “energy”
concern related to the effectiveness and
value of producing ethanol from corn.
Many comments suggc.sted that
815
Federal Register / Vol. 74, No. 106 /Thursday, June 4, 2009/Notices
26834
producing ethanol from corn is not an
efficient, method for achieving energy
needs or meeting any alternative energy
mandates for the United States.
However, in determining the
nonregulated status for a genetically
engineered plant pursuant to its Part
340 biotechnology regulations. APHIS
does not have authority to consider the
economic, marketing, or commercial
usefulness of the plant, or issues such
as the feasibility of meeting energy
needs through any particular crop and
its related han^esting and processing
aspects.
APHIS did receive some comments
that raised specific Issues of concern if
Event 3272 corn was granted
nonregulated status. These issues
included specific food safety concerns
such as the potential for Event 3272
corn to be allergenic, as well as
concerns surrounding the potential
economic and manufacturing issues if
Event 3272 corn were to become present
in corn wet-milling processes.
APHIS does believe it is appropriate
to address in this notice certain
comments submitted that questioned
the conclusion that Event 3272 corn is
not a plant pest, and that there is no
basis for regulatory control of this GE
plant under our statutory authorities
and Part 340 biotechnology regulations.
These comments argue that the alpha-
amylase enzyme engineered into Event
3272 corn may cause damage
(degradation of corn starch products) to
manufactured or processed plant
products ifEvent 3272 corn is included
in the manufacturing and processing of
corn starch products. The comments
claim that this type of damage comes
within the definition of a plant pest.
One of these comments ^ claims that "a
plant pest consists of any living stage of
an article similar to or allied with a
bacterium or any article similar to or
allied with a bacterium that can cause
direct damage to a processed plant
product. The 'article’ in this application
[petition] is the thermo-stable alpha-
amylase enzyme expressed in Event
3272, which ha.s the potential for injury
to plant products if misdirected to corn
wet milling facilities.
APHIS' statutory authority to regulate
genetically engineered organisms under
the Plant Protection Act (PPA) [7 U.S.C.
7701 et seq.) and its Part 340
biotechnology regulations is limited to
those GE organisms that are plant pests
as defined in Section 403, Subsection 14
of the PPA;
2 Sna hltp://ivww.rH$iilations.gav/fdmspublic/
component/
main?mai!}=DacumentDntailS-d-APHIS-2007-
00}6-0t75.1.
Plant Pest — term “plant pest” means
any living stage of any of the foUowii^ that
can directly or indirectly injure, cause
damage to, or cause disease in any plant or
plant product;
(A) A protozoan.
(Bl A nonhuman animal.
(C| A pamsitic plant.
(D) A Iracteritim.
[E) A fringus.
(FJ A virus or viroid.
(G) An infectious agent or other pathogen.
(H) Any article similar to or allied with any
of the articles speuifred in the preceding
subparagraphs.
Thus, in regulating GE organisms
under 7 CFR part 340, APHIS takes a
“safeguarding” approach and examines
the plant pest risk for genetically
engineered plants by looking at all
regulated genetically engineered plants
for iheir potential to be plant pests (See
plant pesl risk assessment, pg. 1).
However, under its PPA statutory
authorities APHIS cannot regulate GE
plants that are outside the PPA’s plant
pesl definition in 7 U.S.C. 7702(14).
This statutory definition provides
specifically that only a parasitic plant
can be a plant pest.
One of the central purposes of the
PPA is to prevent the introduction into
or dissemination of plant pests within
the United Slates. The PPA at 7 U.S.C.
7702(14) provides that a plant pesl must
be a living stage of one of a specific list
of organisms (“articles”) that cause
injury, damage, or disease in plants or
plant products, or an article similar to
or allied with such an organism (article).
An "article” is defined in the PPA (7
U.S.C. 7702(1) as follows:
Article — The term ‘article’ means any
material or tangible object that could harbor
plant pests or noxious weed.s.
As mentioned above, there were some
comments that questioned the
conclusion that Event 3272 corn is not
a plant pest. These comments argue that
the alpha-amylase enzyme in Event
3272 com is a plant pesl because it may
interfere with corn starch processing
and thus directly or indirectly damage
plants or plant products. The developer
of Event 3272 com submitted a
document after the close of the
document ^ period that argues that
Event 3272 com does not meet the PPA
statutory definition of a plant pest. In
this document, the commenter provided
its analysis of APHIS’ regulatory
authority under the PPA. and among
other things, suggests that separate
constituent parts of an organism (in this
case, an enzyme expressed by Event
’ See hUp://wivi«.regaIations.gov/fdmspabIic/
component/
main?main=DocunwntDelai}6^APHIS-2007-
00t6~0222.1.
3272 corn) are excluded from the
definition of plant pest in the PPA
because the enzyme “cannot be
regarded as ‘living’.”
APHIS agrees that enzymes such as
alpha-amylase are proteins that catalyze
chemical reactions. Enzymes are not
“living.” Thus, enzymes cannot be plant
pests because they are not living and
cannot be a “living stage” of any of the
organisms (“articles”) listed in the
PPA’s definition of a plant pest in
subparagraphs (A) through (G) of 7
U.S.C. 7702(14). Likewise, the Event
3272 corn alpha-amylase enzyme also
cannot be a living stage of any article
similar to or allied with any of the
articles specified in subparagraphs (A)
through (G), and thus does not fall
within the statutory definition of a plant
pest as listed in subparagraph (H) of the
PPA’s plant pest definition (i.e., “Any
article similar to or allied with any of
the articles specified in the preceding
subparagraphs”). APHIS has determined
that the alpha-amylase enzyme
engineered into Event 3272 com is not
a plant pest because the alpha-amyiase
enzyme in Event 3272 corn i.s not living
and thus cannot itself be a living .stage
of any organism listed In the PPA's
plant post definition.
Moreover, Event 3272 corn itself is
not a plant pest since it is clearly not a
living stage of any of the organisms
(articles) listed in subparagraphs (A)
through (G) of 7 U.S.C. 7702(t4). Nor is
Event 3272 corn itself the living stage of
any article (organism) similar to or
allied with any of the articles specified
in subparagraphs (A) through (G) as
required by subparagraph (H) of 7 U.S.C.
7702(14). Thus, APHIS has likewise
determined that Event 3272 corn itself
is not a plant pest as defined by the
PPA. Nevertheless. APHIS evaluated the
ability of Event 3272 corn to harbor
plant pests in the Plant Pest Risk
Assessment and determined that Event
3272 corn does not harbor any living
stage of any of the organisms (articles)
that are defined as potential plant pests
in subparagraphs (A) through (G). First,
APHIS described the genetic material
that was inserted into Event 3272 corn,
which included sequences from plant
pests, and included an assessment
analyzing the plant disease risk posed
by the genetic sequences. Second,
APHIS also analyzed the risk that Event
3272 corn would disseminate plant
pests (i.e. act as an 'article'). APHIS
concluded that the inserted genetic
material in Event 3272 com does not
cause plant disease and Event 3272 corn
does not increase susceptibility to plant
disease or insect pests, and therefore
does not harbor plant pests. (The
comments received on the docket
816
Federal Register/Vol. 74, No. 106/Tlmrsday, June 4, 2009/Notices
during the initial comment period did
not dispute or comment on these
particular issues related to APHIS’ plant
pest risk assessment.)
For the reasons explained above,
APHIS has determined that neither
Event 3272 corn itself, nor the alpha-
amylase enzyme in Event 3272 corn, is
a plant pest. To make clear APHIS’
above determination that neither Event
3272 corn, nor the alpha-amylase
enzyme in Event 3272 corn, is a “living
stage” of any of the organisms (articles)
listed in subparagraphs (A) through (H)
of the PPA’s plant post definition,
APHIS has revised the plant pest risk
assessment for Event 3272 corn to
include the PPA’s definition of a plant
pest. The revised assessment also
concludes that neither Event 3272 corn
nor the alpha-amylase enzyme in Event
3272 corn is a plant pest because neither
Event 3272 corn nor the alpha-amylase
enzyme meets the PPA’s definition of a
plant pest. These revisions to the plant
pest risk assessment are for clarity and
further explanation, but do not change
the overall conclusions made in the
draft plant pest risk assessment that
Event 3272 corn is unlikely to pose a
plant pest risk.
APHIS welcomes additional comment
on the issues raised during this process.
APHIS is also requesting comment on
the revised plant pest risk assessment,
and APHIS’ conclusion, as explained
above, that Event 3272 corn and the
alpha-amylase enzyme in Event 3272
com are not plant pests. APHIS will
carefully evaluate all additional
comments received during this process,
and any other relevant information. Ail
comments received regarding the
petition, draft EA, and plant pest risk
assessment will be available for public
review on the Regulations.gov Web site
(see footnote 1 for a link). After
reviewing and evaluating the comments
on the petition, draft EA, plant pest risk
assessment, and other relevant
information, APHIS will make its
determination, either approving or
denying the petition. APHIS will then
publish a notice in the Federal Register
announcing the regulatory status of
Event 3272 corn and the availability of
APHIS' written regulatory and
environmental decision.
Accordingly, we are reopening the
comment period on Docket No. APHIS-
2007-0016 for an additional 30 days.
This action will allow interested
persons additional time to prepare and
submit comments. We will also consider
all comments received between January
21, 2009 (the day after the close of the
original comment period), and the dale
of this notice.
Authority: 7 U.S.C. 7701-7772 and 7781-
77eS; 31 U.S.C. 9701: 7 CFR 2.22, 2.80, and
371.3.
Done in Washington, DC, this 29th day of
May 2009.
Kevin Shea,
Acting Administrator, Animal and Plant
Health Inspection Service.
[FR Doc. £9-13055 Filed 6-3-09; 8:45 am]
BILLING CODE 3410-^4-.P
DEPARTMENT OF AGRICULTURE
Rural Utilities Service
PowerSouth Energy Cooperative;
Notice of Finding of No Significant
impact
AGENCY: Rural Utilities Service, USDA.
ACTION: Notice of finding of no
significant impact.
SUMMARY: Notice is hereby given that
the Rural Utilities Service (RUS), an
agency delivering the United States
Department of Agriculture (USDA)
Rural Development Utilities Programs,
has made a Finding of No Significant
Impact (FONS!) with respect to a
request from PowerSouth Electric
Cooperative (PowerSouth) for assistance
to finance the construction and
operation of a new' 360 megawatt peak-
load natural ga.s-fired generation facility
at PowerSouth’s existing McIntosh
Power Plant in Washington County,
Alabama.
ADDRESSES: The FONSI is available for
public review at USDA Rural Utilities
Service, 1400 Independence Avenue,
SW., Stop 1571, Washington. DC 20250-
1571; and at PowerSouth’s headquarters
office located at 2027 East Three Notch
Street, Andalusia. Alabama 36420. To
obtain copies of the FONSI or for further
information, contact Stephanie Strength,
Environmental Protection Specialist,
USDA, Rural Utilities Service, 1400
Independence Avenue, SW., Stop 1571,
Washington. DC 20250-1571;
Telephone: (202) 720-0466 or e-mail:
sfepAanje.strengfh@wdc.usGfa.gov; or
PowerSoutli’s headquarters office
located at 2027 East Three Notch Street,
Andalusia, Alabama 36420.
SUPPLEMENTARY INFORMATION:
PowerSouth is proposing to construct a
new 360 megawatt peak-load natural
gas-fired generation facility at
PowerSoutli’s existing McIntosh Power
Plant with an in-service date of late
2010. The proposed project would
consist of two 180 megawatt combustion
turbine units operated by natural gas.
Burns and McDonnell Engineering
Company, Inc., an environmental
consulting firm, has prepared an
26835
Environmental Analysis (EA) for RUS.
Rural Utilities Service has conducted an
independent evaluation of the EA and
believes that it accurately assesses the
impacts of the proposal and has
determined that no significant impacts
would result from the construction and
operation of the proposal.
Any final action by RUS related to the
proposed project \vill be subject to, and
contingent upon, compliance with all
relevant Federal environmental laws
and regulations and completion of
environmental review procedures as
prescribed by the 7 CFR part 1794,
Environmental Policies and Procedures,
Dated: May 29, 2009.
James R. Newby,
Acting Administrator. Electric Program, Rural
Utilities Service.
[FR Doc. E9-13114 Filed 6-3-09; 8:45 am]
BILLING CODE 3410-1S-P
DEPARTMENT OF AGRICULTURE
Forest Service
Lewis & Clark County Resource
Advisory Committee Meeting
AGENCY: Forest Service, USDA.
ACTION: Notice of meeting.
SUMMARY: The Lewis & Clark County
Resource Advisory Committee (RAC)
will meet on Wednesday, Juno 10. 2009,
from 6 p.m, until 8 p.m,, in Helena,
Montana. The purpose of the meeting is
to conduct welcomes and introductions,
review RAC charter, discuss the
guidelines for Title II and Title III
funding and proposals, discuss
operating protocols, brief RAC members
on available funding, capture and record
preliminary project ideas, discuss
outreach process for project proposals,
set a next meeting date and receive
public comment on the meeting subjects
and proceedings.
DATES: Wednesday, June 10, 2009, ft-om
6 p.m. until 8 p.m.
ADDRESSES: The meeting w’ill be held at
the USDA-Hclena Ranger District office
located at 2001 Poplar, Helena, Montana
59601 (MT 59601).
FOR FURTHER INFORMATION CONTACT:
Kathy Bushnell, Committee
Coordinator, Helena National Forest,
2880 Skyway Drive, Helena, Montana
59602, 406-495-3747; e-mail:
kbushneU@fs.fed.us.
SUPPLEMENTARY INFORMATION: Agenda
items to be covered include: (1)
Welcome and Committee introductions;
(2) Review and revise, if necessary,
established RAC charter: (3) discussion
of requirements related to Title II and
817
Tuesday
June 16, 1M7
Part il
Department of
Agriculture
Animal and Plant Health Inspection
Service
7 CFR Parts 330 and 340
Plant Pests; introduction of Genetically
Engineered Organisms or Products; Rnal
Rule
818
22^92 Federal Register / Vol. 52. No. IIS / Tuesday. |une 18. / Rutea and Reguiations
OEPARTMEIIT OF AGRICULTURE
An^nai and Bant Haaitti tnapeedon
Strvfea
7CFRPai1a330and340
{Docket Na. 87-021)
IntroducdMi of C^iaidama wid
Preducta Attemi or Produeod
Hirou^ Genedc EngkietKlng WItleft
Aro Plant Peats or WMch Tbero is
Rssaon To BMeve Are Rant PaiRa
ACHBNCV: Animal and I^ant Health
Inspection Service. USDA.
acnow; Rnal rule .
tumiAfm This document establMtes
tegulations for the introduction
(teportation. int«state movement, or
release into the environment) of
genetically engineered organisms and
products whic^ are pknt pests or for
which there is reason to Iwlieve are
irfant pests {regulated articles). The
fc^atioius set forth procedures for
obtaining a permit for tho release into
the environment of a regulated anide
and for obtaining a linuted iwrmit for
the importation m interstate movement
of a r^ulated article. Such penntts are
required before a regulated artidc can
be introduanl in the United States.
Thmie regulations are neeesaary to
pcevmtt &a entry iato aad diaaemination
«k) estabH^ment of fdant pests in Uie
United States.
OATi: Effective date of final rule te July
18,1937.
ran inarrHcii t w roae uTTow oewr acn
Terry L Medley. Director. Biotechnology
end Environmental Coordination Staff.
Animal and Plant Health Inepectlon
Service. U.S. Department of Agriculture.
Room 400, Federal Building. 6S0S
Belcrest Road. Hyattsville. MD 20762.
301^36-7602.
aitpw mfWTaitY iwFoaiaaTioic
Background
^ |une ^ 1SB6. the Anhnal and
Plant Health Inspection Service {APHIS)
published a proposed rule entitled.
"Introduction of Organisms and
Products Altered or Produced Through
Cenetk &igmeering Which Are Hant
Pests or for Which Ihere Is Reason to
Believe Are flant Pests" (SI FR 233S2-
233G6 hereinafter referrerl to as the
{Koposed regulations). Tlte proposed
regulations set forth procedures for
obtaining a permit prior to the
introduction (importation, interstate
movement, or release into the
environment) of genetiCMliy engineerml
organisms or products which are plant
pests or for which there ie reason to
believe are plant pests (regulated
articles).
The provisions that appeared in the
pro;K>sed regulations and adpopted in
this final role concerning the n^ to
obtain a permit prior to introducing a
regulated article are consistent with
existing permit requirements in 7CFR
Psrts 300-399. Such requirements are
imposed hy Af) IIS in regulating the
movement of mm-geiretrcaliy
engineered organisims. products, and
certain articles which are plant pests or
could harbor plant pests. The nnal role
extends the reguiaticn of certain
organisms not genetically engineered to
certain Mganism: that are genetically
engineered.
Coaumata Received oo Proposed
Regutelioiis
AKflS attempted to solicit as many
commenta as pMSible on its propotad
regulationa through public hearing held
in Saenunemo, California, on |uly 29.
1066. and in Washington. DC on Augset
9. 1886 . and through an extension of the
comment period from August 25 to
September 26. 1966 (51 FR 29401. August
IS. 1966). Including the comments
presented ct the public hearings. APHIS
received 184 comments on the proposed
regulations. Commenters included
ecademicians. businesses engaged in
genetic engineermg, trade associations,
professional organisations, private
Indririduals/consultants. State
departments of agriculture, members of
the U.S. House of Representatives, and a
representative from a State legislature.
Ai^S has carefully considered all the
comments on the proposed rule.
Based ort the rationale set forth in the
pRqjoscd reflations end in this
document. APHIS is promulgating a fmal
rule which will become effective on July
16. im?.
Under tlte final rule, a pmon has to
obtain a permit to import, move
hiterstate or release into the enviroment
a geneUcally engineered organism or
product only if:
( 1 ) The organism has been altered or
produced through genetic engineering
bom an organism (donor, vector, or
redpient):
a. That is included in the list of genera
tfid taxa »i 1 3W.2 and such organism
meets the derinition of a plant pect; or
b. That is an unclassified organism
and/or an organism whose classification
is unknown; or
(2) The product contains such .'in
organism (described in (1): or
(3) Any other organism or prmfuct (not
ifiduded in ( 1 ) or (2) altered or produced
through genetic engineering, whidi the
Deputy Administrator det«niines is a
plant pest or has reason to believe is a
plant pest. Thus, this final ruk n^lates
certain genetically engineered
organisms and pr^ucts that present
plant pest risks, and, as explained in
more detail below, does not regulate an
aitide merely because of the process by
which it was produced.
Many provisions, as noted Imiow.
have bea changed in response to
comments, whi^ were generally
constructive and often complex. Because
numerous changes have been made to
the regulations as originally proposed, a
sninmary of those changes is presented
at the outset of the preamble. The
summery includes the number of the
paragraph in which the rationale for the
APHIS action is discussed. Following
the summary is a detailed discussion of
the relevant comments received, and
AMIS’ response to those comments.
The preamble is organized to
correspond with sections of the final
rule.
819
Federal Regiater / Vol. 52. No. 115 / Tuesday. |une 16. 1987 / Rules and Regulations 22M
Summary of Chamqes Made m Final ftuLE><-Continued
Comments on APHIS'Authority to
Restrict the Introduction of a Regulated
Aidcle
1 . Approximately thirty-one
commenters prefaced their remarks with
genera! statements supporting APH!S'
approach in Part 340. The comments
induded backing for APHIS as "lead
a^ncy” and support of APHIS'
authority pursuant to the Federal Plant
Pest Act (FPPA) and Plant Quarantine
Act (PQA| to regulate genetically
engineered oiganisms as set forth in its
proposed regulations. Seven
commenters. however, alleged that
Aprils lacks the authority under the
provisions of the FPPA and PQA for the
proposed rule. Specincaliy, the
commenters indicated that the FPPA
does not authorize AfHIIS to regulate
“release into the environment.” but only
importation and interstate movement:
and that the FPPA and Federal Noxious
Weed Act (FNWA) and the Act of 1903
have no “beforehand testing" or pre-
release review r^uirements to
determine if new organisms might be
pests, noxious weeds or contagious
agmits. -
APHIS disagrees with the commenters
who challenged APHIS' authority for the
proposed rule, is should be noted that
APHIS never cited the Federal Noxious
Weed Act (7 U.S.C. 2601 et seg.) or the
Act of 1903 (21 U.S.C. 111 el seq.) as
authority for promulgating a final rule
under Part 340. Rather. APHIS cites as
authority die Plant Quarantine Act (7
U.S.C. 151 et seq.) and the Federal Plant
Pest Act (7 U.S.C. 150aa et seq.).
It is the Department's position that the
provisirms of the rule requiring a permit
prior to the release into the environment
of certain genetically engineered
organisms or products containing such
organisms is consistent with the
legislative intent of the FPPA and is a
reasonable construction of the
Department's statutory responsibilities
under the FPPA.
Tbe FI7A was enacted to Hll gaps in
the Department's authority to protect
American agriculture against invasion
by foreign plant pests and diseases. It
confers very broad authority on the
Secretary of Agriculture to prevent the
disseiuinaticm into the United States or
interstate of plant pests.
The legislative history of the FPPA
indicates that in addition to providing
authority to regulate organisms that
"can injure” plants or plants products,
the FPPA provide authority to regulate
organisms that might later found to
be injurious to cultivated crops. (See the
Department's legal opinion concerning
this issue, attached as Appendix G of
"Issues in the Fed«al Reg^ation of
Biotechnology: From Research to
Release", a report prepared by the
Subcommittee on fovestigations and
Oversight of the Committee on Science
and Technology of the House of
Representatives. 99th Cong., Znd
Session, December 1988).
2. One eoinmenter who expressed the
view that separate regulation of
genetically engine ered organisms is not
authorized by the FH*A suggested that
APHIS should amend its existing
regulations rather than promulgate new
regulations.
APHIS disagrees with this commenter
and has determined that separate
regulations for certain genetically
engineered organisms are needed. Under
(he FPPA. APHIS can regulate plant
pests whether they ere naturally
occurring or genetically engineered.
APHIS regulations in 7 CFR 33a2QO are
applicable to persons seeking to import,
or move intmtate plant pests which are
naturally occurring and have not
resulted from genetic engitmering.
APHIS believes that the regulations in 7
CFR 330.200 are not adequate to regulate
the introduction (imix^ation. interstate
movement, or release into the
environment) of genetically engineered
organisms and products for two reasmit.
The regulations as presently written
provide no way for the public to
determine whether or not a genetically
engineered organism or product would
be deemed a “regulated article.'*
Secondly, die data that Is called for in a
permit application under 7 CFR 330.200
would not provide APHIS with suHicient
information to make a determination on
the plant pest status of certain
genetically engineered organisms or
products. In short. AIWS determined
that its existing regulations could not be
readily amended to Include the data
elements that are needed to adequately
regulate the introductiem of gtmetically
engineered organisms, and ^t separate
regulations for genetically engineered
organisms are required.
Amis is not treating genetically
engineered organisms and products
which are plant pests or for which there
is reason to believe are plant pests
di^erently titon so<alied “m^tabUsked”
plant pests or naturally occurring
organisms which there is reason to
believe are plant iresto. In bodt cases, a
permit must be obtained from
prior to importation and Interstate
movement. In the case of certain
geneticaliy engineered organisms,
APHIS has deteiminwl that the release
820
ZZBS4 Federal Regbter / Vol. 52. No. IIS j Tuesday, fune 16. 1987 / Rules and Regulations
into the enviroiunent of certain
genetically engineered organisms is
tantamount to the introduction of a new
organism. Further, living organisms do
not acknowledge State lines. Therefore,
a permit must obtained from APHIS
pHor to release into the environment.
Conuaents on the Scope of the Proposed
Regulations
3. Seme commenters expressing
support for APHIS' approach also
expressed concern that the proposed
role was too broad and inclusive and
needed modification to be practicable.
Some commenters indicated that the
propose regulations would cause
APHIS to be overwhelmed with
applications for permits. Many
commenters expressed the view that
APHIS should have the ability to
exclude certain products or classes of
products from the regulations as
experience indicates certain exemptions
are justifled.
APHIS agrees with commenters
expressing the vierv that the proposed
regulations were too broad and
inclusive and has made several
revisions to nsnnw the scope of the
regulations.
As a means of eliminating the need for
a “responsible person" to submit s new
application for a limited permit for the
interstate nwvement a regulated
article between contained facilities each
time the iwrson seeks to move the
article interstate. APHIS has added
provisions in I 3404{cHl} that would
allow such movement to be made under
the pmviitons of a single limned permit,
which would be valid for one year. Such
a permit could be renewed thereafter, if
appropriate. This change should
significanity eliminate the number of
applications AmiS will have to
process, and significantly reduce the
number of sppHcationi that would have
to be submitted. (See paragraph 32.}
Further, as discussed in more detail in
paragraplui 11. 16 , and 19. APHIS has
amended the definitions of “organism",
and '’regulated article", as well as the
list of organisms in S 340.2. These
changes narrow the scope of the final
rule.
In addition, in order to facilitate the
addition or removal of certain genera,
species, or subspecies of organisms on
the list in 3 340.2. APHIS has included
provisions in $340.4 of the finul rule fur
a person to submit a petition to amend
the list of organisms. (See paragraph 42.)
Cotmnents Requesting that .\PHIS Not
’Regulate Research
4- Sixty-eight comments were received
from academic researchers and/or
inatilulions expre.ssing opposition to
APHIS' regulation of the introduction
(Imporiatum. interstate movement, or
release into the environment) of
regulated articles. The majority of the
commenters argued that this amounts to
the regulation of research and that
biotechnology research can be regulated
by the research community itself using
institutional biosafety committees and
the USDA Guidelines that were set forth
in the Advanced Notice of Proposed
USDA Guidelines for Biotechnology
Research. (See SI FR 23367-23393} These
commenters argued that a clear
distinction exists between research und
product development and that APHIS
should regulate only when a product is
involved.
APHIS disagrees with those
commenters that believe that the agency
is regulating research. APHIS believes
that the rcgulatiun of the introduction of
certain genetically engineered
organisms does not amount to regulation
of research, but rather regulation of
movement and release into the
environment of a regulated article. The
fmai rule does not attempt to prescribe
whai a person can or cannot do in a
laboratory or contained greenhouse, but
r.*!th&r. unacr what conditions a
regulated article can be moved or
released. It should be noted that a
person does not become subject to these
regulations until the person seeks to
wtroduce gunctically engineered
organism;;. Thus. AITIIS does not
believe that the final rule is an attempt
to regulate research.
API US also disugrees with the
coounents that argued that APHIS
should only become involved when a
"product " is involved: there is no
statutory limitation in the FPPA or PQA
fur AHHIS to regulate in such a manner.
APHIS' statutory responsibility is to
take those measures necessary to
prevent the introduction into the United
Stares of "plant pests '*
Communis o-n DefimtiRns (934(LX)
T.he defiMUions cf key words in
proposf rf I’a.'l 340 collectively generated
the largest number of commerre on a
single seciinn. Comments or: the
individual definitions and APHIS'
response are presented in alph.^betlcal
order,
Ct}rUfircie of Exemption
5. No change has been made in this
dehnition. but the name has been
changed to "counesy permit." For s
discussion of the comments and
expliination of the rationale for the
change see paragraph 34.
Classical Genetics
8. The six comments on this definition
generally indicated that it should have
included such processes as protoplast.
celU and embryo hision. and
mutagenesis, because such processes
have traditionally been as.sociatcd with
classical genetics techniques. APHIS
agrees with this assessment, and has
revised the defmition of “genetic
engineering" to exclude rderence to
cisssica! genetics as well as protoplast,
cell, and embryo fusion, and
mutugene.qs. An examination of the
literature describing the tedmiques used
in genetics prior to the introduction of
recombinant DNA iechnclogy finds that
many techniques other than interspecific
crosses have been in common use. The
transfer cf genetic traits by methods
such as protoplast, cell, and embryo
fusion, and mutagenesis has been an
accepted part of genetics for some years
prior to the development of varloui
recombinant DNA technologies fw the
movefreni of genes. It wmiid thus seem
that the techniques in question should
properly be tneludcd as a part of
classical genetics, and excluded from
the dofmitiun of “genetic engineering.'*
As * result of the change in the
definition of “genetic engineering" to
exclude reference to classical genetics,
the definition of “classical genetfcs“ has
been deleted.
Genetic Engineering
7. The twenty-three comoients on this
definition generally e.spressed the view
that such techitiquus is pruluplast. celt,
and embryo fusiun. and mutagenesis
encompass classical genetic |*roco8sev.
For the reasons stated in paragraph 6
above on dassical genetics. API US
agrees with the contmeuls that specihe
techniques such as protoplast, ceil and
cRibryo fusion, und mulagenests should
not be included in '’genetic ensmeering."
A new dehoition has been provided, as
foilvws: ■Thcgcnetic ci
organisms by recombinant UN \
techniques." It should bi* noted that if a
new organism or produr-t was produced
using classical genetic techniques, and
rtte new organism was a plant pest, it
would be regulated pursuant to a simthir
permit system found in 7 CFR 3.10.200-
Cenetic Manipulation
6. Because the definition of genetic
engineering has been modified and the
term genetic manipulation is not used iu
the current definition of that term.
APHIS has deleted the definition of
genetic mampulation.
821
Fedwal Rcgitter / Vol. 52. No. 115 / Tuesday. |une 18. ISgT / Roles and Regulations
Introduce
8. Two c»Buiient8 tirere received on
the dermitkm of introduce. One
cmnmenter st^geeteci that the derinition
be expanded to include “creation of a
new oi^nism or genotype" in addition
to importation, intmtate movement,
and release into the environment. The
commenter argued that the regulation of
genetic engineering should begin with
the development of the organism In the
laboratory.
As previously stated, the final rule
does not regulate laboratory research
(inducted at cemtained facilities. The
resptmsibility at USDA for the oversight
of biotechnology research is deleg.ited
to the Assistant Secietaiy for Science
and &lucation. APHIS believes that if
the labomtop’ is a contained facility,
such n^ulaiion by APHIS would be
unnecessary from the standpoint of
preventing the introduction of
genetically engineered organisms which
are plant pests or which there is re.'ison
to believe are plant perts. and would,
therefore, be i^yond APHIS* statutory
authority.
Another commenter expressed the
view that the term introduce or
intnxluction is son^what redundant in
that it oveiiapa with the definition of
relcHse into the environment and that
the term "release into the environment”
should be dropped from the definition of
introduce.
APMUi disagrees with the commenter
that inclusion of the phrase "release into
the environment" is redundant.
Inclusion of the phrase "release into the
environment" in the definition of
Introduce is meant to advise persons
that AflllS is regulating (he release into
the environment of a regulated article, in
nddition to regulating interstate
movement and importation. According
to S 34CMKa} of the Onal rule, no person
stiaii introduce (release into the
envi-roument) a regulated article unless
the introduction is authorized by a
pcinntt and the introduction is in
couformance with ail of the appitcubis
restrictions in this part.
Mutagat
10 . Because the definition of genetic
engineering has been modified and the
turm mutagen (mutagenesis) is not used
in the current definition. APHIS is
deleting the deHnition of mutagen.
Organism
11. The twelve comments on the
definition as proposed expressed the
view that it was too broad and should
not include portions of organisms.
ARfIS agrees with these comments, and
has deleted the language "and any part.
copy, or analog thereof, including DNA.
RNA. which is infectious."
The original definition of organism
included these constituent parts, which
are not included in any currently
accepted concept of the nature of an
organism. APHIS has review^ this
questimi. and determined that the
separate amstituent parts of an
organism can not be regarded as
"living", and do not present (he same
plant pest risk that the complete or
intact a7gani.nrii may pose, lliis is not to
deny that some components, such as
DNA .sequences, or organisms, which
are plant peasls may not present some
ri«k if they are incorporated into other
organisms. However. t( has been
determined that it is passible to regulate
the itsk associated with these cell
components without residing to the
inclusion of these ndi-iiving
constitiienu as organisms. This is
bec;«use a genetirnlly engineered
organism which conmins these
components from en organism listed in
& 340.2 would be deemed a regulated
article.
Phuns have also bec.i deleted from
this definition, and from the list of
onjanisms >n § 340.2. *nie reasons for the
deletion are explained in the discussion
of the comments on S 340.2.
An amended definition hus been
adopted, as follows: "Any active,
infective, or durniant stage of life form
of an entity characterized as living,
including vertebrate and invertebrate
are animals, plants, bacteria, fungi,
myeoptasmas. mycoplasma-like
organisms, as well as entities such as
virjids and viruses, or any entity
characterised as living, related to the
foregoing."
Patf-ogp^n
(2. Because the deHnition of regulated
article h.ts been modified and the tenn
pathcgcii (palhogenir) is not used in the
current d^tfuiiJ-on. APIllS is deleting the
dcfmitjon nf pathogen.
Parstv:, it:tst.»h>sih/e Person
13. One <.onimenter noted that the
proposed re^sHia'ion.*: contained
driiiiitiuns of the terms "person" and
"rpsponvit.le person." The commenter
asked, "who is responsible, the
individual or the individual and his
rorpornlion?
The nnui rule aplies to either a single
person when acting alone when there is
no corporation or other lego! entity, or
the pereun designated by the
corporation or other legal entity to be
the responsible person and the
corporation or other legal entity, when
the responsible person is acting within
the scope of bisor her employment of
the cmpiH'atiim.
Plant
14. The mafoiity of the seventeen
commenters on this detinition pointed
out that it was not consistent with the
classification of ont^nisms in § 3^.2 of
the proposed regulations. Tliese
comments noted that the definition of
plant included bacteria, but that
bacteria was nut listed under the
Kingdom riantcic: bacteria had been
listed under the Kingdom Monera. The
commenters argued that bacteria should
nut be included in the dufinitinn of plant
Other conimi.‘nters objected to the
mclitston of fungi and prokaryotic algae
in the plant kingdom. One commenter
noted that the inclusion of such
organisms in the plant kingdom fails to
consider the results of tvvunty-five years
and more of comparative biochemistry
conceiticd with the structure and
function of ceils.
API IIS agrees with these comments,
and has accordingly dcieit-d bacteria,
fungi, and prokaryotic algae from the
derinition.
amended definition has been
edopted. as follows: Any living stage or
form of any member of the plant
kingdom inciuduig. but not limited to
eukaryotic algae, mosses, club mosses,
ferns, horsetails, liverworts,
angiosperms. gymnospornts. and lidiens
(which contain algae) including any
parts (c.g.. pollen, seeds, cells, tubers,
stems) thereof, and any cellular
components (a.g.. plasmids, ribosomes,
etc.) thereof.
Plant Pest
15. Nine comments were received on
the definition of plant pest. The
commenters indicated that the definition
WHS very broad and overly inclusive,
that it included numerous examples of
nunpniliogenic organisms, and that it
fuiM to adequately notify applicants of
the characteristics or criteria to enable a
determination of non-pest status.
APHIS acknowledges that the
dcHnition of plant pest is very broad.
However. APHIS disagrees that the
definition is overly inclusive, and the
definition has been adopted as
proposed. The definition of plant pest
comes from the definition of plant pest
found in the FPPA (7 Uii.C. ISOaa et
seq.). As discussed in response to
paragraph 1. the deHnition of plant pest
was deliberately made broad by
Congress to include those organisms
thet might latcrbe found to be injurious
to plants. Al^ilS has determined that all
of the types of organisms included in the
definition of plan! pest have been
822
aaKW Federal Register / Vol. 52. No. 115 / Tuesday. |une 16, tW7 / Rules and Regulations
known to directly ch* iniibrectly injure or
cattle either diiease or damage in
planti. or in plant parte, or in proceised.
manufactured, or other product! of
pianta. APHIS believea that the
definition of plant peat indicatea to a
p«son that an organi«n that doea not
have plant peat atatus would be one that
doea not directly m indirectly injure or
eauae diaeaae or damage in any pianta.
or plant paila. ca any {msceaaed,
manufachired. or other products of
plants.
H^hted Article
1&. Thirty-four coinn-.i:nt8 were
received on the deHnititm of regtUated
artide. Fifteen of these comments
expressed the opinirm dial the proposed
deHnition of regelated article was too
touid. Some commenten stated that as
defined '‘regulated article** could be
interpreted in a way that would include
many organisms that the commenters
did not consider to be plant pests. In
many cases o>mmentcrs identified
m>ecific organisms that they ateted were
not plant pests, and thus should not be
subject to regulation. Other enmmenters
stated that the inclusion of non-living
components of plant pest orgiinisms
should not be inchidt^ as a regulated
artide.
APtflS agrees with these comments,
and haa modified the final rule in
•emiireapecta to narrow the aeope of
reguiatad article.
First, the list of organisms in ft W.2.
ttdiich wmild causa a genetically
engineered orgentsm or product to be
detuned a "regulated artide." has been
modified, fay deleting certain organisms
and by dearly atsting hew the list is to
lit utilized. S<^ndly. the definition of
organism has been modified to exclude
non-living components or parts of
organisms listed in § 340X Lastly.
Anns has modified the definition of
rejpilated artide to indicate that an
orgmiism which bdonga to any genera
or taxa deti^ated in ft 9402 must meet
the definition of “plant pest‘* or be an
unciassifiad orgamam and/or an
organism whose classification ia
unknown.^br contain su^ an organism.
or any oihrt’ organism which the Deputy
Administrator determines ia a plant pest
or has reaKin to believe is a plant pest.
The change is significant since it would
affect whether the genetically modified
organism is deemed a related article.
The following new defimtion has been
adopted: “Any organism whidi has been
altered or product thremgh genetic
engineering if the donor otganismjs).
redpi«it cuganism(s), or vector or vector
agentfs) belongs to a genera or taxa
designated in ft 340.2 of this part and
meets the definition of plant pest or is
an undasaifiad oi^anism and/or an
organiMn whose dauification is
unknown, or any product which
contains such an organism, or any other
organism or product altered or product
through genetic engineering which the
Deputy Administrator determinea is a
plant pest or has reason to believe is a
plant peat Excluded are redpient
microofganisma which are not plant
peats aid which have resulted from the
addition of genetic material from a
donor organism where the material is
well characterized and contains only
non-coding regulatory regions." (The
rationale for the exclusion for certain
microorganisms is discussed in
paragraph 18).
Several commenters suggested tliat
APHIS add procedures which would
provide for the exdusion of organisms
altered by recombinant methods, whidt
are not plant pests.
APHIS agrees with the commenters
and believes that the petition procedure
discussed in paragraph 42 ia responsive
to the commenten* rancerns.
Several commenters sugge.Hted that
the delegation of authority to the Deputy
Administrator to designate an organism
as a “regulated article * based upon
"reast'in to believe" was a standardless
delegation of aulhwity.
APHIS disagrees with these
rommemtf. *1116 provision for the Deputy
Administrator to destgnate an organism
as a re^'ifated artidebased upon
''re.isoit to believe" has been retained.
Section 105 of the F^A grants the
emergency authority to regulate an
organism, where there Is reason to
believe it is a plant pest or in order to
prevent the dissemination into the
United Slates of a plant pest. With
regard to conventional plant pests, the
Deputy Administrator of APHIS has
used this authority when it was '
necessary to regulate an organism that
was likely to be a plant pest and was
not otherwise specified because of plant
pesi risk as a regulated artide. "Reason
to believe" Is based on scientific
information, audi as taxonomic
association and bioiogiral data. This
standard is an objective, not subjective
one.
An example of the use of "reason to
believe" occurred in 1982 when a
previously undescribed disease was
observed on lime trees in Southwestern
Mexico. APHIS r^ulations prohibit
entry of citrus fruit from countries where
citrus canker is present Initially it
proved difficult to make a specific
idcntificalicm of the pathogen associated
with thia disease. Because the pathogen
belonged to the bacteria! genus
Xanthomonog. and because the disease
caused lesions on citrus leaves, it was
detmminmi that thiree waa reason to
believe that the disease in Mexico was
citrus caidcer. and that the organism
associated with the disease was a plant
pest. This resulted in various actions
being taken to prevent the introduction
of the disease into the United States.
Subsequmit research conducted in the
United States and Mexico omfirined
that the organism causing the disease in
Mexico was Xanihomonos eampestris
pv. eitri. 3 regulated plant pesL
The dedsion by APHIS to designate
an organism as a regulated article based
upon the "reason to bdieve" fmvision
will be an objective, informed dedsion
made afier review of substantive
information regarding demonstrated
plant pest risks. It will not be an
arbitrary one.
Release into the Environment
17. Of the e^hteen comments on this
definition, the largest number concerned
the fact that the proposed definition
relied only on physical containmrtiL and
ignored biolt^ical containment. Other
commenters requested a definititm of
contained greenhouse, expressed
approval of the definition, or attested
various ai^roaches to the evaluation of
containment
One commsnter indicated that a
general understanding of this tenn hat
been that release ocoirs if as
experiment does not take place uHttJn
the confines of a iaborato^ whare the
organism can be physically contained
and remedial measures taken in the
event of an aeddent APHIS agrees with
the commeiitcr and believes that the
concept of release should be bated on
the concept of a release from the
confines of physical containment One
commenter suggested regulating release
only if there is a deleterious alteration of
(he environment. APHIS believea (hat
what is "deleterious" to the environment
is too subjective a standard. USOA
believes that a release from physical
confinenteni is more understandable
and a practical standard.
APHIS has adopted the definition of
“release into the environment" as
originally propped. APHIS believes
biological and greenhouse containment
are key issues in discussions concerning
this definition. While the definition of
release into the environment does not
formally tncitkie the concept of
biologicai containment (i.e. the inability
of (he regulated article to sunnve
(Hitside specific environmental or host
conditions) API US believes that
biobgicai containment is one important
factor in determining (he prescribed
level of physical containment. Since
greater scrutiny is needed to judge the
823
Federal Register / Vol. 52. No. Its / Tuesday. }une 16. 19S7 / Rules and Regulations 22897
eHicacy of bioio^icai containment than
physicai containment. APHIS does nut
believe a claim of bioiojjical
containment is suRtcient to enempt m
party from the requirement of having to
obtain a permit for the release of a
regulated article into the onvuonnmnt.
Ii5 APfliS' review of pe;init applications,
dutorminations of the ari»iquacy uf
liiologica! containnier.t will vaiy
according to the subj>a;t otgaiiism and
quoiity of scientific evidence, and w lU
be made on a case-by*case basis. In its
review process. ATIHS wilt allow
bioi<^icaI contamment in lieu of
physical containment if it determines
this will prevent the disseminatina and
estnblishment of plant pests in the
United States.
APHIS does not believe it is practical
to tty to define what is a "contained
gn;Rnhnu.se", since what is considered
iideqnate physical containment will vary
according to the subject organism, and
that such determination must be made
on a C8se>hy-C8se basis. For example,
physical containment will depend upon
combinations of laboratory practices,
containment equipment and specinl
laboratory design. APHIS will review
the data submitted in a permit
application ctmeeming the description
of a "contained facility" in determining
whether the eontaiimd facility it
adequate to prevent Ike r^eaae into the
eiiviroRfltent of the genetically
engine«red organism. A person should
consult the NIH Guidelines at 51 FR
16S6B. **A{HM»idix G— niysicel
Containmenr. for guidance on what are
apprupriete methods of physical
containment
APHIS acknowledges that the
Biotechnology Science Coordinating
Committee, the National Institutes of
HeaiUu and the Environmental
Protection Agency am all attempting to
deHne what constitutes release into the
enviremment If a uniform definition is
adopted thmm groups APHIS shall
consider proposmg to amend the final
rule to iimofi^ate such a definition.
Well-Characterized and Contains Only
NonCoding Resahtory Regions:
Exclusion /or (^rtain Microorganisms
18. A total of nineteen comments were
received on this exclusion h’om die
definition of related article, ft was
proposed to exdude muToorganisms
that are "n(m-pethogenic. nrni-
infectious. and othewise not plant pests
that have ranilted frimi the addition of
genetic meteriel that is well
characterized and contains only non-
coding regulatory regions."
Ute comnumts on this provision
ranged from doulri about the scientific
soundness of such an exdudon to
rcquuiits iHut the exdusion he retained
and expanded to include other nnn-
coding regions.
Bas<;d upon u review of these
cnmn.nUs and the Mientifie literature, it
WHS dotumtined that there is no
ovidmc'c that the additioiiof well*
characterized non-coding rogulato.*y
geoi-ti from a im>karyote or eukaryote to
u prokaryote has resulteri in the de novo
ufo'carance of a gene product which riid
not exist phur to the acquisition of the
new genetic material. Tlie scientific
Uier iium indicates that regulatory.
ti-unscripUonal or translational
iiinbiguitics are not found in the transfer
of well characterized genetic material
bet'-veen pn^karyotes. or from
eurkaryote to prokaryote, bat do occur
in prokatyoie to eukaiyote transfers.
One commetiicr indicated that come
pathogens have the capacity to increase
in virulence m change in host range in
response to a .single gene mutation and
(hat sr.hie avirulem derivatives of
palhr>g«ris have the potential to regain*
patiiogericity by mutation. The
commemer stated that such
microorganisms need to be examined
before release to the environment.
However, the commenter noted that a
distinction must be made between a
derivative of a pathogen, potentially
harmful, and a nonpathogenic organism
bearing an introduced gene from a
pathogen.
APHIS agrees with the commenter
that if the recipient microorganism is not
a pathogen or a plant pest the
microorganism aftn the addition of
genetic material which is well
characterized and contains only nnn-
coding regulatory regions, will also not
be a pathogen or a plant pest. Therefore,
as adopted in the final rule, recipient
microorganisms whidi are not plant
pests and which have resulted from the
addition of genetic material from a
donor organism which is "well
characterized and contains only non-
coding regulatory regions" arc not
n^iated articles. However, if the
recipient microorganism was a plant
pest, the addition of simh genetic
material would not lessen the fact that
the recipient microorganiam.s presents a
plant pest riric. and as such, would be a
regulated arilde.
One commenter suggested that other
non-coding regions such as ribosomal
RNAs. tRNAs. and RNAs as required for
replication also be exempted from
review because these do not encode
proteins.
APHIS disagrees with the commenter.
The reason that the exclusion cannot be
currently extended to other specific non-
coding. non-regulatory regions such as
ribosomal RNAs. tRNAs. and RNAs
riiquired for replication is that most of
these aforementioned genes are part of a
complex interdependent .system of
operons. Tbe.se operons generally
contain a very wide array of
dusconnected functions which interact
wiih other related and unrelated
operons to poroducx critical non-
slructnra! proteins which are needed in
equimolar antnunls. Therefore, the
roRscqucnces of the genetic transfer of
this level of genetic complexity, even
between bacteria, are not well
underetood. and co j!d have unforeseen
restUts. APHIS believes there may be
signtficant potential plant pest problemK
present in this type of gene transfer if
the exclusion were more extensive.
Commenters argued that "knowing the
exact nucleotide fuse sequence of a
regulatory element or the transfer of
non-coding regulatory sequences" does
not allow one to predict the biological
role of this element when placed in
another organism.
Anils disagrees with the
commenters. In the case of (the transfer
between prokaryotes or eukaryotes to
prokaryotes) "well-tdiaracterized min-
coding regulatory genes.” there is
absolute predictability of the biological
role of these genetic elements, and it can
only execute its original predetennined
regulatory function.
One commenter argued that it did not
make sense to exempt only non-coding
sequences. The commenter indicated
that almost all "coding" aequmtees
should be given exempt statue sudi as
cloned sequences. Another commenter
noted that there are many well-
cheractcrized coding regions, whidi
have no known or expected hazard to
health or the environment which should
also be excluded.
APHIS disagrees with the commenters
who believe that oucroorganisms which
have resulted from the addition of
genetic material which contains coding
regions should also be exempt.
With the exclusion for
microorganisms as mmUfied in the final
rule, it is impossible for the benign
reci{tiettt to acquire new structural genes
or gene products. The exclusion of well-
characterized coding genes could result
in the acquisition of deleterious new or
novd gene products in a benign
recipient Therefore, the commenter's
suggestion has not been accept^.
One commenter suggested modifying
the definition of well-characterized and
contains only non-coding reguiatmy
regions. The commenter suggested
modifying the definition by eliminating
section (c) of the definition because it is
redundant to sections (a) and (b) and by
revising section (c) to indicate that the
824
23898 Federal Ragirter / Vol. 52 . No. 115 / Tuesday, June 19 . 1987 / Rules and Regulations
transferred genetic material must be
Ron^codii^ in the hew host
microorganism.
The m^iHcation of the definition as
suggested by the commenter is
unnecessary. There is no evidence to
support the commenter's suggestions
that a non-coding gene from a donor
microorganism could be a coding gene in
a recipient microorganism.
One commenter noted that the
precision in molecular biological
experiments must not be confused with
predsiOR in predicting their ecological
ccmsequences. The commenter indicated
that this alteration of the organism as a
whole or its relaticmship to other
organisms in the eRvirrament would be
ui^own. and that such regulatory
dianges in the organism can create
“nover organisms which are eminently
suited to disrupt ecological niches.
APHIS disa;prees with the
commenter’s assertion that a novel or
new organism would be created as a
result of the addition of genetic material
that contains only weli-^aractertaed
non-coding regulatory regions. APHIS
believes that in this apeciflc case, the
absolute underetanding of the
undcriy^ molecular genetic
mechanism is the sole determinant in
being able to predict the plant pest
characteristics of the modified
mieroorgaitism. It is APHIS’ position
that when donor genetic materiai from
an organism whi^ la well characterized
and contains only non-codi^ regulatory
r^ions is placed into a benign
receiplent microorganism, the recipient
will not acquire plant pest traits or
become a plant pest.
Furthennore. APHIS believes that the
genetic menipulatioRs which create such
a microorganiam would be similar to the
same type of genetic manipulations
which occur in nature through mutation
and natural selection (the hi^cr or
lower production of a pre-existing
structural gene} or through classical
breeding techniques which man has
been using for the past 10.000 years, in
short such a modified microorganism
would be so close to ones produced by
natural mutational events or selective
breeding programs (classical techniques)
that there is no reason to believe that
such a microorganism would be a plant
pest. Furthennore. APHIS believes that
the possibililty of harmful ecological
consequences would not be considered
signincant.
ComiMRtt Concerning the List of
Organisms in (§3402)
19. Fifty-two comments were received
on the list of o^anisms in § 340.2. which
are or may contain known plant pests or
for which the Department has reason to
believe are plant pests. The commenters
generally expressed the view that the
list was overly broad and inclusive, and
that only organisms known to be plant
pests should be included. Other
comments were received which objected
to the inclusion of various taxa or
groups of organisms which commentere
a^ed were not plant pests.
APHIS agrees with those commenters
that believe that the list was overly
broad and inclusive, and agrees that
oniy organisms from any genera or taxa
listed in § 3402 and that meet the
dennition of “plant pest" should be
regulated. APHIS has made several
tensions in the Hnal rule to implement
this change.
APHIS has revised the prefatory
language in S 3402 of the rule, which
explains how to determine if an
organism classified In an unlisted taxa
which comes under a higher listed taxa
would be deemed to be a plant pest.
Further. APHIS has amended the
definition of “regulated article” to
indicate that an organism which belongs
to any graera or taxa designated in
i 340.2 must meet the definition of plant
pest before it is deemed a regulated
article. In addition. APHIS has added
the following new footnote 4 to § 340 2
which explains the conditions that must
be met before an organism is deemed a
plant pest.
An ofgicRism belonging to any taxa
contain^ within any listed genera or taxa is
only considered a plant peat if the organism
“can directly or indirectly injure, cause
disease, or damage in any plants or parts
thereof, or any processed, manufiiciured. or
other proiiucts of plams.” Thus, s particular
unlisted species within a listed genus would
be deemed a plant {Mst for purposes of
8 3402 if the sciMifitic literature refers to the
organism as a cause of direct ur indirect
injury, diaeuse. or damage to any plants,
plant parts, or products of plants. (IFtheru is
any question conceming the pianl'pesi status
of an organism belongii^ to any listed genera
or taxa. the person pressing to introduce the
organism in question should consult with
APHIS to determine if the organism is subject
to regulation.)
As the language in the footnote
indicates, an organism is not necessarily
considered to be a plant pest, and thus
subject to regulation, simply because the
organism is a member of any listed
genera or taxa. The list of genera or taxa^
in S 3402 is presented as a list of ail
taxa which may contain plant pests.
Within any listed genus or taxon, the
organisms subject to regulation as plant
pests are only those organisms that meet
the statutory definition of plant pest (t.e..
causes injury, disease, or damage in
{dants. plant parts, or products of
plants). In most cases, organisms that
are known to be plant pests will be
referred to or discussed in the scientiHc
literature. APHIS’ reveiew of the
scientific literature involves a search of
the relevant a^cultural data bases
which include, but are not limited to
Agncola. Biosis Previews. Cab Astracts.
Agris International. Life ^uences
Collection, and Supertech.
In addititm to all those species for
which the plant pest status can be
determined by reference to the scientific
literature, there will be certain other
species or organisms for which the plant
pest status will be unclear, due to such
things as problems with taxonomic
designation. If there is any question
concerning the plant pest status of any
spedes or organism ^longing to any
listed genera or taxa, the person
proposing to introduce the organism in
question should {X)n8ult with APHIS to
determine if the organism is subject to
regulation.
This procedure for determining if an
organism is subject to regulation under
Part 340 is the same type of
determination that must be made when
a person proposes to import or move
interstate non-geneticaily engineered
organisms that may be subject to
regulations promulgated under the FI^A
and PQ.\ and found in 7 CFR 330200.
Lastly, for the reasons discussed In
the proposed regulations of {uoe 26.
1986. published in the FedenI
at 51 FR 23355, unclassified organisms
snd/or organisms whose clasmlcatirm
is unknown are also included in i 3402.
20. Many comments contained
statements that various groups of
organisms listed in { 340.2 should be
removed from the list because these
organisms are not plant pests. The
groups of organisms most frequently
mentioned in these comments were the
bacterial genera Rhizobium and
Bradyrhizobium. and various groups of
mycorrhizal fungi.
However, those commenters did not
present su^icieol data to justify
excluding Rhizobium. Bradyrhixobium,
and various groups of mi^nrhlzai fut^
from the list of oiganisms in 1 340.2.
These taxa or groups of organisms
contain organisms that are able to infect
plants and survive at the expense of the
host plant. The interaction between the
infecting organism and the host plant it
usually regarded as a symbiotic one.
with the plant benefiting from the
increased availability of essential
nutrients. However, because the groups
of organisms in question contain epedet
that are well adapted to infecting and
surviving in their plant hosts. It was
determined necessary to retain these
groups on the list in $ 340.2. It should be
noted that new { 340/1 provides the
825
Fetfera! Register / Vol. 52. No. 115 / Tuesday. June 16. 1987 / Rules and Regulations 2Z80S
procedures for amending the list of
organisms in § 34a2.
The its! in § 340^ is composed of alt
those ^nera or taxa which may contain
organisms that are plant pests. Within
any taxonomic series, the lowest unit of
ctassiHcation actually listed is the group
which is composed of. or includes,
organisms that are regulated. Organisms
belonging to all lower taxa contained
within the group that is listed are
included as organisms which are or may
contain plant pests> if they otherwise
meet the definition of plant pest as
explained above. For example, when the
lowest unit listed of a particular series is
an order, then members of all families,
genera, and species belonging to that
onier are meant to be included as
oigantsms which are or may contain
plant pests, if such organisms meet the
statutory criteria for being a plant pest.
In a second example, if an order is
included on the list, but is followed by a
listing of one or more of the families
belonging to that order, then only the
members (all genera and species) of
those families listed that, meet the
definition of plant pest are intended to
be regulated. Meml»rs of any other
families within that order that are not
listed are not regulated.
// /s crucial to note that an organism
of any genorc or toxa listed in § 340.2 is
significant only when the organism
meets the definition of a plant pest and
two additional conditions are met. The
oiganism must have been modified in
some way through the process of genetic
engineering (as defined in § 340.1). and
there must be the intention to import the
organism, to move the organism
interstate, or to release the organism in
the environment. If an organism is listed
in S 340.2 but does not meet both the
condition of movement or release to the
environment, and of being modified by a
process of genetic engineering, it is not
regulated under Part 34a
Finally, it should be noted that all
other reflations which affect the
importation or movement of an organism
which is a plant pest or could harbor a
plant pest mmain in effect regardless of
the status of the organism under.Part
340. To remind persons of this fact the
following language has been added to
footnote 1.
Under i^laUoRs promulgaled in 7 CKR
“Subpert-NuTfery Stock" a permit is required
for the imponation of certain classes of
nursery stock whether genetically engineered
or not. nms. a person should consult those
regulations prior to the importation of any
nursery stock.
21. Sleveral comments were received
which contained statements that the list
of organisms in $ 340.2 includes groups
which have an incorrect taxonomic
designation or that the list is incomplete
with regard to the Kin^om Monera. In
response to these comments. APHIS
scientists reviewed the list of organisms
and determined that certain changes
were appropriate.
Taxonomy is a dynamic branch of the
biological sciences, and is particularly
so when the oi^anisms being classified
are in taxa or genera that have only
recently been identified. After
crmsulting the current literature, the
following changes are made in the list of
organisms in S 340JL
Prions have been removed from the
list of organisms which are or contain
plant pests in I 340.2. There is no
evidence at the present time that any
prion is associated with a plant pest. All
of the prions identified to date have
been associated with diseases in
animals, if in the future a prion should
be found to be associated with a plant
pester suspected of causing a plant
disease that organism could be added to
the list.
The group of organisms previously
referred to as Rickettsial-like organisms
associated with plant disease are
correctly descrilred as gram-negative
xylem-limited bacteria associated with
plant diseases. Examples of diseases
associated with these pathogens are
Pierce's disease of grape and phony
disease of peach.
Some organisms previously thought lo
be mycop!asma*like organisms (MLO)
are in fact true bacteria and should be
correctly listed as gram-negative
phloem-limited bacteria associated with
plant diseases. Examples of organisms
in this group are the bacteria which are
associated with citrus greening disease
and clover club leaf disease.
Concerning those conunenis that the
list is incomplete. APHIS is conducting a
further examination of the plant pest
status of members of various taxa in the
Kingdom Monera to determine if
additional taxa should be added to the
list or if a more specific and exact listing
can be proposed for members of some of
the genera listed. If APHIS* research
indicates additional taxa should be
included in fi 340.2 or if the list should
be made more speciHc. a document shall
be published in the Federal Register
proposing to add such taxa or otherwise
to revise the list
Items Exempt From Regulation and
Procedures (or Removing Organisms
From the List
22. Thirty-nine comments contained
statements objecting to the inclusion of
various organisms or portions or
constituents of organisms as plant pests.
Many comments contained statements
that various portions (plasmids. DNA
fragments, etc.) of plant pests be
exempted from regulati<m if these
components are "non-pathogenic." Some
comments contained the su^estion that
“disabled*' pathi^ens not be regulated
as plant pests.
In response to these comments.
APHIS has modified the deHnition of
organism so that this definition as
amended now exdudes parts or
components of organisms listed in
§ 340.2. As previously stated, the
definition proposed by APHIS for
organism has been revised, and now
excludes non-living components of
living organisms. The reasons for this
change have been previously explained
in paragraph 11. Any organism
containing these parts or components
ivould be regulated if the parts or
components were incorporated into the
organism through the process of genetic
engineering (as defined in i 340.1).
The movement of killed organisms
that are included in the list of organisms
in S 340.2 is not regulated. The
movement of non-living components
(including, but not limited to. DNA.
RNA. and plasmids) of organisms
included on (he list of organisms in 340.2
is not regulated. However, if certain
components of regulated plant pest
organisms, including DNA and RNA
sequences, organelles, and plasmids
retain their identity and are
incorporated as part of an organism,
then the introduction of this organism
would be regulated under Part 3M. It
was not APHIS* intent to imply that ail
species, biotypes, lines, or races of the
taxa listed in proposed fi 340J2 were
plant pests. For example. Erwinia
carilovoro is a bacterial plant pathogen
causing soft rot diseases. All members
of the genus Erwinio are included in the
list of organisms in § 340.2. If this
organism is modified by the process of
genetic engineering, the modified
bacteria are subject to regulation under
Part 340. If genetically engineered
bacteria of this species are killed, then
the killed cells and/or any parts or
components (including DNA and RNA
sequences) that might be extracted from
them are not subject to relation.
Should any genetic material from these
killed bacteria, including DNA and RNA
or other component as noted at the
beginning of § 340.2. be introduced into
any living organism by the process of
genetic engineering, then that organism
would be subject to regulation under
Part 340.
23. Many comments expressed
concern about die inclusion of certain
organisms as plant pests. In many cases
these organisms are members of a group
containing many plant pests, such as the
826
Federal Regist^ / Vol. 52. No. 115 / Tuesday. }une 1C. 1987 / Rules and Regulations
22 ^
bacleria! genera Pseudomonas,
Xanlhomonas, and Erwinia.
Commenters frequently requested that
specific organisms belonging to these
groups which were believed not to be
plant pests be removed from the list.
Utese requests were based on
conclusions and opinions, rather than
any complete submission of factual
material.
Organisms or groups of organisms ere
(mnsidered to be on the list of organisms
in i 340.2 if they meet die statutory
definition of plant pest. To determine if
a particular species is a plant pest, a
person should consult the scientific
literature or APHIS to determine if the
species has plant pest characteHstics. as
discussed in footnote 4 above.
APHIS recognizes that there may be
instanres when it may be appropriate to
remove siMtcific organisms from the list
because th^ do not ap{Niar to be plant
pests. Provisions for submitting a
petition to remove a ipeciHc oi^anism or
group of organisms from the list are
diacussed in f 340.4. Any person may
submit a petition to remowr an organism
or group of organisms ftma the Ust in
f 340.2. The petition should include full
and factual information supporting the
request for renmval.
Gunmeots on Parouts for tha
latroducdtHi of a Ragulatad Aiticia
C§340J)
Numerous comments were received
on f 340J of the regulations pertaining
to the issuance of a permit for the
introduction of a regulated article. The
comments pertained to: The need for
additional provisions to protect
conndential business infonnation; the
IBOday review period for processing
permit applications: data required in
applications: the need for state
involvement in the review process;
certificate of exemption/courtesy
permits; the need for additional
safeguards to be added to the final rule;
and the standanl permit conditions.
Confidential Business Information
24. One commenter suggested that it
would be beneficial if the regulations
contained speciHc instructions to an
applicant in order to identify and protect
conHdential business information (CBi).
APHIS agrees with the commenter.
and has revised { 340.3(a) of the final
rule to include provisions advii^ing
applicants how CBI should be
designated and submitted. Under
§ 340.3(a) the responsible person should
submit two copies of a permit
application, if there ia information
contained in the application, then each
page of the application containing such
information should be marked **CB!
Copy." In-addttion. those portions of the
application deemed CBI should be so
designated. The second copy of the
application should have ail such CB!
deleted and should be marked on each
page of the application where CBI was
deleted "CBI Deleted.” If an application
does not contain CBI..then the first page
of both copies of the application should
be marked “No CBI.”
APHIS believes that such procedures
wilt readily identify those applications
which contain CBI and will apecificaliy
designate those portions which the
applicant feels must be protected. In
addition, by requiring that an applicant
submit a second copy of an application
with CBI deleted, this will provide
APHIS with a copy of the application
which can be routinely sent to the State
departments of agriculture for their
notification, and review of the
application and to requesting public
interest groups without concern that CBI
data might not be properly safeguarded.
25. Omer comments acknowledged
that the APHIS policy statement on CBI
(See SO FR 38561-38563. September 23.
1 ^) was an important element in
USOA's regulatory program, but that It
ia important that these same procedures
apply equally to any individual outside
of APHIS, at other USOA agencies, that
handle CBI in connection with an APHIS
action.
APHIS a^ees with these commentera.
It should be noted that if CBI la made
available to othn government
employees at other U^A agencies,
such employees are prohibited under the
Trade Secrets Act (18 U.S.C 1905 et
seq.) disclosing such information.
The Trade Secrets Act imposes serious
criminal penalties for violating Its
provisions, and those government
employees handling CBI are aware of
the need to safeguard CBI. In addition,
the USDA is drafting CBI materials
specifically for the O^ice of Agricultural
Biotechnology (OAfi) which is the office
which coordinates biotechnology
research for the Science ami Education
Administration. These CBI materials
will include a "Guide for the Control of
Confidential Business Infonnation
Relating to Proposals for Approval of
Biotechnology Research.” and a
"Commitment to Protect CooHdential
Business Information Form," to be
signed by any person who receives CBI
in an official capacity through the OAB.
1BQ Day Review Period for Processing
Permit Applications
26. Fifty^three comments were
received on the proposed provisions of
the regulations which provided for a 180
day period for the review of permit
applications.
The comments ranged from the
observation that IK) days was “too
long" to more strongly worded
statements that such a delay was
"unreasonable, unacceptable, and
untenable." Approximately half the
commenters (25) on the 180 day review
period suggested a shorter review period
and/or structured review procedures.
One commenter suggested that the
review period should be no longer than
60 days. Other commenters expressed
the view that applications sho^d be
reviewed for their completeness within
45 days, with a final decision being
made in 90 days. The commenters
suggested that for complicated
applmations, there coidd be a provision
for an extmded review of up to 120 days
if the applicant and APHIS agreed.
Most commentere suggested that a 90
day review period would be reasonable
and in accord «vi!h the processing time
for a pre-manufacturing notification
(I^N) submitted to EPA under the
Toxic Substances Control Act
Nearly a quarter of the ccunmenls on
this issue obfected to the foot that in lha
proposed review period. ARHIS did not
distinguish between the diRerent types
of pennits people would be requesting.
These comments expressed the view
that release into the environment and
interetate movement or importation
were separate activities and should be
treated as such. Ona comnrenter
suggested that 14 days would he ■ more
appropriate period for the issuance of a
movement permit.
APHIS agrees with the commentera
that believe the proposed l8&-day
review period should be reduced and
that the review period should vary
according to the type of permit beir^
Issued.
APHIS has adopted a 120-day period,
rather than a fiO-day or PO-day time
period time to review an afiplication for
release into the environment fw two
reasons. First, before APHIS issues a
permit for release, e thorough and
conprebenstve environmental
assessment must be prepared. Because
of the doctrine of "Functional
Equivalency,” the EPA, which by statute
must review a PMN within 90 days from
receipt of a complete PMN. does not
have to prepare an environmental
Assessment during the review period.
APHIS has determined it netressary to
prepare environmental assessments
pursuant to the National Envlronmentai
Policy Act (NEPA) prior to issuance of a
permit for release into the environment.
Therefore. APHIS believes that it needs
1^ days to review a permit application
for environmental release. In the event
an envirrmmentai impact statement
827
Federal Register / VoL 52. No. 115 / Tuesday, |iine 16. 1987
(EIS) has to be prepared, the review
period would be extended. Secondly, the
fmai rule, as revised, provides that
before APHIS issues a pennit for
environmental release it shall submit a
copy of the application for State
notification and r^iew. Because of the
necessity to coordinate and consult with
the State where release shall occur.
APHIS believes it's advisable to allow
for more than a 60-day review period.-
It should be noted that 120 days
would be the maximum time APHIS
would need to review a complete
application for environmental release
that does not involve the preparation of
an EB. and is the period an applicant
should use for piannii^ purposes.
APHIS shall make every attempt to
complete its final review in less toan 120
days. One hundred and twenty days will
also allow APHIS to schedule an
inspection of the site where the release
is to oa:ur prior to the issuance of a
permit, as provided for in new
{ 340.3(dl. It should be further noted that
S 340.3(b} of the final rule is being
revised to indicate that APHIS will
complete its initial review within 30
days of receipt and shall advise the
responsible individual if any additional
tnfonnation is needed within 30 days of
rcMipt of the application.
AfWS disagrees with the commenter
who suggested that a 14-day review
period would be a suHicient period to
l»ocess an appliation for a permit for
interstate movement. As explained in
more detail below, because of the need
to consult with State officials and
possibly to conduct an inspection of (he
contained facility where the regulated
article is to be stored. APHIS has
amended the final rule in % 340.3(b) to
provide for a 60-day review period. For
the review of applications for interstate
movement or importation into a
contained facility, APHIS will, however,
complete its initial review within 15
days of receipt and advise the
responsible individual if additional
information is required. It should also be
noted that 60 days is the maximum time
USDA wilt take to review a complete
pennit application for interstate
movement or importation to a contained
facility and is the period an applicant
should use for planning purposes. In all
possible cases, APHIS will try to
complete its final review in less than 60
days.
Data Required in an Application
27. One commenter noted that a
significant amount of genetic
information is required in advance of
apjHToval of experimentation. The
(»mmenter noted that the level of
documentation required by these
regulations is usually generated as a
result of the research.
As revised, the final rule calls for less
data in an application for a limited
pennit for interstate movement or
importation than imist be submitted in
an application for environmental
release, APHIS believes that the data
that is required for an application for
environmental release should have been
obtained before release is requested,
and can be obtained from the scientific
literature and/or by doing research
within a contained facility.
28. One commenter indicated that
there is no need for APHIS to require
extensive documentation on proposed
experiments after the work has been
approved elsewhere. The commenter
suggested that documentation of other
epprovals. a brief description of the
materials, end a statement of the level
of containment should be enough to
quickly be granted a pennit to receive
cultures that are to be used in a
contained facility.
APHIS believes that the provisions of
the final rule which provide for the
issuance of a limited permit for
interstate movement of a regulated
article into a contained facility address
many of the concerns raised by the
commenter. As revised. APHIS will
issue limited permits for interstate
movement in less time by requiring less
data than a pennit for release into the
environment.
Other commentert argued that the
proposed regulations were too
restrictive as they pertained to the
interstate movement of low risk
genetically engineered organisms. One
commenter indicated that prior approval
should not have to be obtained for the
interstate movement of organisms
shipped between laboratories which
comply with NIK containment
guidelines. The commenter argued that
in such situations a simple notification
to USDA pertaining to the movement of
such organisms would suffice. These
commenters did not present specific
examples of the types of organisms and
under whet conditions certain
organisms would not pose a risk of plant
pest dissemination.
It appears that there are
circumstances under which certain
genetically engineered organisms such
as those employed as ‘'libraries" or
biological containers can be moved
interstate between contained fscilities
under conditions which would not
present a risk of plant pest
dissemination, and for which no permit
would be required. It appears that such
organisms are £ coli K~12 or other
bacterial strains with similar
/ Rules and Regulations 22901
characteristics, containing genetic
material from any plant pest, except
when such genetic material contains
genes which code for: substances toxic
to plants and organisms in the agro-
ecosystem: or substances infiuencing
plant growth: or genes for disease
susceptability: or substances or
characteristics associated with
resistance to pesticides.
Ukewise. a unique synthetic
nucleotide sequence added as a
"marker” for identification of a specific
microorganism, when constructed to not
constitute an open reading frame in any
register, also poses no risk and is
completely benign.
In accordance with notice provisions
of the Administrative Procedure Act.
APHIS intends to publish a proposed
rule in the Federal Register within the
next 30 days whidi would amend Part
340 to include these exclusions.
The fact that APHIS intends to
publish a document which would
propose to make certain chaises to the
final rule, shortly after its publication,
reflects APHIS’ belief that the
regulations should be malleable and
keep pace with the scientific "state of
the art." It is anticipated that the APHIS
regulations will parallel the NIH
Guidelines in the sense that Uiese
regulations will continue to evolve and
be updated as experience is gained and
more information becomes available on
the plant pest risk presented by the
introduction of genetically engineered
organisms. In short. APHIS believes that
when it can be shown that the interstate
movement between contained facilities
of certain organisms does not present a
risk of plant pest introduction or
dissemination, then the regulations
should be amended to exclude such
movement from the permit requirements.
Lastly, to facilitate receipt of current
deta relative to the plant peat status of
certain organisms from outside sources.
APHIS has included the petition inticess
in { 340.4 of the final rule.
Permit Processing Procedures
29. Section 34a3(b} of the final rule is
a new section and is entitled, "Permit
for release into the environment.” If an
application for environmental release is
complete when received. APHIS shall
notify the responsible individual of the
date of receipt of the application for
purposes of advising the applicant when
the 120 day review period commenced.
If an application is not complete. APHIS
will advise the responsible individual
what additional information must be
submitted and shall commence the 120
day review period upon the receipt of
the additional information, assuming the
828
22902 Federat Registef / Vot. 52. No. 115 / Tuesday. June 16. 1967 / Rules and Regulations
additional data requested is adequate.
When it is determined that an
application is complete, APHIS shall
subnut to the State department of
agricultura where the release is planned,
a copy of its initial review and a copy of
the application mariied *'CB! Deleted" or
“No CBI*' for State notiOeation and
review. Pureuant to APHIS’ CBI Policy
Statement of September 23, 1985 (50 FR
38S61--38Se3|, the requirements of
Section Vlil(b} must be complied with
by a State prior to disclosure by APHIS
to the State of CBI material. This section
requires that the request be for an
official puipose; that the requester have
security procedures equivalent to those
of APHIS: and that the person
submitting dte matenal determined by
APHIS to be CBI be notiffed of the
request prior to any disclosure.
An appiicatimi for release into the
environment must include the
information required by $ 340.3(bK3}~
(14). These are the same 14 data
eienmnts that appeared in the proposed
r^ulations under $ 340.3(a}.
30. Section 340.3(c) of the final rule is
a new section and is entitled. “Umited
permits for the interstate movement or
importation of a regulated article.’' This
section provides for a 80 day review
period with an initial review being
performed by APHIS vrithin 15 days of
receipt of an application, like an
ap^eation for r^easa into the
mwrmunmit. if an application is
incomplete and additional information
must requested. APHIS will
commence the 60 day review period
upcm receipt of the additional
isfoimation. SacUrni 340.3(c) of the final
rule also provides that when AWIS
determines that an application is
complete. AI^IS shall submit a copy of
its initial review and the "CBI Deleted ’
or “No CBI” copy of the application to
tha State department of agriculture
located in the State of destination of the
regulated article, for State notiHcation
ai^ review of the application.
State Involvement in the Review
Process
31. Several comments were received
from Slate departments of agriculture
concerning the need for State
involvement and participation when
APHIS is deciding whether to issue a
permit for release into the environment.
A comment from the State of New
Mexico indicated that notification of the
State where release will be
accomplished is necessary to minimize
last minute complications. The State of
California indicated that it has
regulations that mandate certain review
procedures prior to the release of certain
genetically engineered organisms into
the environment, and that APHIS’
permit application for the introducUon
of genetically engineered organisms
contains no provisions for State
recommendations on the application.
The State of North Carolina further
indicated that the Slate where a person
intends to release a regulated article
should be given an opportunity to
review the application, and that the
State should be notiffed of any
exemptions that may be granted, or if a
permit is withdrawn.
APHIS agrees with these commenters
that State notification and review of an
application for the introduction of a
regulated article is essential. To ensure
that the affected State has been notiffed
and has an opportunity to review a
penmii application for release or
interstate movement or importation.
APHIS has modified ii 340.3(b) and (c)
to include provisions that call for State
notification and review of a permit
application. These provisions which
ensure Slate involvement and
participation in the permitting process
for genetically engineered organisms is
totally consistent with existing
procedures for the issuance of a permit
for the movement of plant pests under 7
CFR 330.200. It is envision^ that State
regulatory officials «vill play a
significant role in providing site specific
and other environmanlal and ecological
data on the iocationwhere a genetically
engineered organism is to be released,
and otherwise assist in the enforcement
of the Federal regulations, on a
cooperative basis.
Provisions foe the Issuance of a Single
Permit for Multiple Interstate
Movements
32. New i 340.3(cKl) provides that the
responsible person may apply for a
single limited permit that would be valid
for the interstate movement of multiple
regulated articlea moving between
contained facilities in lieu of having to
submit an application for each
individual interstate movement. Such a
limited permit for interstate movement
would be valid for one year from the
date of issuance. The purpose of this
provision is to eliminate the need for a
person to have to go to APHIS for
approval each time the person proposes
to ship a regulated article, when this
information can be made available to
APHIS in advance of the shipments, all
at one time. APHIS has added
provisions allowing for multiple
shipments to multiple locations under a
single limited permit in response to
comments that it would be too
burdensome to require a person to
submit a new application for each new
shipment. New i 340.3(c)(1) further
provides that a limited permit for
interstate movement of a regulated
article shall only be valid for the
movement of those regulated articles
moving between those locations
specified in the applicaiimi. If a person
seeks to move related articles other
than those speciffed in the apj^ieatton or
to locations other than those apedned in
the application, a supplemental
application must be submitted to APHIS.
Action 340.3(c)(1) of the Rnal role
further provides that the responsible
person sMpping a reguiati^ article
intentate shall keep records for one
yesw^dononstratii^ that the regulated
article readied its intended destination.
The pilose of this requirement is for
the shipper of the regulated article and
APHIS to be able to verify that the
regulated article, in fact, reached Us
intended destination, and to provide the
capacity to trace a regulated artide in
the event it is deiive^ to the wrong
location. This provision can be satisfied
when using the mail by sending a
regulated article, “certified mail, return
receipt requested.” or by using a carrier
that requires the «msi^ee rign for the
delivery. If a person does not use the
mail or a carrier to deliver a regulated
article, then the consignee shcmld keep e
log of when the regulated artide it
received, and a duplicate copy of the
should be maintained by the responstl^
individual. This section also requires
that no person move a regulated artide
inlersiate unless (he number of the
limited permit appears on the outside of
the shipping container.
A person must submit data required
by »340.3(b) (1). (2). (4). (6). (7). (9). and
(U>14) in an application for a permit for
multiple interstate movements. This Is
the same information that would have to
be submitted in an application for a
limited peimil for a single interstate
movement. This data would provide
APHIS with necessary information
about the nature of the reflated
artide(s). the method of movement, and
how it shall be contained during
movement and at the article's
destinationls). Such information will
enable APHIS to decide wheti»r or not
a permit can be issued. If a permit is
issued, such data will be used in
determining what conditions, if any,
should be imposed as part of the permit
to eiiminate or reduce the possibility of
dissemination of a plant pest.
limited Permits for Importatton
33. New $ 340.3(c)(2) of the final rule
provider that the responsible person
sreking a permit for the importation of a
regulated article to a contained facility
must submit an application for a permit
829
Federal Register / Vol. 52. No. 115 / Tuesday. ]une 16. 1987 / Rules and Regulations 2MQ3
at least 60 days prior to the importation
of each shipment of regulated articles.
Unlike a limited permit for interstate
movement APHIS is requiring that a
person submit a separate application for
each importation of regulated articles
rather than issuing a “single” permit for
importation that would be valid for
multiple importations for a specified
period.
APHIS has P-aditionaliy allowed
persons moving regulated articles
interstate to do so repeatedly under the
provisions of a single limited permit, for
movement to specified destinations for
utilization or processing. Such a system
would not be practicable for the
importation of regulated articles
because the entry status of many
imported artmles frequently changes
depending on the plant peat status of the
article's country of origin. Because the
entry status of a regulated article is
subject to change. APHIS needs to
review each permit application for
importation to importation so that
a decisirm whether to allow importation
can be made on a (^se-by^case basis.
APHIS antmipates that in many cases,
a request for the renewal of a limited
permit for importation can be processed
in less than 60 days. APHIS has added
the foUotring new footnote 7 to ( 340.3
(gH 21 to relict this fact
Reaawals may receive shorter review. In
tile case ^aicnewal for a limited permit for
iapntatioB that was isaoed less then one
year earlier, AMIS will notify the
responsible person wititin IS days that either;
(11 The renewil permit is approved or (2) that
■ 00 day teriew period is necessary because
Ute conditions of the origirul permit have
changed
APHIS is also requiring that the
responsible person importing a
regulated article keep records for one
year that demonstrate that the regulated
article arrived at its intended
destination. The one year ftcordkeeping
requirement is c^msistent with the
reoirdkeepir^ requirement for limited
permits for interstate movement. A
person must submit data required by
SS 340.3(bKJl.(2).(4M6M7).C9). and (11)-
(14) in an application ficn a limited
permit for importation. Hiis is the same
data that must be submitted in an
application for a limited permit to move
a regulated article interstate. APHIS
believes that such data will enable it to
properly evaluate the risk of allowing
the reg^ated article to be imported. This
data will provide APHIS with necessary
information about the country of origin
of the regulated article, the nature of the
regulated article, the method of
movement, and how it shall be
contained during movement and at its
final destination. As with limited
permits for interstate movement,
because the regulated article is moving
under containment into a contained
facility. APHIS is requiring that the
same data be subnutted in an
application to imp<»t the regulated
article as is required in an application
for interstate movement.
Certificate of Exemption/Courtesy
Permits
34. Six comments were received on
S 340.4 of the proposed regulation
entitled. “Certificate of Exemption."
Several commenters suggested that the
term “exemption” it not appropriate
because it implies that APHIS is
exempting the introduction of a
regulated organisms from the provisions
of the regidation. ratiier than providing
an indication that the organism was
never subject to the regulation to begin
with. These commenters suggested that
the appropriate name for such a
document should be a “cou rtesy
permit.” as found in 7 CFR 330.208. One
commenter suggested that a certificate
of exemption be issued in situations
where a regulated article is biologically
contained.
APHIS agrees with commenters that
argued the name “certificate of
exemption” is a misnomer, and has
changed the name of the document that
will be issued to “courtesy permit.”
AI^IIS will issue a courtesy permit
under the same circumstances thot were
proposed for the issuance of a
“certificate of exemption.” i.e.. the
organism was never subject to
regulation under Part 340. but is similar
to other organisms regulated under Part
340.
APHIS also added new $ 340.3(h)(3)
which indicates that a courtesy permit
will be issued within 60 days from the
receipt of a complete application, or the
applicant will be advised that a pennit
is required under fi 340.3(b) or (c).
APHIS wll conduct its initial review of
a courtesy pennit application witiun 25
days of receipt of a complete application
and advise the applicant within tlds
period If any additional Information is
required. It should be noted that 60 days
is the maximum time it will take for the
issuance of a courtesy permit and that
every effort will be made to issue sudi
peimits in less than 60 days.
Sin^ courtesy permits are issued for
organisms which are not n^ulated
articles, the issue of containment
whether biological or ph:^ical is not
material.
35. One commenter believed that a
penon would be required to obtain a
“certificate of exemption” (now courtesy
permit) when orgamsms ate pnxluced
through classical genetics.
AMS wishes to stress that a
courtesy permit is an option that an
applicant may seek if It believes that
such a peimit would facilitate the
movement of an organism throu^ a
USDA port of entry, because the
movement might otherwise be impeded
because of its similarity to a regulated
article.
Lastly, one commenter suggested that
a certificate of exemption should be
extended to those genetically
engineered organisms otherwise subject
to regulation under Part 340, that can be
documented not to be plant pests.
In such cases. APHIS woidd issue a
permit without conditims (restrictions)
for the introduction of the regulated
article.
The preceding discussion on APHIS
permits can be summarized as follows:
APHIS Permits for the iNTROoucnoN of a Regulated Article*
of pem^
Application elements
USOA review period
USDAacthxi
Stale noWleation
ar«d review required
120 days (maximum time
from rec^i of complete
^t^tion;> initial review
within 30 days).
60 days (manmum time from
receipt of complete appti-
catiorr; review wrthin
15 days).
issue pem^ wim omditions:
retHiest addition^ data: or
de^ permft with re»tns.
5340.3(b) (1). (2). (4). (6).
(7). (9). {11W14).
Yes.
Movement or Intonation
into a ContaineO Faci^ty.
830
2890i Fedetai Register / Vol. 52. No. 115 / Tuesday, June 16. 1987 / Rules an.d Regulations
APHIS PERMrrs for the iNTRODUcncm of a Reqlrat^ AfrnOLE‘»Cmtinueci
Type of permit
AppScabon elements
USOA review period
USDA action
State notWeaBon
arid revieir requited
Courtesy f^rmit* (not re-
quired; may be sou^ at
the option of an applicant;
organism not a regiSated
articie).
§ 340.3(b) (1). (2). (5). (7)
and statwnent why not a
regulated article.
60 days with inki^ review
within ts days.
Issue courtly permit; re-
quest additionai d^ or
advise appliewtt mat ai>
oOier permit is requeed.
No (if courtesy
pwiMissu^
Yes (H another
permit issued
' Tlw t20 day review penod would be exrended if preparation of an enviroimentaJ Impact statem^ was requved.
Need for Additional Safeguards
38. Three cominents were received on
the need for additional safeguards to be
added to the rule. Chie commenter
indicated that the proposed regulations
did not cont ain t he safeguards already
present in 7 CFR 330.202(b] applicable to
the movement of plant pests. The
commenter noted such provisions allows
USDA to inspect at its discretion, any
site or f»emises prior to the issuance of
a pemiit to determine the adequacy of
the site or premisn for purposes of
ointainment.
APHIS agrees with the crunmenter
and believes that the final rule should
omtain inovisions giving APHIS the
option to conduct a site or premises
inspection prior to the issuance of a
fMmnit. Aaardingly. APHIS has added
new I 340.3(d] entitled, “Premises
Inspection.” which is consistent with 7
33(U02(b) of Its existing plant pest
regulations. Swtion 340J(d] provides
that an inspector may inspect the site or
facility where regulated articles are
proposed to be released or contained
under permit.
This section further provides that
failure to allow the inspection of a
premises prior to the Issuance of an
environmental release or limited permit
shall be grounded for the denial of the
permit.
37. Other commenters suggested that
USDA publish guidelines for academic
investigators that would be useful in
determining what constitutes a
path^enic or environmental hazard,
and recommendations for
commen»iraie containment levels. One
commenter further suggested that
APHIS publish a laboratory safety
mono^aph which addresses feasible
greenhouse containment, and
construction and utilization of growth
chambers. Another commenter
suggested that USOA include in its
regulations minimal safety precautions
for biotechnology research. The
commenter further noted that not ail
personnel have the desirable (raining in
anti-contamination and containment
techniques.
APHIS believes that it would be
beyond the scope of the regulations to
include minimal safety precautions for
biotechnology research. These
comments pertain to worker safety and
do not address the issue of plant pest
dissemination and establishment
An-IIS believes that such information
should be made available by other
Federal agencies whose responsibility is
to regulate Federally funded research or
worker safety, e.gM the National
Institutes of Health, the Science and
Education Administration of USDA, or
the Occupational Safety and Health
Administration (OSHA).
For reasons discussed in paragraph
17, APHIS does not believe the issuance
of a monograph for greenhouse
containment is appropriate because of
the need to make such determinations
on a case-by-case lusis.
Standard Permit Conditions
38. Several commenters objected to
the wording of some of the standard
permit conditions. These commenten
argued that the phrase “as determined
necessary by the Deputy Administrator”
is vague and open-ended.
In an attempt to provide more
specificity to the standard permit
conditions. APHIS has moved the
phrase “as determined necessary by the
Deputy Administrator*’ from the
conditions in H 340.3(1) U) and (2) and
has inserted the phrase, “in a manner so
as to prevent the establishment and
dissemination of plant pests.” APHIS
believes this change makes these
conditions more spectHc.
Sections 940.3(f) (7) and (8) still retain
the phrase, "as determined necessary by
(he Deputy Administrator.” The
language in § 34a3(7) gives APHIS the
authority to specify in a permit any
special conditions that might be deemed
necessary to ensure the regulated article
will not be accidentally released or that
there will not be an unauthorized
release. APHIS believes that such
determinations can only be made on a
case-by-case basis, and that retention of
this phrase gives APHIS the Hexibilily
need to ensure against an accidental or
unauthorized released of the regulated
article.
Section 340.3(f)(8) provides diat a
regulated article shall be subject to the
application of remedial measures
(including disposal) detennined by the
Deputy Administrator to be necessary to
prevent the spread of plant pests. Su^
authority would only be exercised in the
event an accidental release of the
regulated article, and gives AI^IS the
necessary authority to prevrat the
dissemination of plant pests. Such
emergency autitority is fotmd In 7 US.C.
ISOdd of the FPPA.
APHIS has revised f 340.^f)(9) to now
read, “a penon who has been issued e
pennit shall submit to Ilant Protection
and Quarantine monitoring reports on
the performance charactmistia of the
regulated article in acc(»dance vrith any
monitoring reporting requirernema that
may be speciHed in a pennit This
condition previously speciHed that such
reports would have to be submitted, “at
deemed necessary by the Deputy
Administrator.” The decision to require
the submission of monitoring reports
will be made on a case-by-case basis,
and will depend on the nature of the
regulated article. Monitoring reports will
not be required of all permittees.
39. Six commenters objected to the
lime periods for reporting specified
events to APHIS (I.e.. unautiionzed
release (24 hours}), characteristics
substantially different from those in an
application (5 working days), am) death
of the regulated article (S working da^).
Several commenters also objected to
having to report the death of the
regulated article, believing that death is
not an unusual occurrence. One
commenter objected to the fact that oral
notification was required immediately,
and. in every case, followed by the
submission of written notification, in
response to these comments. APHIS has
made the following chanj^s to the
reporting requirements in i 340.3(f)(10).
Oral reporting to AI^IS Is now only
required in the event of any acmdenta!
or unauthorized release. Because of the
potential consequences of such an
event. APHIS believes that such
831
Fcdgtal / VoK 52 . No. 115 / Tuesday. |une 16 . 1987 / Rules and ttegulations 22905
occufTence must be orally reported,
immediately upon discovery, and in
writing within 24 hours. If immediate
oral notification is impossible, then
reporting should occur on the first
workti^ day after discovery of the
release. APHIS has eliminated the
requirement of oral notification for all
reportable events other than
unauthorized or accidental release.
40. One commenter suggested that the
rule should vary the time within ‘which
an accidental or unauthorized release
must be reported, depending on the
nature of the regulated article-
while not all regulated articles
present the same risk of plant pest
dissemination. APHIS believes that in
the event of an imauthorized or
accidental release, it needs to know
about such events as quickly as possible
and that reporting times should be
uniform f24 hours} i^ardless of the
nature of the regulated article.
41. In response to several comments.
APHIS has eliminated the requirement
of having to report the death of a
regulated article in proposed
f 310.3(cKl0)(tii|. Under i m3(fKl0){ii)
of the final rule, a person need only
report in writii^. as soon as po.<isible.
but not later than 5 working days, if the
regulated article or associated host
organism is found to have
characteristics substantially different
from those listed in the permit
application or suffers any unusual
occurrence (excessive mortality or
morbidity or an unanticipated effect on
iton*1arget organisms). APHIS believes
that the death of a regulated article, as
discussed above, should not be a
reportable event
APHIS believes that, as modified,
having to report excessive mortality or
morbidity or an unanticipated effect on
a non-tnrget organism as soon as
possible but not later than S working
days, is a reasonable requirement
APHIS believes that this requirement
will advise the Agency of any disease or
pest that may be of signiricance.
It should be noted that APHIS has
added the phrase “as soon as possible"
to clarify the agency's intent that the
reporting should be prompt. However.
APHIS has not changed the requirement
which appeared in the proposed
regulations that the reporting must not
occur later than 5 working days from the
observance of such events.
Denial of a I^rniit
APHIS, to fully inform permittees of
heir appeal rights, has included
>rovisions in H 340.3(eJ and (a) which
jrovide appeal provisions in the event a
>«miif is denied.
Petition To Amend the List of Organisms
(§ 340 . 4 )
42. Several commenters suggested that
USDA should include a mechanism
which would allow persons to petition
for the “delisting” or removal of
organisms fro.m the list of organisms in
$ 340.2 of the final rule, if it could tie
demoiistrated that such organisms are
not plant pests. Other commenters
indicated that USO.^ should include a
mechanism that would allow n person to
seek the addition of organisms to the
list, if it could be shown that such
organisms were plant pests.
USDA agrees with the commcnlcrs
and has added a new S 340.4 to the Hnal
rule, entitled “Petition to Amend the List
of Organisms.** USDA beltuves that the
petition mechanism will afford
interested persons the opportunity to
readily bring information to USDA’s
attention, as new information becomes
available about existing or newly
discovered organisms. The petition
process in § 340.4 is in accord with
section 4(c) of the Administrative
Procedure Act (3 U.S-C. 553(6)1 for the
issuance, amendment, or repeal of a rule
and with USDA’s Departmental
Piocredings in 7 CFR 1 . 28 .
Under $ 34n.4(a] of the final rule, any
person may submit a petition to the
Deputy Administrolor of Plant
Proiection and Quarantine to amend the
list or organisms in S 340.2 by adding or
removing any genus, species, or
subspecies. Section 340.4(a) further
provides that a petitioner may
supphnnrnt. amend, or withdraw a
petition, in writing, without prior
approval of the Deputy Administrator
and without prejudice to resuhmissinn
at any time, until the Deputy
Administrator rules on the petition.
Section 340.4(b) specifics the
submixsiun procedures and fo.-mat of a
petition. Ifus section requires that a
petitioner provide two copies of a
petition to the Deputy Administrator in
care of the Director nf the Biotechnology
and Environmental Coordination Staff.
Section 340.4(h) also apeciiies what
must be included in the “Statement of
Grounds'* of the petition. A person must
include a full statement explaining the
factual grounds why the genus, species,
or subspecie-s to be added to § 340.2 is a
plant pest or why there is reason to
believe the gemts. species, or subspecies
is a plant pest. In the case of a petition
to remove e genus, species, or
suhrpccies from the list, a person mn.st
include a full statement explaining why
the genus, species, or subspecies is not a
plant pest or why there is no reason to
believe the genus, soecics. or subspecies
is not a plant pest. The petition should
include copies of scientific literature
which the petition is relying upon,
copies of unpublished studies, or date
from tests performed. Because the
petition and any accompanying data
will be made available for public
inspection, the petition should not
include trade secret or confidential
business information.
A pcTiion must also include in the
"Statement of Grounds” reprp.«ientative
information known to the petitioner
which would be unfavorable to a
petition to add or remove organisms.
Section 340.4(b} also requires that a
petitioner sign a short certification that
must he included as part of the petition.
Section ?4n.4(c} specifies the
administrative action that will be taken
on a petition. Under $ 340.4(c). a petition
which appears to be complete will be
filed by the Director of the
Btoiechnblogy and Envirotimental
Coordination Staff, stamped with the
date of filing, and as.stg 2 ted a docket
number, "nic Director of the
Biotechnology and Environmental
Coordination Staff will notify the
petitioner in writing of the filing and the
docket number of the petition. If a
petition is incomplete, the petitioner
shall be sent a notice indicating how the
petition is deficient.
After a complete petition is Hied.
USDA shall publish a proposal in the
Federal Register to amend & 3M.2 and
soliciting comments thereon from the
public. Any written comments submitted
shall become part of the docket file. The
Deputy Administrator shall furnish a
written response to each petitioner
within 1 B 0 days nf the receipt of the
petition. The decision shall he placed in
the public docket file in the offices of the
Biotechnology and Environmental
Coordination Stuff.
The response will either ft} Approve
the petition in whole or in pert, in which
case the Deputy Administrator shall
concurrently take appropriate action
(publication of a document in the
Federal Register amending S 340.2 of
this part): or (2) deny t.he petition in
whole or in part.
APHIS has chosen 18Q days as the
lime period in whirh to respond to a
petition for the follnwing reasons: (1) A
180 day review period would provide
APHIS reviewers sufficient time to
perform thorough and comprehensive
research on the materiai presented in a
petition and to consult with other
scientists at other institutions both
domrsiically and internationaily; (2) a
180 day review period provides APHIS
with sufficicnl time to schedule public
hearings during the petition process
should that be necessary, and (3) a 180
832
22906 Federal Registw / Vol. SZ, No. It5 / Tuesday. |une 16. 1987 / Rules and Regulations
day review period >$ con«istent with the
petition procedures utilised by other
Federal agencies, namely, the Food and
Drug Administration in their regulations
In 2i CFR 10.30.
CoiJtamer Requirements (§ 340.6)
43. Eight comments were received on
the proposed container requirements in
S 340.6 of the regulations. The
commenters generally expressed the
view that the container requirements
were overly stringent and too restrictive,
or in other cases inappropriate.
One commenter indicated that to
assume that an C’^anism is dangerous
simply because it has been genetically
modified is not fustiHcd. Another
commenter indicated that in certain
instances one may wish to carry plant
seedlings a short distance across a Stale
line in an open flat in a car. Tlte
commenter further indicated that in such
an instance, there would be essentially
no chance of dispersal of the plant since
it would be devoid of any reproductive
parts, and presumably all plant parts
could be collected and aconmted for in
case of an accident.
USDA disagrees with the oimment
that a presumption exists that an
organism is dangerous because it hos
biren genetically modified. Consistent
with stated USOA policy, the final rule
does not regulate sn organism because
of the process by udiich it is modified.
l^DA believes that if a person it
seeking to introduce an organism that Is
engineered from organisms which are
known plant pests, then certain
precautions sre necessary. One
precaution that must be taken is that
until the plant pest status of the
organism is established, special
container requirements are required.
The container requirements set forth in
the final rule are no more stringent than
what would be required for the
movement of plant pests under permit in
7 CFR 330.200. However. USDA agrees
with the commenter that argued that for
certain organisms and in certain
instances the container requirements
may be inippropria'.e due to unique
circumstances (the volume, nature, or
life stage of the regulated article|.
In order to remedy this situation on a
case*by-case basis. APHIS has included
a procedure whereby a person seeking
to move a regulated article may seek a
variance from the container
requirements if the responsible
individual believes the container
requirements are inappropriate.
Section 34ae(b} of the final rule
entitled. "Request for a variance from
(mntainer requirements" provides that a
person may submit a short statement
describing why the applicable container
requirements are inappropriate for the
regulated article to be moved and what
the individual would use in lieu thereof.
USDA shall advise the responsible
individual in writit^ at the time a pennit
is granted cr. the ii^tvtdual's request for
a variance.
Cost of Preparing a Pennit Application
Twenty comments were received on
the APHIS analysis made pursuant to
EO. 12^1 on the economic impact of
the regulations. APHIS stated that it
anticipated the cost of preparing a
permit application to be not greater than
SS.OOO per application. Many of these
commenters erroneously interpreted the
statement to mean the APHIS would
charge applicants not more than S5.000
as the fee for processing permit
applications.
APHIS wishes to explain the $5,000
represented the maximum in-housc cost
to an applicant of submitting an
application for a permit to APHIS. The
$5,000 estimated cost was based on the
salary of a Fh.D. researoher earning
$00,000 per year. It was estimated that it
would take approximately two weeks to
prepare an application. The S5.000 figure
also includes the cost of cleric.'il support
and reproduction costs. With the
exception of rcproduslion and postage
ot handling costs, these costs are
ordinary aulary costs that must be paid
regardless of whether a perun is
submitting a permit application to
APHIS. Five thousand doilan for the
most p.irt represents the upper limit of
the tn-hnuse costs. APHIS believes that
in m.'iny cases, the cost will be
significantly less than $5,000. It should
be noted that one producer of
genetically engineered organisms
indicated that theSS.000 figure was
accurate based on the cost of submitting
an application for the field testing of a
genetically engineered organism.
It should be further noted that under
the final rule the SS^X)0 Hgure is only
applicable to the cokt of preparing an
application for a permit for release into
the environment. An application for a
limited permit for the interstate
movement or importation of a regulated
article into a contained facility requires
the submission of less data, and the time
and cost required to prepare such an
application should be less than $5,000.
Comments Concerning |omt lurisdiction
Several comments were received on
the issue of overlapping lurisdiction
between USDA and EPA. Dual or
redundant reviewa of the same organism
or product were mentioned as an
unwelcome possibility.
During the months since the
"Coordinated Framework" was first
published as a proposed policy by the
OSTP and Federal agencies in Deirember
1S84 {49 FR 50856-50907} the
components of EPA and USDA that
have jurisdiction in the same area have
been in communication on a regular
basis. USDA through its Biotechnology
and Environmental Coordination Staff
and EPA through its Office of Toxic
Substances and Office of Pesticide
Programs have identified principal
liaisons who have the responsibility to
share information, coordinate data
requests, and keep one another informed
of communications with submitters.
These individuals will ensure that data
requests are not duplicated.
Compliance With the National
Environmental Policy Act
APHIS indicated i:i its proposed
regulations at 51 FR 23359 on june 2^.
19B6. that the issuance of ail permits for
the introduction of a genetically
engineered organism would be in
accordance with National
Environmental Policy Act (NEPA).
USDA regulations, and APHIS
Guidelines implementing NEP.A.
APHIS shall prepare environmental
assessments and. where necessary,
environmental impact statements prior
lo issuing a permit for the release into
the environment of a regulated artlcie.
The D.C. Circuit's decision in FETy,
Heckier. stated that "NEPA requires an
agency to evaluate the environmental
effects of its action at the point of
commitment." 756 r2d 143 (O.C Cir.
19851 With regard to this Tmai rule. *
APHIS has concluded that the "point of
commitment" occurs when the agency
takvs action on each individual
application to issue a permit for the
release into the environment of a
genciiesliy engineered organism.
The final rule does not imvocably
commit APHIS to any decisiem
concerning issuance of any permits for
release. APHIS retains the authority to
grant or deny a permit for release on a
case by case basis. However. AI^IS
has prepared a special environmental
assessment on the effect of these
regulations.
The special environmental assessment
for the final rule discusses alternatives
that were considered in Heu of
promulgation of this rule and is
available from the person listed under
"FOR FURTHER INFORMATION
COf^ACT."
Editorial Changes
APHIS has also made minor editorial
changes, where necessary.
833
Federal Register / Vo!. 52. No. 115 / Tucr^ay. )une 16. 1987 / Rules and Regulations
Executive Older 32291 end Regulatory
Fioxibiiity Act
This final rule is issued in
rc-nformance with Executive Order
\ZZ9Ti and has been determined to be net
a "major rule." R^sed on tnformation
compiled by the Departmen!. it has been
determined that the proposed rule will
not have a significant effect on the
economy: will not cause a major
increase in costs cr prices for
consumers, individur.1 industries.
Federal. State, or locc! government
. agencies, or geographic regions: and
would not have a significant adverse
effect on competition, employment,
Investment, pmductivity, innovation, or
on the ability of United States*based
enterprises to compete with fortign*
based enterprises in domestic or export
markets.
As explained above, r^ulations
regulate the introduction (importation,
interstate movement, and release into
the environment) of organisms and
products altered or p^uced through
genetic er^eering which are plant
pusts or whidi there is reason to believe
are plant pests. Such organisms and
products are deemed regulated articles
for which cither a limited or
environmental release permit would
have to be obtained prior to its
introduction.
it is anticipated that the cost of
preparing a p«mii application for the
release into the environment of a
regulated article will be no more than
$5.00 per application. The cost of
preparing an apf^ication for a limited
permit vraich requires less data than an
environmental release permit should be
less than SS.OOO. The required
information about the organism, and the
way it was altered or pr^uced should
be available from documents pertaining
to the rrseardi and development of the
regulated article. Thus, a person seeking
to obtain a permit should not have to
generate any new data, but rather
submit to APHIS, what should be,
existing data. The $5,000 estimated cost
is based on the salaries of a PhD.
researcher and the necessary clerical
staff wodcing for approMinately 2 weeks
in preparing an application for a permit
for environmental release. During the
first year, the Department does not
expect to receive more than SO
applications for release into the
environment. Most other costs
associated with complying with the
regulations, e.g.. container requirements,
arc merely Incidental to a person
complying with sound laboratory and
research practices. Ihe only other costs
assodsted with complying with the
regulations would anse if a
supplemental report WMtt required, e.g..
an accidental or unauthorized release of
a regulated article, the regulated article
is found to have sul»tantiaHy different
characteristics than those listed in (he
application, or if APHIS otherwise
believes .monttnring reports are required.
It «$ iintidpatcd that tire cost of such
ri’ports in most instances would be
minimal.
APHIS is requiring that an application
for a permit be submitted 120 daj's prior
to the time a person seeks to release a
regulated article into the environment.
APHIS believes Ihet the 320 day time
period required to process a permit
application will not be an unreasonable
delay in the marketii^of organisms or
products subject to regulations under
Part 340. it is anticipated that if USDA
receives only 50 applications the first
year for tjie release into the
envirenmerd. the average time to
process any application will be
considerably less than the maximum
processing periods of 120 days. Al^flS
doea not Mieve that the applications
will come all at once. In the short term,
we anticipate receiving 50 applications
the first year, growing to pe^apa 3,000
by 1989. The experience gained during
the fvst year should help expedite the
review of future applications. As more
applications are processed, timrter
review times could be achieved through
the use of data previously submitted.
^nce the timing of when to submit an
application to USDA is left to an
applicant, USDA believes that both
large and small business entities will be
able to incorporate (he review period
into their planning process so as not to
disrupt the mntketing of organisms or
products that are snbiect to regulation.
Under the circumstances referred to
above, the Administrator of the Animal
and Plant Health Inspection Service has
determined that this action v;ould not
have a sigriificant economic impact on a
substantial number of small entities.
Papcrwotic Reduction Act
Information collection requirements
contained in this document have been
approved by the Office of Management
and Budget (OMD) under the provisions
of the Poperworii Reduction Act (44
U.S.C. 3501 et seq.) and have been
assigned OMB control number 057^
0085.
Executive Order 12372
This program/activity Is listed in the
Catalog of Federal Domestic Assistance
under No. 10.025 and is subject to the
provisions of Executive Order 12372
whidi requires intergovernmental
consultation with State and local
22907
officials. (See 7 CFR Pari 3015. Subpart
V.)
list of Sub/er.ts
7 CFR Pan 330
Customs duties and inspection.
Garbage. Imports, Plant diseases. Plant
pests. Plants (Agriculture). Quarantine.
Soil Stone and quarry products.
Transportation.
7 CFR Pari 340
As^culturai commodities.
Biotechnology. Genetic er^neering.
Plant diseases. Plant pests. Plants
(Agriculture). Quarantine.
Transportation.
PART 330->FE0ERAL PUNT PEST
REGUUTiONSt GENERAL; PLANT
PESTS; SOIL, STONE AND QUARRY
PRODUCTS; GARBAGE
Accordingly, 7 CFR Part 330 is
amended to read as follows:
1. The authority citation fm* 7 CFR Part
330 is revised to read as foitows:
Authority: 7 U.&C 147*. 150bb. ISOdd-
ISOff. 161. 162. 45& 2260; 16 U.S.C. 21
VS.C. ni. «4a: 31 U.S.C. 9701; 7 CFR 2.17.
2.51. Bnd 371.2{c}.
2. Paragraph (h) % 330.100 is revised to
read aa follows:
$330,100 OefMtlOM.
(h)(1) P/onfpesL Except for If 330JZ00
through 330.212. "Plant Pest" means any
living stage of any insects, mites,
nematodes, slugs, snails, protozoa, or
other invertebrate animals, bacteria,
fungi, other parasitic plants or
reproductive parts thereof, viruses, or
any organisms similar to or allied with
any of the foregoing, or any infectious
substances which can directly or
indirectly infure or cause disease or
damage In any plants or parts thereof, or
any processed manufactured, or other
pr^ucte of plants.
( 2 ) Plant pest. For purposes of
If 330200 through 330.212. "Plent Pest"
means any living stage of insects, mites,
nematodes, slugs, snails, protozoa, or
other invertebrate animals, bact^.
fungi, other parasitic plants or
reproductive parts tlrereof. viruses, or
any organisms similar to or allied with
any of the foregoing, or any infectious
substances of tiie aforementioned whidi
are not geneticaSy engineered as
defined in 7 CFR 340.1 which can
directly or indirectly injure or cause
disease or damage in any idants or parts
thereof. any processed manufactured
or other products of plants.
834
22908 Federal Register / Vol. S2. No. 115 / Tyeiday. June 16. 1987 / Rules and Regulations
Accordingly. 7 CFR. Chapter 1!!. is
amended by adding Part 340 to read as
follows:
PART 340— INTRODUCTION OF
ORGANISMS AND PRODUCTS
ALTERED OR PRODUCED THROUGH
GENEnC ENGINEERING WHICH ARE
PUNT PESTS OR WHICH THERE IS
REASON TO BEUEVE ARE PUNT
PESTS
Sw.
940.0 Restrictions on the introduction of
regulated articles.
340.1 Definitions.
340.2 Groups of organisms whiiA ere or
contain plant peals.
340J Permits for the introduction of a
regdated article.
340.4 Petition to amend the list of
organisms.
340.5 Marking and identity.
340.6 Container requirements for the
movement of regelated articles.
340.7 Cost and charges.
Anlbmitr- 7 U.S.C. iSOae-ISOH, 151-167.
18^; 31 U.S.C. 9701: 7 CFR 2.17. 2.51. and
37J4KC}.
$3404) Reatrictlomionthehiooduefionef
revoiatod aiUtdea.
(a) No person shall introduce any
regulated article unless: (1) Such
introduction is authorized by a permit;
and (2] such Introduction is In
conforml^ with all of the other
ai^licabie restrictions in this part.'
(b) Any regulated article introduced
not In compliance with the requirements
of this part shall be subject to the
inunedtate application of such remedial
measures or safeguards as an inspector
determines necessary to prevent the
introduction of such plant pesta.*
' Fait 3«0 rcgutatM Ih* intradiKDoa «f «resni«tM
thend or pnxluoBd ihrou^ StnsUc «Rtin«enn| and
thair prod^t whuA an riant pnta or which Ihcra
ia reawHt lo bclicv* an plain pcaia. TTi«
introduetioii Into the United States of sudi aitidea
may be aubiect to other regulationa fminiilirated
untierthe Federal riant Peat Act {7US.C iMaa «/
aeq.). the riant Osanniine Act (7 U.&C ISt ci se^.k
and the Federal Neswua Weed Act (7 U.S.C. itm er
eatr-i and f^d in 7 Om Pam StS. Sa. 330. and MO
For example iindtK refpilatiena pmntti«ctcd In 7
CFR "Subpart-Nmeiy Stock" (7 OR 31937} a
permit ie required for the impwlilitm of certain
eianaa of nuraery stodi whetlmr |enetieatly
enginemd or not. Thue. a penon abould CMieult
time reguiaticHU prior to the importaiion of any
nursery tiedt.
* Pursuant to section 106 of the Federat riant Put
Ad <r US.C ISOddl the Secretary of Asrtcuiiure is
auil^zed lo ordw prompt rwnevai from the United
Staiet or to amze. quarantme. treat, apply other
ranedial measurea to. destroy, or oiherwise dispoee
cd.tR such mannsras the Seoctary dernna
appropriate, certain regulated artictes which are
believed to be mfested or mfeded by or conlatn a
plant pest.
S34Q.1 Oofinitiens.
Terms used in the singular form in this
part shaii be construed as the plural,
and vice verse, at the case may
demand. The following terms, wb^
used in this part, shall be construed,
respectively, to mean:
Courtesy permit A written permit
issued by the Deputy Administrator in
accordance with $ 340J(h) of this part
Deputy Administrator. The Deputy
Administrator for I^ant Protection and
Quarantine. Animal and I^ant Health
ln^)ectkin Service. U.S. Department of
Agriculture, or any other officer or
employee of the Department to whom
au^orily to act in his/her stead has
been or may hereafter be delegated.
Donor organism. The organism
which genetic material ia obtained for
transfer to the recipient organism.
Environment All the land. air. and
water: and all tivii^ nanisms in
association with land, air and water.
Genetic engineering. The genetic
modification of organisms 1^
recombinant DNA techniques.
Inspector. Any employee of Plant
Protection and Quarantine. Animal and
iHant Health Inapection Service. U.S.
Department of Agriculture, or other
person, authoriud by the Deputy
Administrator in aoxrdanee with law to
enforce the provlaions of this part.
interstate. Prom any State into or
through any other State.
introduce or introduction. To move
Inlo or through the United States, to
release into the environment, to move
interstale, or any attempt thereat.
Move (moving, movement). To ship,
offer forehipment. o^er for entry,
import receive lor transportation, carry,
or otherwise transport or move, or allow
to be moved into, trough, or within the
United States.
Organism. Any active, infective, or
dormant stage or life form of an entity
characterized as living, including
vertebrate and invertebrate animals,
plants, bacteria, fungi, mycoplasmas,
mycoplaama>like organisms, as well as
entities such as viroufo. vinises. or any
entity characterized as living, related to
the foregoing.
Permit A written pnmit Issued by the
Deputy Administrator for the
introduction of a regulated article under
conditions determined by the Deputy
Administrator not to present a risk of
plant pest introduction.
Person. Any individual, partnership,
conboration. company, society,
associeticHi. or other organist group.
Piant Any living stage or form of any
member of the piant kingdom ^
including, but not limited to. eukaryotic
algae, mosses, club mosses, ferns,
angiospermt. gymnosperms. and lichens
(which contain algae) including any
parts (e.g. pollen, seeds, cells, tubers,
stems) thereof, and any cellular
comptments ( 64 }. plasmids, ribosomes,
etc.} thereof.
Plant f^st Any living stage (including
active and dormant forms) of insects,
mites, trematodes. slugs, snails.
proto;K». or other invertebrate animals,
bact^. fungi, other parasitic plants or
reproductive parts thereof: viruses; or
any organisms similar to or allied with
any of the foregoing; or any infectious
agents or substances, whi^ can directly
or incfirectiy injure or cause disease or
damage in or to any plants or parts
thereof, or any processed, manufactured,
or other products of plants.
Piant Protection and Quarantine. The
organizational unit within the Animal
and Plant Health Inspection ^rvtce.
U.S. ttepartment of Agriculture,
delegated responsibility for enfoieing
provisions of the Plant Quarantine Act,
the Federal Plant Pest Act, and related
legislation, and quarantme and
regulations promulgated thereunder.
Product Anything made by or from, or
derived from an organism, living or
dead.
Recipient organism. The organism
which receives genetic material from a
donor organism.
Regulated article. Any organism
which has been altered or produced
through genetic engineering, if the donor
organirin. recipient organism, or vector
or vector agent belongs lo any genera or
taxa designated in | 340.2 of this part
and meets the definition of plant pest, or
it an unclassified organism and/or an
organism whose classification is
ui^owD, or any product which
contains such as organism, or any other
organism or product allemi or produced
through genetic engineering which the
Deputy Administrator determines is a
piant pest or hat reason to believe is a
plant pest. Exduded are recipient
microorganisms which are not plant
pests and which have resulted fiom the
additim of genetic material from a
donor organism where the material is
well characterized and contains only
non-coding regulatory regions.
Release into the environment The use
of a reguteted article outside the
constraints of physical confinement that
ere found in a laboratory, contained
* Die ((xonoinic (dwine for the plimt kit^dom ia
that fo-jnd in Synopaia and Oaatiiicaiion of Uvinit
' cv S.P. Parker. McCraw Hili (tSS*}.
835
Federal Regbtgr / Vol 52. No. 115 / Tuesday. |une 16. 191^ / Itoles and Regulatioat 2589C9
greenhouse, or a fermenter or other
(^ntained structure.
Responsible person. The person who
has ccmtroi and will maintain control
over the introduction of the regulated
article and assure that ail conditions
cwitained in the pennit and
re<]uiramenls in this part are osmpiied
with. A responsible person shall a
resident of the United States or
designate an agmt who is a resident of
the United States.
Secretary. The Secretary of
Apiculture, or any other officer or
^ployi^ of the Department of
Apriculture to whom authority to act in
his/her stead has been or may hereafter
be delegated.
State. Any Slate, the Dtstrict of
Columbia. American Samoa. Guam.
Northern Mariana Islands. Puerto Rico,
the Virgin Islands of the United States,
and any other Territories or Districts of
the United States.
United States. All of the States.
Vector or vector a^ent. Organisms or
obfe^s used to transfer genetic material
from the donor organism to the redpient
organism.
Well-diaractenzed and ctmtains only
non-coding regulatory regions
(e.g. operators, promoters, origins of
rapiication. terminators, and ribosome
bindii^ regions). The genetic miterial
added to a microorganism in which the
following can be documented atout
sudi genetic material: (a| The exsct
nucleotide base sequence of the
regulatory region and any inserted
flanking nud^tides: (b) The regulatory
region and any inserted flanking
nucleotides do not code for protein or
peptide; and fc) The regulatory region
solely c<mtrols the activity of other
sequences that code for protein or
peptide molecules or act as recognition
sites for the initiation of nucleic acid or
protein synthesis.
$340.2 QftHms of oroanlsms wMen are or
contain (gant pests.
The organisms that are or contain
plant pests are irtcluded in the taxa or
group of o^anisms contained in the
following list. Within sny taxonomic
serin induded on the list, the lowest
unit of classiHcation actually listed is
the taxon or group which may contain
organiuns which are reguiated.
Organisms belonging to all Imver taxa
omtained within the group listed are
uicluded as organisms that may be or
may cmitain plant pests, and are
regulated if they meet the definition of
plant pest in § 340. t*
* Any evsBntsm belwigitig (o any Uxa conulned
wKhin any lifted genera or taxa U only contidered
to t>e a i^nt pest if the o^anien "can directly or
Note.— Any genstiesUy eaginrered
oqian^ oHnposed of E^A or RNA
sequences, orgsoeile*. plumidt. parts,
ojpies. and/or analogs, of or boin any of ths
groups of organisms listed below shall be
deemed a regulated artida if it also meets the
dehnition of plant pest in §340.1.
GROUP
Viraids
Saperkingdoat Prekaryotee
Kingdom Virus
Alt members of groups containing plant
viruses, and all mher plant and insect
vinises
Kingdom Moaera
Division Bacteris
Family Pseudomonadaceae
Genus Pseudomonas
Genus Xanthomonas
Family Rhizobiaetae
Genus Rhizobium
Genus Bradyrhizobium
Genus Agrobacterium
Genus Phyllobaeterium
Family Enterdtacieriacne
Genus Erwinia
Family Streptomycetaeeae
Genus Streptomyces
Family Actinomycetaeeaaa
Genua Actinomyces
CtMyiteform group
Genus Clavibacter
Genus Arthrobacier
Genus Curtobacterium
Genua Corynebactaria
Cram-negative phloem-limited bacteria
associated with plant diseasas
Cram-negative xylem-limited bacteria
associated with plant diseases
And all other bacteria associated with plant
or insect diseases
Rickettsiaceae
Rickettaial-like otganiKns associated with
insect diseases
Class MoUicutes
Order Mycoplssma tales
Fsmily Spiroplasmatarese
Genus Spiroplasma
Mycopiasms-like organisms associsted with
plant diseases
Mycoplasma-like organisms associated with
insect diseases
Indirectly injim. or esuse disease, or dsauge In any
piantf or psrtt thereof, wany processed
Buaufsetured Of other products of ^ants” Those
particuler untitled epeciec witWo a listed genue
would be deemed a plant pest for purposes of
I MQ.Z if the ecientiAc literaiure refers to the
organism ee s ceuce of direct or indirvei infory.
ditetee. w damage to any ^ata. plant parts or
products of plants. (If there is any quastion
cmiceming (he plant pest status of an organism
betangmg to any listed genera or taxa. the person
proposing to introduce the organism in question
should consult with APHIS to detemtne tf the
organism is subfeet to rcgotalion.)
Superkin^om Eukaryotas
Kir^dom Planiae
Sabkingdoat ThaUobionta
Dtvisirai Chlorophyta
Genus Cephaleuros
Genus Rhodochytrium
Gmius niylloati^on
IXvision Myxomycota
Qess nasmodiophoromyretaa
Division Eumycota
OaM Chytridimnycates
Ord» Chytridiales
Claw Oemyeatas
Order Lagenidialei
Family LagenidlMeat
Family Olpidiopaidaeaaa
Order Pertmosporalea
Family Albt^naceaa
Family ^ronoiporaceaa
Family PythUtceaa
Order Saprolegniales
Family Saprdegniaceaa
Family Leptolegniellaceae
Class Zygomycerns
Order Mucorales
Family Choanephoracaae
Family MucxMraceae
Family Entomof^thoraeeae
Claaa Hemiaacomycetea
Family Protomyoetacaae
Family Taidrinacaae
Qata Loculoascomycetsa
Order Myriangiales
Family ^inoeiceae
Family Myriangiaceaa
Order AsterinalM
Order Dolbtdealea
Order Chaetothyrialea
Order Hysteriaies
Family I^rmulariteeae
Family PhilUpaieUaeeae
Family Hyateriaeeae
Order Pieosporales
Order Melanommatales
Class Piectomycetes
Order Euro tiales
Family Ophiostomataceae
Order Ascophaerales
Class Pyrenomycetes
Order Erysiphales
Order Melioiales
Oder Xyiariales
Order Diaporthales
Order Hypoereales
Order Qavicipitaies
Class Oiscomycetes
Order Hiactdiales
Order HettUiales
Family Ascocorliciceae
Family Hemiphacidiaceae
Family Dermttaeeae
Family Sclerotiniaeeae
Order Cytarrialea
Ordw Medeolariaiea
Order Pezziaiea
Family Sarcoaomataceae
Family Sarcoscyphaceae
836
22910 FediM-al Register / Vol. 52. No. 115 / Tuesday, jane 16. 1987 / Rules and Regulations
Ctasa Teliomycetes
Claw Phregmobasidiomyceies
Family Auriculariaceae
Family Ceratobasidiaceae
Clasa Hymenomycetes
Onler Exobasidiales
Order Agaricalea
Family Corticiaceae
Family Hymenochaefaceae
Family Echinodontiaceae
Family Fiatulinaceae
Family Clavariaceae
Family Polyporaceae
Family Tricholomataceae
Oaaa Hyphomycetea
Qaw Coelomyceies
And all other fungi aaaocialed with plant ta
inaect diaeaies
Sabkingdom Bmbryobionta
Neta.<~0/:gomsina listed in the Code of
Federol Regulations os noxiota weeds ore
regulated under the Fedetel Noxious Weed
A&
Divititm Magnoliophyta
Family Balanophoraceaa~<paraaitic apedea
Family CuacutaMae — paraaitie apedea
Family Hydnoraceae— paraaitie apedea
Family Krameriaceae-^iuraaitlc apedea
Family Lauraecan-'paraaitie apedea
Genua Casaytha
Family Leniwaceae— paiaaitic apedw
Fanuiy Loranthaceae^panaiiic apedea
Family MyxodeRdraceae>-paraaiiic apedea
Family Olacaceae— paraaitie speeiea
Family Ord>aimhaceae->panati]c apedea
Family Ranietiaceae— parsalUc apa^
Faidty Santalaeeae^-paraailie apedea
Family Scrophulanaceae>~pereaitie apedea
Genua Aleetra
Genua Bartaia
Canua Buchnera
Genua fiuttonia
Genua Ceatillefa
Genua Centranthera
Genua Cordylanthua
Genua Oaaiatoma
Genua Euphraaia
Genua Cerardia
Genua Harveya
Genua Hyobanche
Genua Lathraea
Genua Melampyrum
Genus Melasma
Geniu Orthantha
Genua Orthocarpus
Genus Pedicularia
Genus -RKamphicarpa
Gmna Rhinanthus
Genua Schwalbea
Genus Se^eria
Genua Sl^tmoaiegia
Genua Sopubia
Genua Striga
Genua Tozzia
Family Viscaceae— paraaitie spm:iea
Kingdom Animolio
Subkingdom Protozoa
Genua Phylomonaa
And ail Protozoa associated with insect
diaeaaea
Subkingdom Eumeiazoo
Phylum Nemala
Class Secementea
Order Tylenchida
Family Anguinidae
Family Belonolaimidae
Family Caioosiidae
Family Criconematidae
Family Doiichodoridae
Family Fergusobiidae
Family Hemicyciiophoridae
Family Heteroderidae
Family Hoploiaimidae
Family Meloidogyni^*?
Family Nacobbidae
Family Neotylenchidae
Family Nothotylenchidae
Family Paratylenchidac
Family Pratylenchidae
Family Tylenchidae
Family Tylanehulidae
Order Aphelenchida
Family Apheienehoididae
Class Adenophorea
Order Oorylaimida
Family Longidoridae
Family Tridradoridae
Phylum Molhisca
Ctasa Gastropoda
Subclaw Pulmonata
Order Baaommatephora
Supcrfamily Planwbaeaa
Order Slylommalophora
Subfamily Strophocheilacea
Family Succineidse
Superfamily Aehatinaeae
Supcrfamily Antmacaa
Superfamily Umaeaeca
Superfamily Kelieacta
Order Sysieiiommatophora
Superfamily Vei(micellacaa
Phylum Arthropoda
Claw Arachnlda
Order Paraailif<Mmea
Suborder Meaostigtnala
Supcrfamily Aacoidea
Supcrfamily Oetmanyaaoidea
Order Acahfonaea
Suborder Proatigmata
Superfamily Eriophyoidea
Supcrfamily Tetranyeboides
Supcrfamily Eupodoidea
Suparfamily Tydeoidea
Superfamily Erythraemidei
Superfamily Trombidlotdes
Superfamily Hydryphantoidea
Superfamily Tarsonemoldea
Superfamily Pyemotoidea
Suborder Asligmata
Superfamily Hemisarcoptoldaa
Superfamily Acaroidca
Claaa Oiplopoda
Order Polydeimida
Class Insects
Order CoUembola
Family SmlnthoHdae
Order laoptera
Order Thysanoptera
C^der Orlhoptera
Family Acrididae
Family Cryliidae
Family GryUacrididae
Family Gryllotalpidae
Family Phasmatidue
Family Ronaleidae
Family Teltigoniidae
Family Telrigidae
Order Hemiptera
Family Thaumaatocoridae
Family Aradidae
Superfamily Piesmatoidea
Superfamily L^aeoidea
Superfamily idiuatoloidea
Superfamily Coreoidea
Superfamily Pnitatomoidea
Superfamily Pyrrhoeoroidea
Superfamily *nf^cKdea
Superfamily Miroidea
Onier Homoptera
Order O^eoptera
Family Anobtidae
Family Apienidae
Family Anthribidae
Family Boatrichidae
Family Brentidac
Family Bnichidae
Family Buprestidae
Family Bytundae
Family Cantharidae
Family Carabldae
Family Cerambycidae
Family CKryacunelidaa
Family Coi^nellidae
Subfamily Epilachnhuie
Family Curcubonidae
Family Demeatidae
Family Elateridaa
Family Hydrophiiidae
Genua Helopborua
Family LyetidM
Family Mdoidaa
Family Mordeltidae
Family Platypodidae
Family Searabaeidae
Subfarndy Melolonthioae
Subfamily Rutelinae
Subfamily Catoniiaac
Subfamily Oynaatinaa
Family Scolytidae
Family Selbytidae
Family Tenebrionidae
Order Lepidoplera
^der Oiptera
Family Agromyzidae
Family Anthomyiidae
Family Ceeidomyiidae
Family Chioropidac
Family ^^ydrfdse
Family Londtaeidae
Family Muacidae
Genua Alherigona
Family Otitidae
Genua Euxeta
Family Syrphidae
Family Tef^ritldae
Family Hpulidae
Order Hymenoptera
Family Apidae
Family Caidddae
Family Chelcidne
Family Cynipidac
Family Eur^omidae
Family Formicidae
Family Pailidae
Family Siricidae
Family Tenthndinidae
837
Federal Register / Voj. 52. No. 115 f Tueaday. June 16. 1967 / Rules and Regulations 2SS11
Family Torymidae
Family Xylocoptdae
Unclauifted organisms and/or organisms
whose ciesaificaiion is unknown.
$340.3 for tha introduction of a
rafpuUdadMtKda.
(a) .(4pp/ica/iVm for permit. Two copies
of a unitten application for a permit to
introdu^ a regulated article shall be
submitted by the responsible person cm
an application form obtained from Plant
Protection and Quarantine, to the
Biological Assessment Support Staff
(Biotedt Unit). Plant Protection and
Quarantine, ^mal and Plant Health
Inspection ^rvice. U.S. Department of
/l^riculture. Federal Building. &50S
Beicrest Road. Hyettsville. Maryland
20782. U there are portions of the
application fbemed to contain trade
secret or confidential business
information fCBi}. each p^e of the
appUcation containing such information
sh^ld be mariced "CBI Copy", in
addition, those portions of the
application which are deemed *'CBI"
shall be so designated. The second copy
shall have all such C3I deleted and shall
be marked on each page of the
application where CBI was deleted.
'*(31 Deleted”. If an application does
not contain CB! then the first page of
both copm shall be marked "No (31”.
(b) for release into the
environment An application for the
release into the environment of a
regulaUKi artide shall be submitted at
least 120 days in advance of the
proposed release into the environment.
An initial review shall be completed by
Plant Protection and Quarantine within
30 days of the receipt of the application.
If the application is complete, the
responsible individual shall be notified
of the date of receipt of the appUcation
for purposes of advising the applicant
when the 120 day review period
commenced.* If tlw appUcation is not
complete, the responsible individual wiU
be advised what additional infonnation
must be submitted. Flant Protection and
Quarantine shall commence the 120 day
review peritKl upon receipt of the
additional information, assuming the
additional infonnation submitted is
adequate. When it is determined that an
application is complete. Plant Protection
and C^aranttne shall submit to the State
department of agriculture of the State
where the release is planned, a copy of
the initial review and a copy of the
application marked "(31 Deleted”, or
‘'No (3!” for Stale notification and
■ tti* 120 day teviaw Oertod would ba aatanded if
prefwratton of an anviraiutiental tmpoct atatanrai
in addtiien to an caviranmental aiantment wat
nacataary.
review. Ute appUcation shall include the
following information; *
(1) Name, title, address, telephone
number, signature of the responsible
person and type of permit requested (for
importation, interstate movement, or
release into the environment);
(2) Ail sdentinc, common, and trade
names, and ell designations necessary
to identify the: Donor organism(8):
recipient organismis); vector or vector
agent(s): constituent of each regulated
article which is a product: and.
regulated article:
(3) Names, addresses, and telephone
numbers of the persons who developed
and/or supplied the regulated article:
(4) A description of ^ means of
movement (e.g.. mail, common carrier,
baggage, or handeerried (and by
whom]}:
(5) A description of the anticipated or
actual expression of the altered genetic
material in the reflated article and how
that expression differs from the
expression in the non>modined parental
organism (e.gH morphological or
structural clmracteristics. physiological
activities and processes, number of
copies of inswted genetic material and
the physical stale of this material inside
the recipient organism (integrated or
extrachromosomal), pr^ucts and
secretions, {^wth characteristics):
(6) A detailed description of the
molecular biology of the system (e.g..
donor*recipient«vector) which is or vrill
be used to produce the regulated article:
(7) Country and locality where the
donor organism, recipient organism,
vector or vector agent, and regulated
article were collected, developed, and
produced:
(8) A detailed description of the
purpose for the introchiclion of the
regulated article including a detailed
description of the proposed
experimental and/or production-design;
(9) The quantity of the regulated
article to be intrt^uced and proposed
schedule and number of introductions:
(10) A detailed description of the
processes, procedures, end safeguards
which have been used or will be used in
the country of origin and in the United
States to prevent contamination,
release, and dissemination in the
production of the: Donor organism;
recipient organism: vector or vector
* Application (amu si« •vatiaWt wilhewl chaiyt
from th« Sialoaical AiMaMiant Support StafL PUal
Protection m 4 Quarantine. Animal and Plant
Health inepection Scnrtce. VS. Department of
Agriculture. Federal B uilding . SSOS Balcmt Road.
Hyattatnlle. Maryland SSPtL or from toeat eflioaa
which art liated In lulephoiM diroctertae. A poraen
•houid apecily in requaiimg the appUcattoo that ttw
permit it for the introduction of c regulated arttcla
•uhiect to regulation under Part S40.
agent: constituent of each regulated
article which is a product and r^ulated
article:
(11) A detaited desoription of the
intend^ destination (induding Gnai and
ail intermediate destinations), uses,
and/or distributton of the related
article (e.g., ^eenhouses. laboratory, or
growth chamber location: field trial
location: pilot project locatttm:
production, propagation, and
manufacture location: prcqmsed sale and
distribution location);
(12) A detailed d^cription of the
proposed pro«Kiures. processes, and
saf^uards whidi will be used to
prevent escape and dissemination of the
related article at each of the intended
destinations:
(13) A detailed description of any
biologtcal material (eg^ culture nwdium.
or h(M material) accompanying the
re^UtiNi article durmg movement: and
(14) A detailed description of the
proposed method of final disposition of
the regttleted article.
(c) limited permits for interstate
movement or importation of a regaiated
article. An application for the interstate
movement or ingiortetion of a regulated
article shall be submitted et least 60
days in advance of the first proiM»ed
interstate movement and et (east 60
dtye prior to each importation. An
initial review shell be completed by
Kent Protection and Quarantine within
15 days of the receipt of the ep^ication.
If the application is complete, (he
responsible person shall be nodfied of
the date of receipt of the application for
purposes of advising the sppUcant when
the 60 day review period commenced. If
the application is not complete, the
responsible person will be advised what
ad^Uonal information must be
submittsd. Plant Protection and
Quarantine shall commence the 60 day
review period upon receipt of the
additional information, assuming the
edditionsi information submitted is
adequate. When it is determined that an
epplicalion is complete. IHent Protection
and Quarantine shali submit to the State
department of agriculture of the State of
destination of the regulated article a
copy of the initial review and the
application marked. "(31 Deleted”, or
"No CBI” for State notification and
review.
(1) Limited permit for interstate
movement. The reiH)onsib}e person may
apply for a single limited permit for the
interstate movement of multiple
regulated articles in lieu of suteiittlng
an application for each individual
interstate movemimt. Eadi limited
pernut issued shall be numbered and
shall be valid for one year from the date
838
22912 Federal Register / Vol. 52. No. 115 / Tuesday. June 16. 1987 / Rules and Regulaliong
of issuance. If a permit is sought for
multiple interstate movements between
contained facilities the responsible
individual shall specify in the permit
application ail the regulated articles to
be moved interstate: the origins and
destinations of all proposed shipments;
a detailed description of all the
contained facilities where regulated
articles will be utilized at destination;
and a description of the containers that
will be used to transpoH the regulated
articles. A limited permit for interstate
movemmt of a regulated article shall
only be valid for the movement of those
regulated articles moving between those
locations specified in the application. If
a person seeks to move regulated
articles other than those specified in the
application, or to a location other than
those listed in the application, a
supplemental applicatitm shall be
submitted to Plant fVotection and
Quarantine. No person shall move a
regulated article interstate unless the
number of the limited permit appears on
the outside of the shipping container.
The responsible peraon shipping a
regulated article intentate shall keep
records for one year demonstrating that
the regulated article arrived at its
intended destination. I'he responsible
person sedcing a limited pmmit for
interstate movement shall submit on an
application form obtained from Plant
(4ote<^on and Quarantine the data
required by 1 34a3{b}(l}. (2). (4). (6). (7).
(9).and(llHM|.
(2) Limited permit for importation.
The responsible person seeking a permit
for the impmlation of a regulated article
shall submit an application for a permit
prior to the importation of each
shipment of regulated articles. The
responsible person importing a
regulated arbcle shall keep records for
one year demonstrating that the
regulated artide arrived at its intended
destination. The responsible person
seeking a limited pmmit for importation
shall submit on an application form
obtained from Plant Protection and
Quarantine data required by
5 340.3{bHl). {2). (4}. 16). (7). (9). and
(dl Premises inspection. An inspector
may inspect the site or facility where
regulated articles are proposed,
pursuant to a permit, to be released into
the environment or contained after their
interstate movemem or importation.
’ Renew*!* m*y receive tliAiier review, tn the
C4«e ol * renewBt for • limited permit for
mipurtelion th*l hat been iisued IcM Ilian one year
earlier. AI^US wilt notify 'He retponiibic pertOR
wifHiR >S day* that either ft’ The renewal permit 1*
•ppraved or (21 ih*i a SO day Kviaw period ia
necestary becatiae the conuiiton* ol the uriK'itai
permi' have cHanacd.
Failure to allow the inspection of a
premises prior to the issuance of a
permit or limited i^rmit shall be grounds
for the denial of the p^mit.
(e) Administmrive action on
appiicotions. After receipt and review
by Plant Proteetkm and Quarantine of
the application and dte data submitted
pursuant to paragraph (a) of this section,
including any additional information
requested by Plant Protection and
Quarantine, a permit shall be granted or
denied. If a permit is denied, the
applicant shall be promptly informed of
the reasons why the permit was denied
and given the opportunity to appeal the
denial in accordance with the provisions
of paragraph (gj of this section. If a
permit is granted, the permit will specify
the applicable conditions for
introduction of the regulated article
under this part.
[f) Permit conditions. A person who is
issued a pennit and his/her employees
or agetila shftU comply with the
foliowing conditions, and any
supplemental conditiona which shall be
listed on the permit, as deemed by the
Deputy Administrator to be necessary to
prevent (he dissemination and
esiablishment of plant pests:
{l}The regulat^ article shall be
maintained and disposed of (when
necessary) in a manner so as to prevent
(he dissemtnatton and eatablishment of
plant pests.
(2) Ail packing material, shipping
containers, and any other material
accompanying the regulated article shall
be treaied or disposed of In such a
manner so as to prevent the
cJisseminaiion and establishment of
plant pests.
{3| The regulated article shall be kept
separate from other organisms, except
<is specifically allowed in the permit:
(4) The regulated article shall Be
maintained only in areas and premises
.ipecified in the permit:
(51 An inspector shall be allowed
access, during regular business hours, to
the place where the regulated article ts
located and to any records relating to
the introduction of a regulated article:
{6| The regulated article shall, when
possible, be kept identified with a label
showing the name of the regulated
article, and the date of importation:
(7) The regulated article shall be
subject to (he application of measures
determined by the Deputy Administrator
to be necessary to prevent the
uccidenial or unauthorized release of
the regulated article:
fS) I'hc regulated article shall be
subject to the application of remedial
measures (including disposal)
determined by the Deputy Administrator
to be necessary to prevent the spread of
plant pests:
(9) A person who has been issued a
permit shall submit to Plant Protection
and Quarantine monitoring reports on
the performance characteristics of the
regulated article, in accordance with
any monitoring reporting lequiroments
that may be specified in a permit:
(10) Plan! Protection and Quarantine
shall be notiHed within the time periods
and manner specified below, in ^e
event of the foliowing occurrences:
(i) Orally notified immediately upon
discovery and notify in writing %vlthin 24
hours in the event of any accidental or
unauthorized release of the regulat«l
article:
(11) In writing as soon as possible but
not later than within 5 working days If
the regulated article or associated host
organism is found to have
characteristics substantially different
from those listed in the application for a
permit or suffers any unusual
occurrence (excessive moriaiity or
morbidity, or unanticipated eHedl on
non'target organisms):
(11) A permittee or his/her agent and
any person who seeks to import a
regulated article into the United States
shall;
(i) Import or offer the regulated article
for entry only at a port of entr y %^ cfa Is
designated by an asterisk in 7 CFR
319.37>14(b):
(ti) Notify Plant Protection and
Quarantine promptly upon arrival of any
regulated article at a port of entry, of Its
srrival by such means as a manifest,
customs enuy document, commerdal
invoice, waybill, a broker's document, or
a notice form provided for such purpoee;
and
(iii) Mark and identify the regulated
article in accordance with f 340.S of this
part.
(gJ Withdrawal or denial of a permit
Any permit which has been issued may
be withdrawn by an inspector or the
Deputy Administrator if he/she
determines that the holder thereof has
not complied with one or more of the
conditions listed on the permit. APHIS
will confirm the reasons for the
withdrawal of the permit in writing
within ten (10) days. Any person whose
permit has been withdrawn or any
person who has been denied a permit
may appeal the decision in writing m the
Deputy Administrator within ten (10)
days after receiving the written
notification of the withdrawal or denial.
The appeal shall state ail of the facts
and reasons upon which the person
relies to show that the permit was
wronghilly withdrawn or denied. The
Deputy Administrator shall grant or
839
Federal Register / Vol. 52. No. 115 / Tuesday, |une 16. 1987 / Rule« and Regulations 28913
tJony the iippeHl. in writing, stating the
r(;;i;iLins for the Ueciston as promptly as
< allow. If there is a
corHii’j }».«« to miy material fact, a
he’>nii<> .shall be held to resolve such
confliii. Roles of practice concerning
such t hearing wilt be adopted by the
Administrator.
fh) Courlt'ity parmU--{i] Issuance.
Hie Deputy Administrator may issue a
courtesy permit for the introduction of
organisms modified through genetic
engineering which aro not subject to
regulation under this part to facilitate
movement when the movement might
otherwise be impeded iMscauseof
simiUirity of the organism to other
organisms rcgulat^ under this part.
(2) Application. A person seeking a
courtesy permit shall submit on an
application form obtained from Plant
ProtMtion and Quarantine data required
by Si 340^{blUj. (Z). and (5) of this part
and shall indicate sudhi data is being
•ubmitled as a request for a courtesy
permit. A person should airo include a
statement explaining why he or she
believes the organism m* product does
not come within the definition of a
regulated article. The application shall
be sulHnitted at least 80 days prior to the
time the courtesy permit is sought.
(3) Administrative action. Plant
Ihotection and Quarantine shall
omiptete an initial review within IS
days of the date of receipt of the
applicatliHi. if the application is
complete, the responsible individual
shall be noticed of the date of receipt of
the application for purposes of advising
the applicant when the 60 day review
period commenced. If the application it
not complete, the responsible individual
will be advised what additional
fnfonnation must be submitted, and
shall commence the 60 day review
period upon receipt of the additional
information, assuming the additional
information sutmiitled is adequate.
Within 60 days from the date of receipt
of a aimplete application. Plant
Protection and Quarantine will either
issue a courtesy permit or advise the
responsible individual that a permit is
required under $ 340 Jfb) or (c).
9340.4 Petition to amend the nst of
organisina.
fa) General. Any person may submit
to tlm Deputy Administrator a petition
to amend the list of oigauisms in § 340.2
of this part by adding or deleting any
genus, species, or subspecies. A
petitioner may supplement, amend, or
withdraw a petition in writing without
prior npprovai of the Deputy
Administrator and without prejudice to
resubmis.>tion at any time until the
Deputy Administrator rules on She
petition. A petition to amend the list of
organisms shall be submitted in
acnur;bnu.e with the prouedufus and
furin.'it specified by titis section.
(i>) iy^l/iuissiKi procedures and
fiirtiict. A person shall submit two
copies of a petition to the Deputy
Administralur of Plant Protection and
Quarantine, in care of the Director of the
Biotechnology and Environmental
Coordination Staff. Animal and Plant
Health Inspection Service. U.S.
Department of Agriculture. 8505 Beli^st
Road. Room 406, Federal Building,
Hyattsville. Maryland 20782. The
petition should be dated, and structured
as follows:
PttitioQ Ta Amend 7 OH MM
The undentgned submits this petition
under 7 CFR M>.4 to request the Deputy
AdministraKm of Plant Protection end
Qusrentine. to fedd the following genus,
spectci. or subspedet to the list of otganlsms
in 7 CFR 340Jt} or (to remove the following
genus, ^eeies, or subspecies bom the list of
orgomsflui in I 340l2].
A. Statement of Croandt
(A person must present a full statement
explaining the factual grounda why the genua,
apeciea. or aubapedes to be added to I MM
ol thia pert ta a plant past or why there is
reason to believe the genus, species, or
subspedes Is a plant pest or why the genus,
spedes, at subspecies seogbt to be removed
is not o plant pest or why thoro Is tosson to
bdieve the genus, sptdee. or subspecies is
not e plant peeL The petition should include
copies of sdentifk titeruturo which the
petitioner Is telyl^ upon, ct^les of
unpublished studies, or data from teita
performed. The petition should not include
trade secret or confidential business
infarmatian,
A peraon ahould also inciuda
repmaentative information known to tha
petilirmer which would be unfavorable to a
petition for bating or delisting. (If a peraon it
not aware of any unfavorable inforaeiion the
petition should state. Unfovorable
(nformelion: NONE).
B. Certification
The undersigned certifies, thit to the best
knowledge end belief of the undersigned, this
petition includes all information end views
on which the petitioner reties, and that it
includes rcpresMiarive data and inlormation
known to the petitioner which ere
unfavorable to the petition.
(Signature) -
(Nameof^titioner) — ■
(MaiUl^l address! —
(Telephone number) — -
(c) Administrative action on a
petition. (1) A petition to amend the list
of organisms which meets the
requirements of paragraph (b) of this
section will be filed by the Director of
the Biotechnology and Environmental
Coordination Staff, stamped with the
date of filing, and assigned a docket
number. The dod^et number shall
identify the file established for all
submissions relating to tiie petition. The
Biotechnology and Environmental
Cooixlinati<ai Staff, will promtply notify
the petitioner in WTiting of the filing and
docket number of a petition, if a petition
does nut meet the requirements of
paragraph (b) of this section, the
ftittitioner shall be sent a notice
indicating how the petition is deticient.
(2) After the filing of a petition to
amend the list or organisms l^DA shall
publish a proposal in the Federal
RegUder to amend i 340.2 and solicit
comments thereon from the public. An
interested person may submit written
comments to the Director of the
Biotechnology and Environmental
Djordination Staff on a Bled petition,
which shall become part of the docket
file.
(3) The Deputy Administrator shall
furnish a response to each petitioner
within 180 days of receipt of the petition.
The response will either (i) A{^>rove the
petition in whole or in pert In v^ich
case the Deputy Administrator shall
concurrently take appropriate action
(publication of a document in the
Pod«nl Registiv amending 1 340.2 of
this pari: or (li) deny the petition in
whole or in part Tbe petitioner shall be
notified In writing of the Deputy
Administrator's decision. Hie decision
shall be pieced in the public docket file
in the ofBces of the Biotechnology and
Environmental Coordination Staff, and
in the form of a notice published in the
Federal Renter.
93408 MsfliinesndMwMity.
(a) Any regulated article to be
imported other than by mail, shall, at the
time of importation into the United
Slatea. plainly and correctiy bear on the
outer container the following
infonnation:
(1) General nature and quantity of the
contents:
(2) Country and locality where
collected, developed, manufactured,
reared, cultivated or cultured:
(3) Name and address of shipper,
owner, or person shipping or forwarding
the organism:
(4) Name, address, and telephone
number of consignee;
(5) Identifying shipper's mark and
number and
(6) Number of written permit
authorizing the importation.
(b) Any regulated article imported by
mail, shall be plainly and correctly
addressed and mailed to Plant
Protection Quarantine at a port of entry
designated by an asterisk in 7 CFR
319.37>l4(b) and shall be accompanied
840
Federal Register / Vol. 52, No. 115 / Tuesday. |une 16, 1087 / Roles and Regulations
22^4
by a separate sheet of paper within the
package ptainiy and correctly bearii^
the name, address, and telephone
number of the intended recipi»it. and
shall plainly and correctly bear on the
outer container the following
information:
(1) General nature and quantity of the
contents:
(2) Country and locality where
collected, developed, manufactured,
reared, cultivated, or cured:
(3) Name and address of shipper,
owner, or person shipping or forwarding
the regulated article: and
(4) Number of permit authorizing the
importation:
(c) Any regulated article imported into
the United States by mail or otherwise
shall, at the time of impmlation or offer
for importation into the United States,
be accompanied by an invoice or
packing list iudicatii^ the contents of
the shipment
§340.6 CoMstasw requireoMote for the
movement of reguiated af tl clas>
fa) Genera! requirements. A regulated
article shall not be moved unless it
conq)lies with the |»ovisions of
paragraph (b) of this section, unless a
variance has been granted in
accordance with the provisions of
paragraph fc) of tlds section. *
(b) Container requirementa^X]
Plants and piant parts. All plants or
plant parts, except seeds, cells, and
subcellular elements, shall be packed in
a sealed plastic bag of at least S mil
thickness, inside a sturdy, sealed, leak-
proof. outer shipping container
constructed of corrugated ftberboard.
corregated cardboard wood, or other
material of equivalent strength.
(2) Seeds. All seeds shall be
transported in a sealed plastic bag of at
least S mil thickness, iruide a aealed
metal container, whteh ahull be placed
inside a second sealed metal container.
Shock absori>ing cushitming material
shall be placed between the inner and
outer metal containers. Each melai
container shall be independently
capable of protecting the seeds and
preventing spillage or escape. Each set
of metal containers shall then be
enclosed in a sturdy outer shipping
cuntdincr constrected of corrugated
fit^iboard. corrugated cardboard, wood,
or other material of equivalent strength.
(3) Live microot^anisms and/or
ef:o.'()gic agents, cells, or subcellular
* Thr rcttuiremenif of lhi« oectian are in aiiiiition
I? and R»l m iieu of any other Mek>f>| reqiHrement*
•% U«u«e for the tmr.iiponaiKni of .dioiogie
«sen)* preiLTibed (y the Deportment of
TraiiHwrtatiuR in I'itle 49 of the Code of Fedcra!
ReitufotuKit or any oilier agency of d:e Federal
tav<»mnent.
elements. AJI regulated articles which
are iive (non-inactivated)
microorganisms, or etiolt^ic agrats.
ceils, or subcellular elements shall be
packed as specified below:
fij Volume not exceeding SO ml.
Regulated articles not exceeding 50 ml
shall be placed in a securely closed,
watertight emtainer fprimary container,
test tube. vial, etc.) which shall be
enclosed In a second, durable watertight
container (secondary container). Several
primary containers may be endoted in a
tu^e seemdary container, if the lota)
volume of all the primary containers so
endosed does not exceed 50 ml. The
space at the top. bottom, and sides
between the primary and secondary
emtainers shall contain sufficient
nonparticulate absorbent material (e.g..
paper towel) to absiwb the entire
contents of the primary containerfs) In
case of breakage or leakage. Each set of
primary and secomLey containers shall
then be endosed in an outer shipping
container constructed of com<gated
fiberboard. comigated cardboard, wood,
or other material of equivalent strength.
fii) Volume greater than SO mi.
Regulated articles which exceed a
volume of SO ml. shall comply with
requirements specified in paragraph
(b)(3)(i) of this section, in addition, a
shock absorbing material, in volume at
least ^ual to that of the absorbent
material between the primary and
secondary containers, shall be placed at
the top, bottcHn. aid sides between the
secondary container and the outer
shipping container, single primary
containers shall not contain more than
1.000 mi. of material. However, two or
more primary coniainers whose
combined volumes do not exceed 1.000
ml. may be-placed in a single, secondary
container, lire maximum amount qf
microorganisms or eliologic agents,
cells, or subcellular elements which may
be enclosed within a single outer
shipping container shall not exceed
4.000 ml.
(Hi) Dry ice. If dry ice is used as a
refrigerant, it shall be placed outside the
secondary containerfs). If dry ice is used
between the secondary container and
'.he outer shipping container, the shock
absorbing material shall be placed so
that the secondary container does not
become loose inside the outer shipping
container as the dry ice sublimates.
(4) Insects, mites, and related
orgamsms. Insecte. mites, and other
small arthropods shall be packed for
shipment as specified in this paidgraph
or in paragraph (b)l3) of this section.
Insects (any life stage) shall be placed in
an escape-proof primiir>' shipping
container (insulated vacuum container,
glass, metal, plastic, etc.) and sealed to
prevent ettespe. Such {mmary container
shall be placed securely within a
secondary shipping contaiimr of
crushpitmf styrofoam or other material
of equivalent strength: one or more rigid
ice {»dcs may also be pieced within die
setmmlary shipping container: and
sufficient packit^ material idiall be
added around the primary ctmtainer to
prevent movement of the primary
shipping container. The secondary
(styroftMim or other) container shall be
placed securely within an outer shipping
container constructed of comigated
fiberboard. corrugated caniboard. wood,
or other material of equivaimit atrength.
(5) Other macroscopic organisms.
Other macroscopic organisms not
covered in paragraphs (b) (1). (2). and (4)
of this section whi^ do no! require
continuous aotess to aUimspherie
oxygen shall be packaged as specified in
paragraph fb) f3) or (4) of Uils s^on.
All macroscopic organiunt which are
not plants and whi& require continuous
access to atmospheric oxygen shall be
placed in primary shipping containers
construct^ of a stu»ly. crush-fmiof
frame of wood, metal, or equivalent
strength material, summeded by
escape-proof mesh or netting of a
strei^ and mesh size suffident to
prevent the escape of the raukUest
organism in the shipment with edges
arid seama of the mesh or netting sealed
to prevent escape or organisms. Eadh
primary shipping container shall be
securely placed within a laigw
secondary shipping container
constructed of wood, metal or
equivalent strength material. The
primary and secondary shipping
containers shall then be placed securely
within an outer shipping container
constructed of corrugated fiberboard.
corrugated cardboard, wood, or other
material of equivalent strength, which
outer container may have air holes or
spaces in the sides snd/or ends of the
container, provided that the outer
shipping container must retain sufilcient
strength to prevent crushing of the
primary and secondary shipping
containers.
(c) Bequest for a variance from
container requirements. A responsible
person who believes the container
requirements noimully applicable to the
movement of the person’s regulated
articiefs) are inappropriate due to
unique circumstances (such as the
nature, volume, or life stage of the
reguiated article) may submit in an
application for a permit, a request for a
variance from the container
requirements. The request for a variance
under this section shall consist of a
short statement describing why the
841
Federal Repster / Vo!. 52. No. 115 / T^igsday, fune 16. t^7 / Rulea and Regulations 22915
nurmaily fipplicable container
requirements .ire inappropriate for the
rcgiiluted article which the person
proposes to move and what t^mtainer
lequirements the person would use in
lieu of the normally prescribed container
requirements. USDA shall advise die
resfKmsibie person in writing at the time
a permit is granted on the person’s
request for a variance.
9340.7 Coat charges.
Tlie ser.'ices of the inspector during
regularly assigned hours of duty and at
the u.suHi places of duty shall be
furnished without cost.* Ibe U.k
Department of Agriculture will not be
responsible for any costs or charges
* He Dciwriineiit's |>r*v)a>on« lelalias to
oveitinc Dorset for «n imfiector'e MWicot •reeei
forik in f cm P»rt SSI.
incident to inspections or compliant*:
with the provisions of this part, other
than for the services of the inspector.
Done 8t Washington. DC. this lOlh day of
{uoe. 19^.
D.Husaik.
Acting Deputy Adiniiustrotor. Plont
Protection and QtHtrantim. Animal and Plant
Health imp«:tion Service.
}FR Doc 87.13589 Filed 8-15-87: B:4S am]
aiLUNGeooc Mte-sMi
842
RECEIVED
By APHIS BRS Document Control Officer at 3:16 pm. Aug 06, 2010
Forage
'"^“Genetics
iitirmfioRil
August 6, 2010
Forage Genetics International
N5292 Gills Coulee Road
West Salem, WI 54669
(608)786-2121
Mr. Michael C. Gregoire
Deputy Administrator
Biotechnology Regulatory Services
Animal and Plant Health Inspection Service
U.S. Department of Agriculture
4700 River Road, Unit 98
Riverdale, MD 20737
Re; Environmental Report ■ Partial Deregulation Measures for Cultivation of
Roundup Ready® Alfalfa Events J101/JI63
Dear Mr. Gregoire:
Forage Genetics International, LLC (“FOr’), a wholly owned subsidiary of Land
O’Lakes, Inc. (“Land O’Lakes”), is an alfalfa breeding and seed production company and
one of the original petitioners who sought a determination of non-regulated status for
glyphosate-tolerant alfalfa in Docket No. APHIS-2007 -0044, On behalf of the
cooperative members of Land O’Lakes and our customers, we are writing to request that
the Animal and Plant Health Inspection Service (“APHIS”) grant a temporary “partial
deregulation” or implement other administrative interim measures to mitigate the harm to
the interests of those members and farmers resulting from delays in commercial planting
of glyphosate-tolerant alfalfa. We request that such measures be implemented until such
time as APHIS concludes its review of the petition for non-regulated status and its new
decision on the petition takes effect. The proposed interim measures are consistent with
the type of partial deregulation discussed recently by the U.S. Supreme Court in the
Geertson case.
Land O’Lakes
Land O’Lakes is a farmer-owned food and agricultural cooperative representing the
interests and needs of more than 300,000 direct and indirect members across America.
Land O’Lakes was organized in 1921 with the goals of enabling a stronger presence in
the marketplace and of giving farmer-members a stronger voice in their own economic
destinies. As a farmer-owned cooperative. Land O’Lakes proved to be an idea, and an
organization, that worked for its producer-members. In the late 1920s, members asked us
843
to take that cooperative idea into the agricultural inputs marketplace, and we entered the
farm supply business. Our goal at that time was to provide farmer-members a secure,
competitively priced supply of high-quality inputs. It was from those beginnings that our
current Feed, Seed and Crop Protection Products businesses were born. Innovation is a
hallmark of Land O’Lakes’ performance in both agricultural inputs and the food side of
our business.
Our structure as a cooperative continues to benefit members in a variety of ways:
generating market access (and capturing value from the market) for our farmer-members;
providing a secure source of high-quality agricultural inputs; enabling members to
participate in the profits/losses generated by our businesses; and developing and
delivering new products and services tailored to member needs. And, through their
representation on our board of directors, our farmer-members exercise control over the
strategic direction of the cooperative. Ultimately, a key element in determining that
strategic direction is our stated Mission of “optimizing the value of our members’ dairy,
crop and livestock production.”
A Leader in Agricultural Technology
FGI is a vertically integrated alfalfa seed company involved in basic R&D, plant
breeding/product development, seed production, sales and marketing of alfalfa seed. Our
research efforts include the development of biotechnology traits and conventional
breeding. The seed products we develop are sold in both the U.S. and export markets, and
to both conventional and organic alfalfa producers.
We see significant grower value for biotechnology traits, but understand that there are
sectors of the U.S. and global markets that will choose not to plant alfalfa with these
traits. The continued success of our business depends on our ability to serve all of these
markets - biotechnology, conventional and organic - and includes a commitment to
stewardship practices that enable market and environmental coexistence. Again, this
dedication to sound science and producer choice is an important part of our company
culture.
Biotechnology can play a significant role in the future of alfalfa, which is the fourth
largest crop grown in the U.S, and is a key component of the diet of dairy cows. Alfalfa
acres have been declining over the past 20 years, due in part to weed and quality issues.
Additionally, growers have reduced the amount of alfalfa planted in part because the
availability of biotechnology in other crops provides growers a better opportunity to
manage production risks compared to growing conventional alfalfa. As acres of alfalfa
decline, so too do the benefits that alfalfa provides as a key contributor to sustainable
agriculture, including:
o Nitrogen fixation/crop rotation benefits
o Reduced soil erosion compared with row crops
o Deep, extensive root systems that improve soil tilth and sequester
cai'bon
2
844
o Key source of digestible fiber and protein that can be produced
right on the farm for the diet of dairy cows.
In order to address the problems in alfalfa caused by weed and quality issues, FGI has
worked with Monsanto Company (“Monsanto”) to develop glyphosate-tolerant alfalfa
known as Roundup Ready® alfalfa (“RRA”). Under an exclusive license from Monsanto,
FGI has been the developer, a seed producer, and seller of RRA. FGFs alfalfa breeding
program developed all of the initial RRA cultivars and, along with one other seed
company licensed by FGI, has contracted the production of all of the RRA seed sold prior
to March 2(X)7. All seed harvested thereafter was placed in controlled storage subject to
Court Order and APHIS Administrative Rule. Though it is FGFs intent to license other
alfalfa breeding companies to develop RRA varieties in the future, FGI is currently the
sole source of seed available for RRA varieties for planting. The RRA seed is to be sold
by seed companies that are licensed by Monsanto to sell the product to licensed forage
growers.
History of RRA
RRA was deregulated in June 2005 by APHIS following preparation of an Environmental
Assessment (which included public comment) and the issuance of a Finding of No
Significant Impact - a process consistent with 78 prior or more recent deregulation
decisions issued by the agency.
In February of 2007, Judge Charles Breyer of the United States District Court for the
Northern District of California held that APHIS had not taken a sufficiently “hard look”
in its Environmental Assessment of RRA at certain specific issues in support of the
agency’s decision to deregulate RRA. Judge Breyer’s determination focused principally
on the potential for gene flow from RRA to conventional or organic alfalfa seed fields,
noting that alfalfa seed production has traditionally occurred in certain fairly concentrated
areas of certain Western states. Although Judge Breyer also expressed concern regarding
a possibility of flowering by alfalfa forage crops, APHIS’ experts, along with multiple
academic experts, concluded that the possibility for gene flow from one forage field to
another was highly remote. The evidence submitted in the case also indicated that RRA
growers would suffer significant harm in excess of $200 million from a halt in their
ability to plant and use RRA for forage production for crop years 2007, 2008 and spring
2009.
Judge Breyer issued a preliminary injunction in March 2007 preventing any new planting
of RRA beginning March 30, 2007, and subsequently issued a permanent injunction in
May 2007 that enjoined further planting and sale of RRA pending completion of an
Environmental Impact Statement ("EIS”). The injunction allowed the continued harvest
of hay and seed production fields established prior to March 30, 2007, subject to certain
conditions imposed by the court. Finally, the court enjoined APHIS from granting the
RRA deregulation petition "even in part” before preparation of an EIS.
® Roundup Ready is a registered trademark of Monsanto Technology LLC.
3
845
During the remedy phase in Judge Breyer’s court, APHIS representatives testified that
they believed the agency would conduct an EIS within two years of the court order.
Based largely on APHIS’ estimated timeline, FGI elected to honor its seed production
contracts with individual seed growers rather than pay to terminate these contracts. FGI
purchased seed from the seed growers of RR A varieties produced in 2007, 2008 and
2009. All RRA seed purchased by FGI during these years was produced under multi-
year grower contracts in place prior to the injunction. FGI also recalled from its seed
company customers, who in turn recalled from their customer-growers, RRA seed
produced and shipped but not planted prior to March 30, 2007. Thus, millions of pounds
of RRA seed are in controlled storage.
Preparation of the EIS has taken APHIS longer than anticipated. Next spring will mark
the fourth anniversary of the injunction and the EIS has not been completed.
Impacts of Geertson Litigation - The Risk of Further Delay
Although all RRA seed is now in storage conditions designed to optimize medium-term
seed viability, seed quality is beginning to deteriorate. Based on our tracking of changes
in germination percentages over the last 12 months, and our experience with typical
patterns in seed quality decline, we believe that missing the spring 201 1 commercial
planting opportunity would place a significant volume of seed stocks at risk of
deteriorating below current Certified Seed quality standards.
Any further delay in commercial planting opportunity would greatly increase potential
losses. The RRA inventory described above, and the risk associated with this inventory,
is owned by FGI, and passed on to our parent company and, ultimately, its farmer-
members.
Prior to Judge Breyer’s injunction, approximately 5,500 growers planted about 250,000
acres of RRA in the fall 2005, spring 2006, fall 2006, and/or truncated spring 2007
planting seasons. In a survey of a random sampling of these 5,500 RRA growers, farmers
self-report a yield advantage of 0.9 tons/per acre/per year for RRA, when compared to
conventional hay production on their farms. Based on average current hay prices, that
translates into a $1 10 per acre/per year farm-gate advantage. Based on expected potential
sales in the spring of 201 1 , typical planting rates and an average four- year rotation, the
aggregated incremental value of RRA associated with .spring 201 1 planting alone is
approximately $160 million.
A missed opportunity to plant RRA in spring 201 1 is lost income for alfalfa growers,
particularly important during the recent period of lower hay prices and a difficult dairy
economy.
Request for Temporary Paitial Deregulation or Other Interim Measures
The District Court’s injunction on planting of RRA was ultimately appealed to the U.S.
Supreme Court. In its decision of June 21, 2010, the Court overturned Judge Breyer’s
4
846
injunction and specifically anticipated the ability of APHIS to take interim measures by
partially deregulating RRA with appropriate mitigation conditions during the continued
preparation of the EIS. In the Supreme Court’s own words, “a partial deregulation need
not cause respondents any injury at all, much less irreparable injury; if the scope of the
partial deregulation is sufficiently limited, the risk of gene flow to their crops could be
virtually nonexistent.” The Supreme Court remanded the Geertson case for further
proceedings consistent with its June 21 opinion.
In the interest of our farmer member/owners and alfalfa growers in general, we are
requesting that APHIS grant such an interim partial deregulation of RRA. Our co-
petitioner, Monsanto, concurs in this request. Enclosed for your reference is an
Environmental Report which discusses a set of proposed interim measures, consistent
with the mea.sures discussed recently by the Supreme Court, along with the potential
environmental impact of those measures. We set forth these proposed measures and
conditions of use in the context of the ongoing RRA litigation. Although there has been
no evidence of any actual harm to the environment from multiple years of RRA seed and
forage crop cultivation to date, these measures are nevertheless crafted to further
minimize (if not eliminate) any perceived risks previously identified in the litigation
context. In short:
• For RRA seed production, only eight pre-authorized seed grower consortia at
physically isolated locations would be allowed during this interim period. The
seed growers at these specific pre-authorized locations have requested the
opportunity to produce RRA seed and would be required to follow the best
management practices of the National Alfalfa and Forage Alliance (“NAFA”).
These best practices have been adopted by the industry as standards for any future
RRA seed production as part of an overall stewardship program designed to
ensure coexistence of various alfalfa hay and seed markets. In addition, certain
minimum isolation requirements for RRA seed fields would be increased during
this interim period.
• For production of RRA forage (i.e., hay or haylage), our request includes a
number of interim measures, including seed identification requirements, field
tracking and geographic restrictions that would locate the very large majority of
these RRA forage production acres in areas with no alfalfa seed production at all.
It is important to note that over 99% of the alfalfa planted in the United States is
planted for harvest as forage.
Conclusion
In sum, we propose that APHIS grant our request for limited interim measures designed
to mitigate harm to thousands of growers until APHIS’ final decision on the petition for
non-regulated status takes effect. By granting our request for partial deregulation of
RRA, APHIS would protect the interests of agriculture and consumers and, at the same
time, address potential environmental impacts cognizable under the National
5
847
Environmental Policy Act by providing for a negligible risk of gene flow from RRA
plantings.
FGI, Land O’ Lakes and our farmer member/owners appreciate the efforts APHIS has
made to address the challenges that have been raised to the commercialization of RRA
and pledge our continued support and cooperation as we face the challenges that lie
ahead. Your prompt consideration of this request for interim administrative action will
be greatly appreciated. Please contact me with any questions concerning this request.
Sincerely,
Mark McCaslin, PhD
President
Enclosure
cc: Monsanto Company
6
848
RECEIVED
By APHIS BRS Document Control Officer at 3:12 pm, Aug 06, 2010
ENVIRONMENTAL REPORT
Partial Deregulation Measures for Cultivation of
Roundup Ready® Alfalfa Events J101/J163
August 5, 2010
849
ACRONYMS AND ABBREVIATIONS
ACCase acetyl-CoA carboxylase (enzyme)
ADF Acid detergent fiber
ai/A Active ingredient per acre
ALS acetolactate synthase (enzyme)
AMS Agricultural Marketing Service (USDA)
AOSCA Association of Official Seed Certifying Agencies
AP Adventitious presence
APHIS Animal and Plant Health Inspection Service (USDA)
ASIA American Seed Trade Association
BMP Best Management Practices
BNF Biotechnology Notification Files
BRS Biotechnology Regulatory Service (USDA APHIS)
BST Bovine somatotropin
CEO Council on Environmental Quality
CFIA Canadian Food Inspection Agency
C.F.R. Code of Federal Regulations
CRLF California red-legged frog
CTIC Conservation Technology Information Center
CTP2 Chloroplast transit peptide
d Dose
DNA Deoxyribonucleic Acid
EA Environmental Assessment
EC European Commission (EU)
EEC Estimated Environmental Concentration
EIS Environmental Impact Statement
EPA Environmental Protection Agency (U.S.)
Events J101 and J163
Environmental Report
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Acronyms and Abbreviations
8/5/2010
850
EPSPS 5-enolpyruvylshikimate-3-phosphate synthase (enzyme)
ER Environmental Report
ERS Economic Research Service (USDA)
EU European Union
FAO Food and Agricultural Organization of the United Nations
FDA Food and Drug Administration (U.S.)
FFDCA Federal Food, Drug, and Cosmetic Act
FGI Forage Genetics International
FIFRA Federal Insecticide, Fungicide, and Rodenticide Act
FONSI Finding of No Significant Impact
FQPA Food Quality Protection Act
FSANZ Food Standards Australia New Zealand
ft feet
GE Genetic engineering or genetically engineered
GM Genetically modified
GMO Genetically modified organism
GPS Global Positioning System
GR Glyphosate resistant
GT Glyphosate-tolerant
HSP70 Heat shock protein intron
IM/NRC Institute of Medicine and National Research Council
in. Inches
IPA Isopropylamine salt
lbs. Pounds
IM Institute of Medicine
kg Kilograms
Events J101 and J163
Environmental Report
Acronyms and Abbreviations
ii 8/5/2010
851
M Mendelian manner
mg Milligrams
MRID Master Record Identification Number
MT/SA Monsanto Technology Stewardship Agreement
NA National Academies
NAFA National Alfalfa and Forage Alliance
NAS National Academy of Science
NASS National Agricultural Statistical Service (USDA)
NCSA National Cattlemen's Beef Association
NDF Neutral detergent fiber
NEPA National Environmental Policy Act
No. Number
NOP National Organic Program
NRC National Research Council
OECD Organization for Economic Cooperation and Development
OFPA Organic Foods Production Act
OSTP Office of Science and Technology Policy
PNT Plant with a Novel T rait
PNW Pacific Northwest
POEA Polyethoxylated Tallow Amine
PPA Plant Protection Act
ppm Parts per million
rDNA Recombinant DNA
RED Reregistration Eligibility Decision
RfD Reference Dose
ROD Record of Decision
Events J101 and J163
Environmental Report
Acronyms and Abbreviations
Hi 8/5/2010
852
RR
Roundup Ready
RRA
Roundup Ready® Alfalfa
TUG
Technology use guide
T-DNA
Transferred DNA
UC
University of California
MO
Micrograms
U.S.
United States
U.S.C
U.S. Code
USDA
U.S. Department of Agriculture
USDC
U.S. District Court
WHO
World Health Organization
WSSA
Weed Science Society of America
wt
weight
Events J101 andJ163
Environmental Report
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Acronyms and Abbreviations
8/5/2010
853
TABLE OF CONTENTS
SECTION 1.0 INTRODUCTION 1
1.1 PURPOSE OF THIS ER 1
1.1.1 Background 1
1.1.2 Purpose of and need for action 3
1 .1 .3 The proposed measures 4
1 .2 RATIONALE FOR CREATION OF RRA 1 7
1 .3 SCOPE OF ENVIRONMENTAL ISSUES ADDRESSED 17
1.3.1 Gene transmission to non-genetically engineered alfalfa 17
1.3.2 Socioeconomic impacts 18
1.3.3 Consumer's choice to consume non-GE food 18
1 .3.4 Potential for development of glyphosate-resistant (GR) weeds 19
1.3.5 Cumulative effects of increased use of glyphosate 19
1 .4 FEDERAL REGULATORY AUTHORITY - COORDINATED FRAMEWORK 19
1 .4.1 USDA regulatory authority 20
1 .4.2 EPA regulatory authority 21
1.4.3 FDA regulatory authority 22
1.5 THE NATIONAL ORGANIC PROGRAM AND BIOTECHNOLOGY 22
1 .5.1 Non-GMO Project working standard 24
1 .5.2 Growth in organic and GE farming 25
1.6 COEXISTENCE IN U.S. AGRICULTURE 25
1 .6.1 Coexistence and biotechnology 25
1 .6.2 USDA position on coexistence and biotechnology 26
1.6.3 Coexistence in U.S. agriculture 26
1 .7 ROLE OF THE NATIONAL ACADEMIES IN AGRICULTURAL
BIOTECHNOLOGY 27
1.8 ALTERNATIVES 28
1 .8. 1 Alternative 1 - No Action 28
1.8.2 Alternative 2 - Partial Deregulation 29
SECTION 2.0 AFFECTED ENVIRONMENT 30
2.1 ALFALFA CHARACTERISTICS 30
2.1.1 Growth 30
2.1.2 Pollination 30
2.2 ALFALFA PRODUCTION 31
2.2.1 Forage production, general 31
2.2.2 Organic alfalfa hay production 35
2.2.3 Seed production 36
2.3 GENE FLOW 41
2.3.1 Hybridization 42
2.3.2 Seed-to-seed gene flow studies 44
2.3.3 Gene flow potential 46
2.4 ALFALFA WEED MANAGEMENT 46
2.4.1 Weed characteristics and concerns 46
2.4.2 Problem weeds in alfalfa production 47
2.4.3 Use of herbicides to control weeds 52
2.4.4 Non-herbicide weed management practices 59
2.5 HERBICIDE RESISTANCE 60
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2.6 SEXUALLY COMPATIBLE RELATIVES INCLUDING CONSPECIFIC FERAL
AND VOLUNTEER ALFALFA 63
2.6. 1 Native sexually compatible relatives 63
2.6.2 Feral and volunteer alfalfa 63
2.7 FOOD, FEED AND OTHER ALFALFA USES 65
2.8 PHYSICAL AND BIOLOGICAL ISSUES 66
2.9 SOCIOECONOMICS AND HEALTH 66
SECTION 3.0 ENVIRONMENTAL CONSEQUENCES 67
3. 1 PLANT PATHOGENIC PROPERTIES AND UNINTENDED EFFECTS 67
3.1.1 Background 67
3.1.2 Evaluation of Intended effects 70
3.1.3 Evaluation of possible unintended effects 71
3.2 WEEDINESS PROPERTIES AND FERAL CROPS 73
3.2.1 Weediness properties of alfalfa 73
3.2.2 RRA and weediness 74
3.2.3 Impacts 75
3.3 IMPACTS OF RRA FORAGE CROPS ON CONVENTIONAL AND ORGANIC
FORAGE CROPS 75
3.3.1 Pollen sources in forage production fields 75
3.3.2 Potential for gene flow in forage production fields 76
3.3.3 Potential consequences of gene flow in forage production fields 77
3.3.4 Growing and marketing alfalfa 77
3.3.5 Potential for and consequences of mechanical mixing 78
3.3.6 Impacts 79
3.4 IMPACTS FROM RRA FORAGE CROPS ON NATIVE ALFALFA 80
3.4.1 Impacts 80
3.5 IMPACTS FROM RRA FORAGE CROPS ON FERAL ALFALFA
POPULATIONS 81
3.5.1 Impacts 82
3.6 IMPACTS FROM RRA FORAGE CROPS TO RANGELAND ALFALFA
CROPS 83
3.6.1 Impacts 83
3.7 IMPACTS FROM RRA FORAGE CROPS TO CONVENTIONAL OR
ORGANIC ALFALFA SEED PRODUCTION AREAS 84
3.7.1 Impacts 85
3.8 IMPACTS FROM RRA SEED PRODUCTION 86
3.8.1 Cross-pollination 86
3.8.2 Seed Mixing 87
3.8.3 Impacts 87
3.9 LIVESTOCK PRODUCTION SYSTEMS 88
3.10 FOOD AND FEED 88
3.10.1 FDA authority and policy 89
3.10.2 FDA biotechnology consultation note to the file BNF 000084 90
3.10.3 Health Canada approval 2005 94
3.10.4 CFIA approval 2005 95
3.10.5 Japan approval 95
3. 1 0.6 Australia - New Zealand approval 95
3.10.7 Other approvals 95
3.10.8 Impacts 95
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3.11 WEED CONTROL AND GR 97
3.11.1 Weed control with conventional alfalfa 97
3.11.2 Weed control with RRA 98
3.11.3 Herbicide-resistant weeds 99
3.11.4 GR weeds 100
3.11.5 Impacts 102
3.12 PHYSICAL 103
3.12.1 Land Use 104
3.12.2 Air Quality and Climate 104
3.12.3 Water Quality 105
3.13 BIOLOGICAL 106
3.13.1 Animal and plant exposure to glyphosate 107
3.13.2 Threatened and endangered species 111
3. 1 3.3 Potential impact of exposure to RRA 113
3.14 HUMAN HEALTH AND SAFETY 113
3.14.1 Consumer health and safety 113
3.14.2 Hazard identification and exposure assessment for field workers 114
3.1 5 SOCIAL AND ECONOMIC IMPACTS OF THE PROPOSED PARTIAL
DEREGULATION 116
SECTION 4.0 CUMULATIVE IMPACTS 120
4. 1 CLASS OF ACTIONS TO BE ANALYZED 120
4.2 GEOGRAPHIC AND TEMPORAL BOUNDARIES FOR THE ANALYSIS 1 20
4.3 RESOURCES ANALYZED 121
4.4 CUMULATIVE IMPACTS RELATED TO THE DEVELOPMENT OF
GLYPHOSATE RESISTANT WEEDS 121
4.5 CUMULATIVE IMPACTS OF POTENTIAL INCREASED GLYPHOSATE
USAGE 122
4.6 CUMULATIVE IMPACTS ON LAND USE, AIR QUALITY AND CLIMATE 125
4.7 CUMULATIVE IMPACTS ON WATER QUALITY 125
4.8 CUMULATIVE BIOLOGICAL IMPACTS 126
4.9 CUMULATIVE IMPACTS ON HUMAN HEALTH AND SAFETY 131
4.10 CUMULATIVE SOCIAL AND ECONOMIC IMPACTS 131
4.11 SUMMARY OF POTENTIAL CUMULATIVE IMPACTS 132
SECTION S.O REFERENCES 1 33
Events J101 and J163 Table of Contents
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856
APPENDICES
Appendix A Monsanto Technology Stewardship Agreement (MT/SA) and accompanying
Technology Use Guide (TUG)
Appendix B National and Tier III Production Data and State Maps with County-level Detail for
the Eleven Tier III States with Seed Production greater than 100,000 lbs.
Appendix C National Alfalfa & Forage Alliance Best Management Practices for Roundup
Ready® Alfalfa Seed Production.
Appendix D Orloff, S., D.H. Putnam, M. Canevari and W.T. Lanini, Avoiding Weed Shifts and
Weed Resistance in Roundup Ready Alfalfa Systems, University of California
Division of Agriculture and Natural Resources Publication 8362 (2009).
Appendix E Effects of Glyphosate-Resistant Weeds in Agricultural Systems (Appendix G from
Draft EIS).
Appendix F Selected Comments to Draft Environmental Impact Statement from Farmers
Using Roundup Ready Alfalfa.
Appendix G Chart of Anticipated Adoption of RRA under Partial Deregulation, Prepared by
Monsanto/FGI (August 4, 2010).
Appendix H Roundup Ready Alfalfa Satisfaction Study (Study #091 113 1 108) Prepared by
Market Probe, Inc. (December 2008).
Appendix I Putnam, D. and D, Undersander. 2009. Understanding Roundup Ready Alfalfa
(full version). Originally posted on the Hay and Forage Grower Magazine web
site at:
http://hayandforage.oom/understanding_roundup_ready_alfalfa_revised.pdf
(January 1, 2009).
Appendix J Roundup Ready Alfalfa Harvesting Study, Study # 3482 (originally submitted as
Appendix 6 to Monsanto/FGI comment to draft EIS).
Appendix K Fitzpatrick, S. and G. Lowry. 2010. Alfalfa Seed Industry Innovations Enabling
Coexistence. Proceedings of the 42nd North American Alfalfa Improvement
Conference, Boise, Idaho, July 28-30, 2010.
Table 1-1 Alfalfa Seed and Hay Production Overview (State List)
Table 1 -2 Eight Seed Grower Consortia
Table 2-1 Alfalfa Forage and Seed Production by State
T able 2-2 Organic Alfalfa Hay Harvested Acreage
Table 2-3 Summary of FGI Idaho Gene Flow Studies
Table 2-4 Seed to Seed Gene Flow
Table 2-5 Weeds in Alfalfa
Table 2-6 Susceptibility of Broadleaf Weeds in Seedling Alfalfa to Herbicide Control
Table 2-7 Susceptibility of Grass Weeds in Seedling Alfalfa to Herbicide Control
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Table 2-8 Susceptibility of Weeds in Seedling Alfalfa to Herbicide Combination Control
T able 4-1 Comparison of Potential Effects of Glyphosate and Alfalfa Herbicides on
Freshwater Fish
T able 4-2 Comparison of Potential Effects of Glyphosate and Alfalfa Herbicides on
Freshwater Aquatic Invertebrates
T able 4-3 Comparison of Potential Effects of Glyphosate and Alfalfa Herbicides on Aquatic
Plants (Algae and Duckweed)
FIGURES
Figure 1-1 Table 3-9 from Draft EIS for RRA
Figure 2-1 Gene Flow
Figure 2-2 Herbicide resistance worldwide
Figure 4-1 Growth in adoption of genetically engineered crops in U.S.
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SECTION 1.0 INTRODUCTION
This Environmental Report (ER) examines the environmental impacts of cultivation of Roundup
Ready® alfalfa (RRA) lines J101 and J163 (J101/J163)' for a temporary period subject to a
range of measures, including geographic restrictions, stewardship requirements and other
limitations. This ER is provided in connection with the petitioners' supplemental request for non-
regulated status in part (commonly known as “partial deregulation") for RRA. This document is
intended to provide information that may be utilized by the United States Department of
Agriculture’s (USDA) Animal and Plant Health Inspection Service (APHIS) in complying with the
National Environmental Policy Act (NEPA)^ and its applicable regulations^ either in connection
with partial deregulation of RRA or for any other regulatory or administrative action adopting the
measures addressed herein. A partial deregulation or other administrative action adopting the
measures may be superseded at a later date after APHIS completes the Environmental Impact
Statement (EIS) and makes its determination regarding the pending petition for complete
deregulation of RRA.
Alfalfa (Medicago sativa L.) was planted on approximately 21 million acres in the U.S. in 2009.
Overall crop value was $7.9 billion in the 2009-2010 crop year. Over 99 percent of the alfalfa
planted in the U.S. is planted for harvest as forage, with less than one percent harvested for
seed. RRA, which has been genetically engineered to be tolerant to the herbicide glyphosate, is
currently cultivated on approximately 200,000 acres or less, (USDA NASS, 2010b; USDA
APHIS, 2009), pursuant to permit or court order.
1.1 PURPOSE OF THIS ER
1.1.1 Background
In April 2004, under the requirements of the Plant Protection Act (PPA)"* and its implementing
regulations,® Monsanto Company (Monsanto) and Forage Genetics International (FGI)
submitted a petition to APHIS for a determination of non-reguiated status for RRA (Rogan and
Fitzpatrick, 2004), Monsanto is an agricultural company involved in the development and
marketing of biotechnology-derived agricultural products. FGI is an alfalfa seed company and a
^ The terms RRA and glyphosate tolerant alfalfa, or GT alfalfa are used interchangeably throughout this document.
^ NEPA of 1969, as amended; Title 42 of the U.S. Code (42 U.S.C.) §§4321-4347.
3
Council on Environmental Quality (CEQ) regulations implement NEPA and are found in Title 40 of the Code of
Federal Regulations (40 C.F.R.), Parts 1500 through 1508. The U.S. Department of Agriculture has Implemented
NEPA regulations, which are found at 7 C.F.R. part lb, as has APHIS, and those are found at 7 C.F.R. part 372.
7 U.S.C. §§7701-7786.
® 7 C.F.R. Part 340.
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whoiiy-owned subsidiary of Land O’Lakes, Inc., a farmer-owned food and agricultural
cooperative representing the interests and needs of more than 300,000 direct and indirect
members across the U.S. APHIS, through its Biotechnology Regulatory Service (BRS), is one
of three federal agencies responsible for regulating biotechnology in the U.S. under the
Coordinated Framework described in Section 1.4. APHIS regulates genetically engineered (GE)
organisms that may be plant pests, the Environmental Protection Agency (EPA) regulates plant
incorporated protectants and herbicides used with herbicide-tolerant crops, and the U.S.
Department of Health and Human Services' Food and Drug Administration (FDA) regulates food
and animal feed. The FDA completed its consultation process for RRA in 2004 (Tarantino,
2004), EPA approved the use of glyphosate over the top of RRA on June 1 5, 2005. The use of
glyphosate over the top of RRA did not require an increase in the existing glyphosate residue
tolerance of 400 ppm in the animal feed, non-grass crop group. EPA issued a new glyphosate
tolerance for alfalfa seed of 0.5 ppm on February 16, 2005.®
NEPA requires federal agencies to evaluate the potential impact of proposed major federal
actions and consider such impacts during the decision-making process. After agency review for
safety, including an evaluation of relevant scientific data and all public comments relating to
potential plant pest risks and related environmental impacts, APHIS issued an Environmental
Assessment (EA) pursuant to NEPA in 2005 (USDA APHIS, 2005). Based on that EA, APHIS
reached a finding of no significant impact (FONSI) on the environment from the unconfined
cultivation and agricultural use of RRA and its progeny (USDA APHIS, 2005). Accordingly, in
June 2005, APHIS granted non-regulated status to RRA (USDA APHIS, 2005).
After RRA was deregulated, the seeds were sold and planted. During the growing season of
2005 and 2006, approximately 200,000 acres were planted in 1,552 counties in 48 states
(Alaska and Hawaii were not included), Approximately nine months after APHIS granted non-
regulated status to RRA, two alfalfa seed growers and seven associations filed a lawsuit against
the USDA over its decision to deregulate RRA, claiming that APHIS’ EA failed to adequately
consider certain environmental and economic impacts as required by NEPA. In February 2007,
the court granted the plaintiffs' motion for summary judgment, finding that APHIS is required to
prepare an EIS before approving its deregulation of RRA, and vacated APHIS’ 2005 decision to
deregulate RRA (U.S. District Court (USDC), 2007a). On March 12, 2007, the Court issued a
preliminary injunction order in the case (USDC, 2007b). The order prohibited all sales of RRA
seeds, effective on the date of the order, pending the Court’s issuance of permanent injunctive
® 40 C.F.R, §180.364; 70 Fed. Reg. 7864 (Feb, 16, 2005),
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relief; and prohibited all future planting, beginning March 30, 2007. The Court also vacated
APHIS’S deregulation determination. On March 23, 2007, APHIS published a notice in the
Federal Register describing the Court’s decision that RRA was once again a regulated article,^
On May 3, 2007, the Court issued a permanent injunction regarding the control of the RRA that
had been planted, and requiring APHIS to issue an administrative order specifying mandatory
production practices that must be implemented by RRA growers (USDC, 2007c). The Court
Issued an amended judgment on July 23, 2007, further clarifying the mandatory production
practices (USDC, 2007d). APHIS issued its administrative order on July 12, 2007 (USDA
APHIS, 2007a). In August and September 2007, USDA, Monsanto, FGI and others filed an
appeal, arguing that the injunction was improper. After the Ninth Circuit Court of Appeals
affirmed the district court decision, the U.S. Supreme Court decided to hear the case. In June
2010, in Monsanto Co. et at. v. Geerston Seed Farms et at., the Supreme Court overturned the
lower court ruling, striking down the injunction.
Following issuance of the district court’s amended judgment in July 2007, APHIS commenced
work on the EIS for complete deregulation. The Notice of Intent was published in the Federal
Register on January 7, 2008.® The notice of availability for the draft EIS was published in the
Federal Register on December 18, 2009.® In the draft EIS, APHIS preliminarily concluded that
there is no significant impact on the human environment due to granting nonregulated status to
RRA (USDA APHIS, 2009). The comment period for the draft EIS, following an extension
granted by APHIS, concluded on March 3, 2010. Approximately, 145,000 comments were
submitted. APHIS is now preparing the final EIS.
1.1.2 Purpose of and need for action
This ER has been prepared to support an anticipated EA to be prepared by APHIS with respect
to a partial deregulation of RRA, The ER examines the environmental impacts of implementing
the proposed measures laid out below, either through a partial deregulation of RRA or other
administrative means. The proposed measures would allow commercialization and
deregulation of RRA in limited areas and under specific cultivation conditions explained more
fully below in Section 1 .1 .3, If APHIS concludes that an EA supports a FONSI for the proposed
measures, APHIS could decide to implement such measures through “partial deregulation”.
^72 Fed. Reg, 13735 (Mar. 23, 2007).
® 73 Fed. Reg. 1 198 (Jan. 7, 2008),
® 74 Fed. Reg. 67205 (Deo. 18, 2009).
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1.1.3 The proposed measures
Monsanto/FGI have proposed the following measures to be implemented through partial
deregulation or other administrative means. The companies state that these measures would
allow a subset of alfalfa farmers to obtain the substantial benefits of RRA pending complete
deregulation. For example, they expect RRA to (i) offer growers a wide-spectrum weed control
option that will enhance stand establishment and increase alfalfa forage; (ii) increase flexibility
to treat weeds on an as-needed basis; (iii) allow alfalfa production on marginal land with severe
weed infestations; and (iv) provide growers with a weed control system that has a reduced risk
profile for the environment. The proposed measures include a separate set of restrictions for
RRA forage production and RRA seed production. These restrictions are described in the
sections below.
FORAGE PRODUCTION RESTRICTIONS
1) Grower Requirements : Each grower is required to abide by the terms specified in their
Monsanto Technology / Stewardship Use Agreement (MT/SA) and accompanying
Technology Use Guide (TUG), which contractually obligates growers to comply with
stewardship requirements related to growing RRA for forage, A copy of the MT/SA and
TUG are included in Appendix A.
2) RRA Seed Licensing Requirements : All RRA seed is sold through a network of
licensed seed companies and their retailers and dealers/distributors. Each seed
company is required to have a current Genuity® Roundup Ready® Alfalfa Commercial
License Agreement to sell RRA seed. This agreement specifies the limited rights of the
seed companies to market the product, including stewardship requirements associated
with RRA.
3) Seed Identification : RRA seed bag labeling and a unique purple seed colorant will be
required product identity mechanisms to notify all RRA forage growers of the presence
of the RRA trait and the geographic limitations for product use.^°
4) Crop Harvest (Forage only) : RRA fields, except as noted under “Seed Production
Restrictions” Section below, may be harvested for forage only. All growers shall adhere
to limitations as outlined in the MT/SA and TUG (Monsanto TUG, attached as Appendix
A),'”
10
Similar labeling and use agreements are typically used for the sale and stewardship of other GE crops, so growers
are currently familiar with such contractual obligations,
' ' Forage growers who have previously used RRA are familiar with this crop use limitation. See Appendix A.
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5) Geographic Restrictions for Forage Planting based on Cropping Practices :
Geographic restrictions will be placed on forage planting by state and county based on
the amount of alfalfa seed produced (see Appendix B). Data on the amount of seed
produced is from the 2007 Census of Agriculture, as summarized in Figure 1-1 (for
additional details see Table 1-1 and Appendix B). Geographic restrictions for alfalfa
forage plantings will be defined in three categories (Tiers I, II, and III) based on the
amount of alfalfa seed production reported in each state. (See Appendix B for maps).
a. Tier I: States with no reported alfalfa seed production (2007): 27 States and all
counties within each.
i. New RRA forage production plantings are allowed in accordance with the
requirements established by the TUG and Genuity® Roundup Ready®
Alfalfa Commercial License Agreement.
ii. Forage growing is the only reported crop practice for alfalfa. No
commercial alfalfa seed growth was reported in Tier I states in 2007.
However, if conventional seed production fields are now present, then
RRA forage grown near these new conventional seed production fields
are subject to the requirement provided in Restriction Enhancement A
(see Tier II. ii below).
b. Tier II: States with <100.000 lbs annual seed production (20071: 12 States and
all counties within each.
Commercial alfalfa seed production occurs in these states; however, the number
of seed growers, seed acres and cumulative pounds are limited and widely
dispersed. Only 0.51 percent of the U.S. alfalfa seed crop is produced in these
states (2007).
i. New RRA forage production plantings are allowed in accordance with the
requirements established by the TUG and Genuity® Roundup Ready®
Alfalfa Commercial License Agreement.
ii. Restriction Enhancement A applies if the RRA forage field is located
within 165 ft of a commercial, conventional alfalfa seed production field.
Under Restriction Enhancement A, the RRA grower must harvest forage
before 10 percent bloom.
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1 . Rationale for Restriction Enhancement A: In grower locations
where an individual RRA forage field is within 165 ft of a
conventional seed production field, the TUG requires the RRA
grower to mitigate RRA flowering by harvesting not later than 1 0
percent bloom stage to mitigate pollen production. RRA forage
grower compliance with the TUG’s 10 percent bloom stage
harvest has been high and rarely was it delayed by weather or
other factors. (See Appendix J). This restriction will address
mitigations at or near geographic (county, state and federal)
borders. The 165 ft distance is the science and market-based,
industry recognized isolation distance for certified alfalfa seed
crops (see Association of Official Seed Certifying Agencies
(AOSCA), 2009); and, the potential extent of gene flow of 10
percent bloom hay to nearby seed crops is de minimis at 165 ft
(Teuber and Fitzpatrick, 2007; Van Deynze et al., 2008).
c. Tier III: States each having >100.000 lbs annual seed production (20071: 1 1
States. Enhanced restrictions to be applied based on predominant county
cropping practices. In the eleven states with greater than 100,000 acres of
annual alfalfa seed production, additional by-county geographic restrictions will
apply. In many cases, within each state, seed acreage is geographically
concentrated and typically localized to a few specific counties where climate is
suitable for seed growing. (See geographic maps for each of these states in
Appendix B.) In these states, alfalfa seed is typically grown by professional
growers under seed company contracts and official seed certification Inspection
programs are widely used by growers and the contracting seed companies.
Alfalfa forage production is also a major enterprise in these states and in many
cases it is geographically separate from seed crop acres.
i. By-County criterion used to determine eligibility for new RRA forage
plantings.
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a. New RF?A forage production is allowed in accordance with
the requirements established by the TUG and Genuity®
Roundup Ready® Alfalfa Commercial License Agreement.
b. Restriction Enhancement A: If RRA forage field is located
within 165 ft of a conventional alfalfa seed field, RRA
grower must harvest forage at or before 10 percent bloom.
c. Restriction Enhancement B: All RRA forage growers are
required to report GPS coordinates of ail RRA forage field
locations. GPS field location information is available for
monitoring and enforcing the planting restrictions
applicable to RRA forage fields.
d. Forage production is the only reported crop practice in
these counties. Commercial alfalfa seed growing is not
reported.
2. Counties with seed production reported (Appendix B).
a. Restriction Enhancement C: New RRA forage plantings
are not allowed in counties with commercial alfalfa seed
production.
b. Commercial alfalfa seed growing is a predominant activity
in these counties
c. 99.5 percent of U.S. aifalfa seed production is in these
counties.
6) Summary of Allowed Foraoe Production Scope:
a. Nationwide, the counties excluded from new RRA forage production under the
requested partial deregulation represent 99,5 percent and 21.84 percent of the
alfalfa seed production pounds (lbs) and forage production acres, respectively
(See Appendix B).
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b. Nationwide, the counties where new RRA forage plantings are allowed (with
various restrictions) include 0.5 percent and 78.16 percent of the alfalfa seed
production (lbs) and forage production acres, respectively.
7) Monitoring and Enforcement of Forage Crop Restrictions
Support and enforcement of the partial deregulation of RRA for forage production would
be accomplished by the following mechanisms.
a. Education and Communication: Education and communication activities would
be conducted with hay growers, seed dealers/seliers and seed companies.
Examples of these activities include training and information sessions for dealers
and sellers, detailing the requirements for selling RRA, sales meetings, periodic
visits with growers and sellers, and computer based training modules that can be
tailored to specific areas of focus related to the product and requirements.
i. Training: Online training would be required for each seed company staff
member handling RRA as well as the appropriate personnel at
Monsanto/FGI.
ii. The MT/SA and accompanying Monsanto TUG: The MT/SA and
accompanying TUG, a legal agreement between growers who utilize
Monsanto technologies and Monsanto, would be updated to include direct
reference to the partial deregulation conditions, including the limitations
pertaining to where RRA forage can be grown and hay and forage
management practices.
iii. Packaging Updates: In addition to being clearly labeled as RRA seed,
all bags of finished product would have an additional prominent tag that
lists the states and counties in which the product could not be planted. In
addition the seed would have a unique coating color (purple) that
identifies it as being RRA seed.
iv. Dealer Requirements: All dealers selling RRA would sign a dealer
agreement legally binding them to adhere to the partial deregulation
requirements.
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V. Industry Communications; Alfalfa industry-specific groups would be
utilized to support communication of the partial deregulation requirements
in communications to their members. These include National Alfalfa and
Forage Alliance (NAFA), American Seed Trade Association (ASTA), etc,
vi, RRA Information Line; A toll free number will be available for growers
or other individuals to clarify information or answer questions regarding
the partial deregulation,
b. Assessment and Verification; Multiple assessment and verification tools will
be utilized to monitor and verify adherence to the partial deregulation request,
i. Reconciliation of Sales Data: All sales to hay growers will be reconciled
with remaining RRA seed inventory at the end of the planting season
(twice per year). This reconciliation will be part of a legal commercial
requirement of the seed companies and dealers selling RRA,
11, GPS coordinates: GPS coordinates will be collected on all sales in the
eleven (11) Tier III states. The GPS coordinates will be collected on all
fields planted with RRA. Information will be validated at time of receipt;
questionable data will be reviewed.
ill. Hotline: A toll-free hotline will be available for individuals to report
violations to the partial deregulation ruling,
c. Proactive Sampling, Testing and Review, inclusion of third parties: Various
internal and/or third parties will be utilized to randomly review plantings and to
determine grower compliance with the conditions of the partial deregulation.
d. Enforcement: Violations of the partial deregulation decision will have the
following impacts:
i. Grower: T akeout of the alfalfa field in violation would be required.
Grower has the potential to lose access to RRA.
ii. Dealer: Any dealer incentive payments would be at risk. In addition,
dealers would also risk losing their ability to sell RRA in the future.
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iii. Seed Company: Any seed company incentive payments would be at
risk. In addition, seed companies would also risk losing their ability to sell
RRA in the future.
e. Ongoing Measurement: An annual report would be prepared by FGI for the
USDA summarizing activities in all areas identified above. Additional data would
be provided upon request.
f. Any potential additional investigation or action would be conducted in
accordance with all federal, state and local laws concerning individual property
rights, inspections and sampling activities. Monsanto has demonstrated that it
does not exercise its patent rights where trace amounts of patented seeds or
traits are present in a farmer's fields as a result of inadvertent means.
Table 3-9. State Production of Alfalfa Seed (2007 Census of Aqriculture).
state
Farms
Seed Acres
Harvested
Pounds of
Seed
Harvested
California
114
36,625
19,083,458
Washington
82
17,127
10,860,608
Idaho
92
12,788
9,346,709
Wvominq
62
10,548
5,915,816
Nevada
19
6.498
4.237,101
Montana
80
10,338
3,729,635
Orecjon
32
4,959
Utah
54
3,803
2,077,813
Arizona
53
5,206
1.902,669
South Dakota
47
6,014
428,447
Oklahoma
29
2,004
281,121
Texas
24
646
79,885
Minnesota
17
611
63,461
Missouri
19
399
40.540
North Dakota
6
34,784
15
310
29,907
Kansas
5
342
22,430
Nebraska
29
546
21,216
Michigan
10
(D)
15,610
New York
3
27
6,180
Iowa
5
(D)
(0)
Ohio
lin|||||[[|H
(D)
(D)
Colorado
8
1,815
ffi)
(0): Data withhtid to avoid disclosing data for incfividual farms.
Figure 1-1. Table 3-9 from Draft EIS for RRA.
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Table 1-1 Alfalfa Seed and Hay Production Overview (State Li
868
invironmental Repoi
CAROLINA
869
870
lepol
871
RRA SEED PRODUCTION RESTRICTIONS
The National Alfalfa and Forage Alliance (NAFA) used current science and extensive
stakeholder input to design the “Best Management Practices (BMP) for Roundup Ready Seed
Production” (See Appendix C in this ER for additional details on BMPs for Roundup Ready®
Alfalfa Seed Production). These BMP have been adopted by the industry as standards for any
future RRA seed production as part of an overall stewardship program designed to ensure
coexistence of various alfalfa hay and seed markets. All RRA seed grower contracts require full
adherence to the NAFA BMP, a type of identity preserved process-based seed stewardship,
which includes but is not limited to the following measures:
• RRA seed field location reporting to official seed certification agencies
• Field and isolation zone inspection by official seed certification agencies
• Equipment cleaning prior to and after use
• Segregated and uniquely identified seed handling and storage
• Planting stockseed labeling
• FGI RRA seed grower education and contracting
• Field termination reporting
• Seed company monitoring of compliance
• Annual third-party review of efficacy of BMP
• Other
FGI has individual seed-producer farmer partners who have asked for the opportunity to
produce RRA seed crops.
Partial deregulation of RRA would include seed production that is restricted to eight defined
seed grower consortia (Table 1-2), FGI has determined that each of these individual consortia
could meet or exceed the National Alfalfa & Forage Alliance BMP for RRA Seed Production
(NAFA, 2008a) parameters and the proposed partial deregulation enhancements to isolation
distance described below (See Appendix C and Table 1-2).
1) Seed Identification : Stockseed container to be clearly labeled as containing RRA trait
seed. Grower seed contracts and official field reporting will notify each seed grower
regarding the measures imposed for seed growing.
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2) Implement all NAFA BMP with Isolation Enhancement
a. All BMP measures will be followed, documented, monitored and enforced for
compliance by FGI or its representatives. In addition, each field will be inspected
annually by the local seed certification agency, confirming minimum isolation
standards for that production year.
b. Measures will set the enhanced, minimum, isolation requirements for RRA seed
fields as follows. The minimum required isolation from conventional, commercial
seed fields will be 4 miles and 1 mile, when honeybees or leafcutter bees are the
managed pollinating species, respectively.
c. The potential for gene flow at NAFA BMP isolation is de minimis (Van Deynze et
al. 2008) and this measure’s proposed enhancement of isolation distance would
further ensure de minimis gene flow potential into conventional seed crops
should they be present.
3) Geoafaphic Restrictions :
a. Only eight pre-authorized, physically-isolated locations for RRA seed production
will be allowed. Each location of proposed seed growing is composed of one to
three large seed growers who will act together to manage isolation control within
a local, informal RRA seed grower consortium.
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1 .2 RATIONALE FOR CREATION OF RRA
Alfalfa is a small seeded perennial forage crop that competes with annual weeds during
establishment and with annual and perennial weeds in established stands. With irrigated alfalfa
stands, weed seeds in irrigation water can reinfest the stand with weed seeds with every
irrigation event. Weed infestation increases the risk of successful establishment and weeds
generally compete with alfalfa for light, water, and nutrients. Weeds can have an adverse affect
on the quality of harvested forage and effectively shorten the productive life of the alfalfa stand.
RRA offers alfalfa growers a simpler, more effective, more flexible, and less expensive herbicide
alternative for weed control. Current weed control programs in alfalfa production have serious
limitations because certain weed species are difficult to control. Certain of these difficult to
control weeds are poisonous and/or toxic to livestock. Glyphosate applications to RRA will offer
flexibility In timing of weed control, including preplant, preemergence and/or postemergence
applications. In contrast to most other commonly used alfalfa herbicides, glyphosate can safely
be applied at virtually any stage of GT alfalfa development. The use of GT alfalfa can help
increase alfalfa forage yield and forage quality through better weed control (Rogan and
Fitzpatrick, 2004, pp. 20-21; Medlin and Siegelin, 2001).
Glyphosate is not used for in-crop weed control in conventional alfalfa (those without glyphosate
tolerance) because it damages the plants. With GT alfalfa, growers have another option for
weed control,
1 .3 SCOPE OF ENVIRONMENTAL ISSUES ADDRESSED
During the lawsuit discussed above, certain specific issues were identified by the court as
requiring additional NEPA analysis by APHIS (USDC, 2007). These primary issues are
described below and are addressed in the Affected Environment and Environmental
Consequences sections of this ER. Other issues identified by APHIS in the draft EIS are also
addressed to the extent they are relevant to the proposal for partial deregulation to ensure full
disclosure and analysis of any potential impacts associated with partial deregulation of RRA
under the proposed measures. Many of the citations herein are to the draft EIS discussions of
the basic facts regarding alfalfa, its weed threats and cultivation.
1.3.1 Gene transmission to non-genetically engineered alfalfa
Alfalfa is a perennial crop and is typically replanted every three to six years. The crop is
typically harvested for forage three to eight times per year, depending on location and seasonal
climate. Most alfalfa in the U.S. is harvested in the late vegetative stage (pre-bloom) to optimize
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yield and nutritional quality. Forage quality begins to drop dramatically in hay harvested after
the flowering stage, and continues to deteriorate as the crop further matures toward pod/seed
set (USDA APHIS, 2009, p. 40), Hay harvested after 10 percent bloom is generally of poor
quality for feed and has low market value (USDA APHIS, 2009, p. G-6). This leaves little
opportunity for pollination among forage crops. Alfalfa is exclusively pollinated by bees which
normally pollinate other alfalfa plants growing in close proximity. However, pollinations at
greater distances can occur (e.g, less than 1 to greater than 3 miles depending upon the bee
species).
In contrast, growers promote flowering and seed ripening in commercial seed fields. In most
fields, flower buds begin to form on stems approximately 4 to 6 weeks after field mowing during
long-day photoperiods and warm weather. Once alfalfa begins flowering, it flowers
indeterminately, and its duration depends on moisture, temperature, and other factors (Rogan
and Fitzpatrick, 2004). Ripe seed, viable for germination, is formed 5 to 6 weeks after
pollination (i.e., 9 to 12 weeks total after mowing). Seed harvested before this stage is not
viable.
Cross-pollination between RRA and conventional or organic alfalfa crops could potentially result
in the inadvertent presence of GE material in conventional or organic alfalfa hay intended for a
market with specific or zero tolerance for the presence of GE material. Putnam (2006)
estimated that the GE sensitive hay market is approximately 3 to 5 percent of the total market.
He estimated that the majority of the market (95 to 97 percent) is composed of growers that may
either adopt RRA varieties and/or are not likely to be GE sensitive in their buying decisions.
Detailed analysis of the potential for gene transmission from RRA has been conducted.
Potential impacts from both hay and seed production on organic and conventional hay and seed
production, other Medicago crops, and feral populations of alfalfa are analyzed in Sections 3.3
through 3.8 of this ER. A study of the topic was separately published (Van Deynze et al., 2008).
1.3.2 Socioeconomic impacts
The court found that APHIS failed to analyze in its initial EA the socio-economic impacts of
deregulating RRA on organic and conventional farmers. Therefore, further analysis was
conducted and is discussed in Sections 3.15 of this ER.
1 .3.3 Consumer’s choice to consume non-GE food
The court found that APHIS failed to analyze the possibility that deregulation of RRA would
degrade the human environment by eliminating a consumer's choice to consume, or a grower’s
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choice to grow, non-GE food. Therefore, further analysis was conducted and is discussed in
Section 3.10 of this ER.
1.3.4 Potential for development of glyphosate-resistant (GR) weeds
As the adoption of GT crops has grown, the use of glyphosate has increased (National
Research Council [NRC], 2010, Figures S-1, S-2, and S-3; Young, 2006). Concerns have been
expressed that increased use of glyphosate may lead to development of GR weeds. Further
analysis was conducted and is discussed in Sections 2,4 and 3.1 1 of this ER.
1 .3.5 Cumulative effects of increased use of glyphosate
Further analysis of cumulative impacts from increased use of glyphosate was conducted and is
discussed in Section 4 of this ER.
1.4 FEDERAL REGULATORY AUTHORITY - COORDINATED FRAMEWORK
Interagency coordination in scientific and technical matters is the responsibility of the federal
Office of Science and Technology Policy (OSTP), which was established by law in 1976. A
large part of the OSTP’s mission is “to ensure that the policies of the Executive Branch are
informed by sound science” and to “ensure that the scientific and technical work of the
Executive Branch is properly coordinated so as to provide the greatest benefit to society"
(OSTP, undated).
In 1986, the OSTP published a “comprehensive federal regulatory policy for ensuring the safety
of biotechnology research and products”, the Coordinated Framework for the Regulation of
Biotechnology (Coordinated Framework) (OSTP, 1986). The OSTP concluded that the goal of
ensuring biotechnology safety could be achieved within existing laws (OSTP, 1986).
The Coordinated Framework specifies three federal agencies responsible for regulating
biotechnology in the U.S.: USDA’s APHIS, the EPA, and the FDA. APHIS regulates GE
organisms under the PPA of 2000, EPA regulates plant-incorporated protectants and
herbicides used with herbicide-tolerant crops under the Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA) and Federal Food, Drug, and Cosmetic Act (FFDCA). FDA regulates
food (including animal feed, but not including meat and poultry, which is regulated by USDA),
including food and feed produced through biotechnology, under the authority of the FFDCA,
Products are regulated according to their intended use and some products are regulated by
more than one agency. Together, these agencies ensure that the products of modern
biotechnology are safe to grow, safe to eat, and safe for the environment. USDA, EPA, and
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FDA enforce agency-specific regulations to products of biotechnology that are based on the
specific nature of each GE organism.
In 2001, in a joint Council on Environmental Quality (CEQ)/OSTP assessment of federal
environmental regulations pertaining to agricultural biotechnology, the CEQ and OSTP found
that “no significant negative environmental impacts have been associated with the use of any
previously approved biotechnology product” (CEQ/OSTP, 2001, p. 1).
For RRA, the plant is reviewed by USDA and FDA, whereas EPA is responsible for registering
the use of the glyphosate herbicide and establishing a tolerance for allowable giyphosate
residues.^^ As indicated herein, although certain issues such as weed resistance and impacts
of glyphosate on animals or plants are addressed by EPA (not APHIS), this ER nevertheless
addresses those issues.
1.4.1 USDA regulatory authority
The APHIS BRS mission is to protect U.S. agriculture and the environment using a dynamic and
science-based regulatory framework that allows for the safe development and use of GE
organisms. Under its authority from the PPA, APHIS regulates the introduction (importation,
interstate movement, or release into the environment) of certain GE organisms and products.’^
A GE organism is presumed to be a regulated article if the donor organism, recipient organism,
vector, or vector agent used in engineering the organism belongs to one of the taxa listed in the
regulation^'’ and is also presumed to be a plant pest. APHIS also has authority under these
rules to regulate a GE organism if it has reason to believe that the GE organism may be a plant
pest or APHIS does not have sufficient information to determine that the GE organism is unlikely
to pose a plant pest risk.’®
Under APHIS’ regulations a person may petition APHIS to evaluate submitted data and
determine that a particular regulated article is unlikely to pose a plant pest risk, and, therefore,
should no longer be regulated.’® The petitioner is required to provide information related to
plant pest risk that the agency may use to determine whether the regulated article Is unlikely to
^ Under the FFDCA and associated regulations, EPA sets a tolerance, or maximum residue limit, for pesticide
treated food and feed items. A tolerance is the amount of pesticide residue allowed to remain in or on each treated
food commodity. The tolerance is the residue level that triggers enforcement actions. That is, if residues are found
above that level, the commodity will be subject to seizure by the government.
7 C.F.R. §340,
7 C.F.R. §340.2.
’*7 C.F.R. §340.1,
’® 7 C.F.R. §340,6, entitled “Petition for determination of non-regulated status'.
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present a greater plant pest risk than the unmodified organism.’^ If the agency determines that
the regulated article is unlikely to pose a plant pest risk, the GE organism will be granted non-
regulated status. In such a case, APHIS authorizations (i.e. permits and notifications) would no
longer be required for environmental release, importation, or interstate movement of the non-
regulated article or its progeny.
It was under these regulations that Monsanto/FGI submitted the petition for a determination of
non-regulated status for event J101/J163 (Rogan and Fitzpatrick, 2004), J101/J163 alfalfa were
considered regulated because they contain non-coding deoxyribonucleic acid (DNA) segments
derived from plant pathogens and the vector agent used to deliver the transforming DNA is a
plant pathogen (See Section 3,1 for a discussion of these concepts) (USDA APHIS, 2005, p. 5).
1 .4.2 EPA regulatory authority
EPA is responsible for regulation of pesticides (including herbicides such as giyphosate) under
the FIFRA,'® FIFRA requires that all pesticides be registered before distribution, sale, and use,
unless exempted by EPA regulation. Before a product is registered as a pesticide under FIFRA,
it must be shown that when used in accordance with the label, it will not result in unreasonable
adverse effects on the environment.
Under the FFDCA, as amended,’® pesticides added to (or contained in) raw agricultural
commodities generally are considered to be unsafe unless a tolerance or exemption from
tolerance has been established. EPA establishes residue tolerances for pesticides under the
authority of the FFDCA. EPA is required, before establishing a pesticide tolerance to reach a
safety determination based on a finding of reasonable certainty of no harm under the FFDCA,
as amended by the Food Quality Protection Act of 1996 (FQPA). The FDA enforces the
tolerances set by the EPA. EPA approved the use of giyphosate over the top of RRA on June
15, 2005. The use of giyphosate over the top of RRA did not require an increase in the existing
giyphosate residue tolerance of 400 ppm in the animal feed, non-grass crop group; this
tolerance supports the feeding of alfalfa forage that has been treated with giyphosate to
livestock. EPA issued a new giyphosate tolerance for alfalfa seed of 0,5 ppm on February 16,
2005.^“
7 C.F.R. §340.6(0)(4).
’®7U.S.C. §136etS6q.
’®21 U.S.C, §301etseq,
40 C.F.R. §180,364: 70 Fed. Reg. 7861 (Feb, 16, 2005).
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1.4.3 FDA regulatory authority
FDA, which has primary regulatory authority over food and feed safety, has published a policy
statement in the Federal Register concerning regulation of products derived from new plant
varieties, including those genetically engineered (FDA, 1992). Under this policy, FDA uses a
consultation process to ensure that human food and animal feed safety issues or other
regulatory issues (e.g. labeling) are resolved prior to commercial distribution of a bioengineered
food. Monsanto/FGl submitted a food and feed safety and nutritional assessment summary for
RRA to FDA in October 2003. FDA completed its consultation process in 2004 (Tarantino,
2004; Hendrickson and Price, 2004). FDA's analysis and related impacts are discussed in
Section 3.10.
1 .5 THE NATIONAL ORGANIC PROGRAM AND BIOTECHNOLOGY
Congress passed The Organic Foods Production Act (OFPA) of 1990 to avoid the confusion
and misrepresentation then taking place in the “organic” marketplace.^' The OFPA required the
USDA to establish a National Organic Program (NOP) to develop uniform standards and a
certification process for those producing and handling food products offered for sale as
“organically produced.”^^ The OFPA requires certification under the NOP, which was finalized
in 2000, to be process-based.^® “The certification process does not guarantee particular
attributes of the end product; rather it specifies and audits the methods and procedures by
which the product is produced” (Ronald and Fouche, 2006), The NOP defines certain “excluded
methods" of breeding that cannot be used in organic production, describing them as “means
that are not possible under natural conditions or processes. Along with genetic engineering,
three other modern breeding techniques are specified as “excluded methods” in the
regulations.®® Thus, a certified organic grower cannot intentionally plant seeds that were
developed by these specific excluded methods. However, because “organic" is based on
process and not product, the mere presence of plant materials produced through excluded
methods in a crop will not jeopardize the integrity of products labeled as organic, as long as the
grower follows the required organic production protocol. Also, other modern breeding methods -
®’7U.S,C. §6501 etseq.
®® 7 C.F.R. Part 205, announced at 65 Fed, Reg, 80548 (Dec. 21, 2000),
“ 7 U.S.C. §6503(a).
7 C.F.R. §205,2.
25
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for example, induced radiation or chemical mutagenesis - are not specified as excluded
methods by the NOP (discussed in Section 3.1.1).
All organic growers’ production plans must be approved by an organic certifying agent before
the farm can be certified as “organic,”^® Such plans must include, among other things, steps the
organic grower is taking to avoid what the NOP refers to as “genetic drift” from any neighboring
crops using excluded methods.^^ Certification must include on-site inspections of the farm to
verify the procedures set forth in the organic production plan.^®
Thus, the NOP recognizes the coexistence of organic growers with neighboring growers who
may choose to grow products developed using certain methods of biotechnology. So long as an
organic grower follows an approved organic method of production that seeks to avoid contact
with these specific biotechnology-derived crops, if some residue of the biotechnology-derived
plant material is later found in the organic crop (or food produced from it), neither the crop (or
food) nor the organic farm is in danger of losing its organic status. According to the standards
established by the NOP, no grower or seed producer should lose organic certification due to
inadvertent transmission of genetic material from a genetically engineered crop.
In the context of the genetic drift discussion, in the preamble of the NOP regulations, USDA
emphasized that it is the use of excluded methods as a production method that is prohibited, not
the mere presence of a product of excluded method:
It is particularly important to remember that organic standards are process
based. Certifying agents attest to the ability of organic operations to follow a set
of production standards and practices that meet the requirements of the Act and
the regulations. This regulation prohibits the use of excluded methods in organic
operations. The presence of a detectable residue of a product of excluded
methods alone does not necessarily constitute a violation of this regulation. As
long as an organic operation has not used excluded methods and takes
reasonable steps to avoid contact with the products of excluded methods as
detailed in their approved organic system plan, the unintentional presence of the
products of excluded methods should not affect the status of an organic product
or operation.^®
The NOP calls for testing only if there is “reason to believe" that a grower has used excluded
methods,®® The preamble states that a “reason to believe” may be triggered by situations such
SeeTC.F.R. Part 205, Subpt. E.
See id. at 205.201; 65 Fed. Reg. 80547, 80556 (Dec. 21, 2000) (discussing "genetic drift"),
^®7C.F.R. §205.403.
9Q
65 Fed. Reg. 80547, 80556 (Dec. 21, 2000).
7 C.F.R. 1205.670(b).
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as a formal, written complaint to the certifying agent regarding the practices of a certified
organic operation; the proximity of a certified organic operation to a potential source of drift; or
the product from a certified organic operation being unaffected when neighboring fields or crops
are infested with pests.^’
This testing provision does not establish a zero tolerance standard for the presence of products
of excluded methods in organically labeled food. Rather, it serves as a warning that excluded
methods may have been used: “Any detectable residues of. . . a product produced using
excluded methods found in or on samples during analysis will serve as a warning indicator to
the certifying agent.”^^
[TJhese regulations do not establish a “zero tolerance” standard. . . [A] positive
detection of a product of excluded methods would trigger an investigation by the
certifying agent to determine if a violation of organic production or handling
standards occurred. The presence of a detectable residue alone does not
necessarily indicate use of a product of excluded methods that would constitute a
violation of the standards.”®^
Only if the organic producer intentionally used excluded methods of crop production will that
producer be subject to suspension or revocation of organic certification.
Indeed, since the time GE crops were introduced in the U.S. in the mid-1990s, organic markets
have grown and expanded (Smith, 2010b, p. 10).
1.5.1 Non-GMO Project working standard
The Non-GMO^^ Project is a non-profit organization created by leading members of the organic
industry to “offer consumers a consistent non-GMO choice for organic and natural products that
are produced without genetic engineering or recombinant DNA technologies” (Non-GMO
Project, 2010a). The Non-GMO Project has created a working standard to implement its goal.
The standard sets action thresholds for “GMO" (GE) adventitious presence for certain products.
If these action thresholds are exceeded, the participant must investigate the cause of the
exceedance and take corrective action (Non-GMO Project, 2010, p, 13). The standard sets a
threshold of 0.25 percent for GE material for the presence of GE traits in non-GE seeds (p. 28),
and a 0.9 percent threshold for non-GE food or feed (p.14).
See 65 Fed. Reg. 80547, 80629 (Dec, 21, 2000),
Id. at 80628.
Id. at 80632.
34
GMO stands for genetically modified organism,
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1.5.2 Growth in organic and GE farming
Expansion of organic farming has succeeded at the same time as the growth of GE crops.
Consumer demand for organically produced goods “has shown double-digit growth for well over
a decade" and organic products “are now available in nearly 20,000 natural food stores and
three of four conventional grocery stores.” Organic products “have shifted from being a lifestyle
choice for a small share of consumers to being consumed at least occasionally by a majority of
Americans” (USDA Economic Research Service [ERS], 2009c).
1 .6 COEXISTENCE IN U.S. AGRICULTURE
1.6.1 Coexistence and biotechnology
Coexistence of different varieties of sexually compatible crops has long been a part of
agriculture, especially in seed production, where large investments are made in developing new
varieties and high seed purity levels are required by the Federal Seed Act's implementing
regulations.^® The aspect of coexistence most relevant to this document is that related to
specific methods of crop production. In this context, coexistence refers to the “concurrent
cultivation of conventional, organic, and genetically engineered (GE) crops consistent with
underlying consumer preferences and choices” (USDA Advisory Committee, 2008). The
differences among these crops that are particularly relevant to coexistence in this ER are in the
types of breeding methods (sometimes referred to as “genetic modifications”) that are
associated with each of these three types of crop production.
“Genetic engineering” is defined by APHIS regulations as “the genetic modification of
organisms by recombinant DNA techniques.”®® Recombinant DNA (rDNA) techniques are
discussed In Section 3.1.1 of this ER. While there are many ways to genetically modify a crop,
the APHIS definition of GE crops applies only to those developed using rDNA techniques, which
are among the more modern breeding methods.
Organic crops are those produced in accordance with the requirements of the NOP, discussed
in Section 1 .5.
Conventional crops are simply those that are neither GE nor organic. They may be
commodity crops (mass produced), or they may be identity preserved, with some characteristic
tailored for a specific end user. Identity-preserved usually refers to a “specialty, high-value,
premium or niche market” (Massey, 2002). One type of identity preserved product that has
®® 7 C.F.R, § 201
®®7C.F.R, §340,1
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been produced since the introduction of GE crops is “non-GE”; however, there are no
mandatory standards governing the use and/or marketing of “non-GE" products. (USDA
Advisory Committee, 2008).
Farmers who want to maximize their profitabiiity must decide whether the higher prices
(premiums) they may receive for organic or identity-preserved crops are sufficient to offset the
added managerial costs of producing these crops. As researchers have noted, “Although yields
on organic farms are sometimes less than those of conventional systems, price premiums make
it an attractive option for growers looking for specialized markets and a higher-value product”
(Ronald and Fouohe, 2006),
1.6.2 USDA position on coexistence and biotechnology
It is USDA’s position that all three methods of agricultural production described above can
provide benefits to the environment, consumers, and the agricultural economy (Smith, 2010b),
1.6.3 Coexistence in U.S. agriculture
The USDA Advisory Committee on Biotechnology and 21” Century Agriculture who reported
that “coexistence among the three categories of crops is a distinguishing characteristic of U.S,
agriculture, and makes it different from some other parts of the world," expressed its belief that
U.S. agriculture supports coexistence, and recommended continued government support of
coexistence (USDA Advisory Committee, 2008). Among the Committee’s findings:
• The U.S. is the largest producer of GE crops in the world.
• The U.S. is one of the largest producers of organic crops in the world.
• The U.S. is one of the largest exporters of conventionally-grown, identity preserved, non-
GE crops in the world.
• Some U.S. farmers currently are producing a combination of organic, conventional, and
GE crops on the same farm.
Among the coexistence-enabling factors the Committee identified is the existing “legal and
regulatory framework that has enabled different markets to develop" without foreclosing the
ability of “participants in the food and feed supply chain to establish standards and procedures
(e.g., not setting specific mandatory adventitious presence (AP) thresholds and having process-
based rather than product-based organic standards).” At the same time, development of
practices and testing methods that allow for voluntary thresholds has also enabled coexistence
(USDA Advisory Committee, 2008).
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As APHIS has previously observed, “studies of coexistence of major GE and non-GE crops in
North America and the European Union (E.U.) demonstrated that there has been no significant
gene flow from GE crops and that GE and non-GE crops are coexisting with minimal adverse
economic effects" (Smith, 2010b, pp. 11-12) (citing Gealy et al,, 2007; Brookes and Barfoot,
2003; Brookes and Barfoot, 2004(a) and (b), and Walz 2004). In addition, “the agricultural
markets and local entities have addressed coexistence through contractual arrangements,
management measures, and marketing arrangements. This market-based approach to
coexistence has created economic opportunities for all kinds of producers of agricultural
products.” (Id. p. 9). RRA is one of fifteen GT events previously deregulated by USDA, See
APHIS, EPA, Petitions of Non-Reguiated Status Granted or Pending by APHIS as of February
2, 2010, http://www.aDhis.usda.aov/brs/not rea.htmlV
1 .7 ROLE OF THE NATIONAL ACADEMIES IN AGRICULTURAL BIOTECHNOLOGY
The analyses in this ER are based on published, peer-reviewed scientific papers; federal
government assessments; assessments from international agencies; information from
specialists from many universities; data collected by Monsanto/FGI under controlled conditions;
and information from other relevant sources. One resource used for this ER is the National
Academies (NA), a private, non-profit institution that advises the nation on scientific and
technical matters. It consists of the National Academy of Sciences (NAS), the National
Academy of Engineering, the Institute of Medicine (IM) and the National Research Council
(NRC) (NA, 2010). Scientists, engineers and health professionals are elected by their peers to
the academy and serve pro bono. Reports are prepared by committees of members with
specialized expertise and reviewed by outside anonymous experts (Alberts, 1999). NA reports,
as well as the scientific studies used in those reports, are used as applicable throughout this
document.
The NA has been active in studies related to agricultural biotechnology since the 1970s and
works cooperatively with federal agencies, and its reports have provided guidance and
recommendations for process improvement to regulatory agencies (Alberts, 1999). The NRC
1989 guidelines for field testing of genetically engineered organisms were used as the basis for
agency procedures for field trials (Alberts, 1999; NRC, 1989), In studies in 1987 and 2000 the
NRC emphasized that the characteristics of the modified organism should be the object of a risk
assessment, and not the methods by which the modifications were accomplished; and that the
risks associated with recombinant DNA techniques are the same in kind as risks from other
types of genetic modification (NRC, 1987; NRC, 2000). This position was re-iterated in a 2004
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study prepared jointly by the IM and the NRC. Whether such compositional changes result in
unintended health effects is dependent on the nature of the substances altered and the
biological consequences of the compounds. To date, “no adverse health effects attributed to
genetic engineering have been documented in the human population" (Institute of Medicine and
National Research Council [IM/NRC], 2004, p. 8). In a 2002 report, the NRC “found that the
current standards used by the federal government to assure environmental safety of transgenic
plants were higher than the standards used in assuring safety of other agricultural practices and
technologies" (NRC, 2002). The NRC reports that, while biotechnology is not without risk, since
the first commercial introduction of transgenic plants, “biotechnology has provided enormous
benefits to agricultural crop production” (NRC, 2008). NRC’s latest report on biotechnology in
agriculture evaluates the impact of genetically engineered crops on farm sustainability (NRC,
2010). The authors concluded that an understanding of impacts on all farmers will help ensure
that GE technology contributes to sustainability and that commercialized GE traits to date, when
used properly, “have been effective at reducing pest problems with economic and environmental
benefit to farmers" (NRC, 2010),
1.8 ALTERNATIVES
In addition to the alternative of implementing the partial deregulation measures (Alternative 2),
this ER considers the alternative of full regulation (Alternative 1).
1 .8.1 Alternative 1 - No Action
In conducting NEPA review, agencies consider a no action alternative, which provides a
baseline against which action alternatives can be evaluated. This ER identifies the no action
alternative as a return to full regulation - or the status quo when the petition for deregulation of
RRA was initially submitted. Under this alternative, the introduction of RRA would be fully
regulated and would require permits issued or notifications acknowledged by APHIS until APHIS
completes its EIS and issues a Record of Decision (ROD) regarding whether to deregulate
RRA. For purposes of this analysis, we assume that Alternative 1 would not involve widespread
RRA cultivation, and instead would contemplate a return to conventional alfalfa crops or to
crops other than alfalfa.^^
37
This ER does not address the acres of RRA planted prior to March 30, 2007, and cultivated pursuant to conditions
required by the district court and Implemented by APHIS by administrative order. These acres are reaching the end of
their productive lives and will be removed within the next few years under either Alternative. Because their acreage
and expected lifespan is so small, and because their impacts would be Identical under either Alternative, the analysis
of these limited impacts would not be meaningful within the scope of this ER.
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1.8.2 Alternative 2 - Partial Deregulation
Under this alternative APHIS would implement the proposed measures described in Section
1.1.3.
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SECTION 2.0 AFFECTED ENVIRONMENT
2.1 ALFALFA CHARACTERISTICS
Alfalfa (Medicago sativa L.) is a deep-rooted and short-lived perennial plant considered to be
the “Queen of Forages” due to its high nutritional content for cattle, sheep and horses (USDA
APHIS, 2009, p. 18).
2.1.1 Growth
Alfalfa is recognized as a widely adapted crop, growing in all continental States, as well as
Alaska and Hawaii. Alfalfa initially grows from seed, but after each harvest or winter it will re-
grow from buds arising from the perennial crown/root structure. As alfalfa grows, yield (i.e.
above ground biomass) increases until alfalfa yield peaks at full bloom. However, juvenile
vegetative alfalfa vegetative alfalfa plants have the highest nutritional value and that nutritional
value decreases as the plant approaches full flower. The vegetative growth interval during
most of the year is 22 to 40 days. The crop is typically harvested for forage three to eight times
per year, depending on location and seasonal climate. The alfalfa plant grows until stopped by
a hard freeze. Fields grown for forage production are typically maintained for 3 to 6 years or
longer in some areas (USDA APHIS, 2009, p. 18-19).
2.1.2 Pollination
Alfalfa is predominantly cross-pollinated and the flowers depend entirely on bees for cross-
pollination. Alfalfa requires bees to physically “trip” flowers to release pollen for egg fertilization
and seed production (refer to Section 2.2.3) (USDA APHIS, 2009, p. 19).
Alfalfa is exclusively insect pollinated (Mallory-Smith and Zapiola, 2008). The flowers depend
on bees for cross-pollination. Alfalfa seed farmers must stock bees to ensure pollination
because most regions that cultivate alfalfa seed do not have naturally occurring populations of
effective alfalfa pollinators. Forage farmers do not stock bees, however, because they do not
want or need pollination of their fields (USDA APHIS, 2009, p. 94; Rogan and Fitzpatrick, 2004).
Leafcutter bees (Megachile rotundata F.) are typically used to pollinate alfalfa seed production
fields in the cooler Pacific Northwest (PNW), and honey bees (Apis mellifera) are primarily used
in the Desert Southwest. However, a few growers in niche regions like southern Washington
use alkali bees (Nomia melanderl) due to their unique geography and climate (USDA APHIS,
2009, p. 19), Alfalfa pollen is not carried by the wind; it is not wind-pollinated. Severe
environmental conditions such as, heavy winds in combination with drought, may sometimes
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cause flowers to trip and self-pollinate. Although rare, self-pollinated seeds have inferior vigor
and germination due to genetic inbreeding depression in alfalfa (Teuber, 2007).
Pollen-mediated gene flow decreases exponentially as the distance from the pollen source
increases (Mallory-Smith and Zapiola, 2008). However, the type of pollinator determines the
extent. All bees have a limited range over which they will search to efficiently collect pollen;
most nectar or pollen foraging occurs close to the nest when flowers are present. The
maximum foraging radius for each of the three commercially available bee species {honey bees,
leafcutter bees, and alkali bees) depends heavily on the abundance of nectar and pollen
resources. Leafcutter bees have the shortest routine foraging radius of less than a 1/4 mile.
The honey bee and alkali bee having a forging range of 1 to 3 miles (Arnett, 2003; Gathmann
and Tscharntke, 2002; Hammon et al., 2006; Teuber et al., 2005). Honey bees may infrequently
transport alfalfa pollen and effect pollination up to 3 miles from the source (St. Amand et al.,
2000; Teuber et al., 2004; Hammon et al. 2006). Honey bees are predominantly nectar
collectors and as such they tend to avoid the tiny alfalfa flowers when other sources of nectar
flowers are available. When visiting alfalfa flowers, honey bees are known as inefficient
pollinators because they predominantly “side-feed” solely for nectar, i.e,, they leave the flower
closed (un-tripped) and un-pollinated. Feral honey bees and native bees including Bombus
spp., Osmia spp., Agapostomen spp. and Megachile spp. can also be found visiting alfalfa
flowers in varying numbers. These species may sometimes pollinate alfalfa flowers but their
importance in alfalfa pollination is minor (USDA APHIS, 2009, p, 0-5; Hammon et al., 2006;
Arnett, 2002).
2.2 ALFALFA PRODUCTION
2.2.1 Forage production, general
Alfalfa is among the most important forage crops in the U.S., with more than 21 million acres in
cultivation. Recognized as the oldest plant grown solely for forage, alfalfa has been used as
livestock feed because of its high protein and low fiber content. Alfalfa is ranked fourth on the
list of most widely grown U.S. crops by acreage and is ranked third among agricultural crops in
terms of value (USDA APHIS, 2009, p. 1 7). The harvested acreage of alfalfa harvested for
forage (dry hay) was approximately 21 million acres in 2009, which generated 71 million tons of
hay at an average yield of 3.35 tons per acre (USDA ERS, 2010a and 2010b). Over the last 60
years (since 1951), harvested alfalfa hay acreage in the U.S, has ranged between 20.7 acres
(2010) and 29.8 million (1957) (USDA ERS, 2010a). From 1951 to 2009 (latest year available),
total U.S. production (dry) has ranged between 46.8 million tons (1951) and 91.9 million tons
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(1986) (USDA ERS, 2010b), Since 1950, yields generally increased until about the mid-1980s;
since then yields in most years have been around 3.3 tons per acre. The total acreage of
harvested alfalfa has generally been declining since the mid-1980s, with 2010 the lowest year
since 1950 (USDA ERS, 2010a). The production decreases are due to alfalfa's use in crop
rotation declining in the U.S., and the increased use of corn silage as a source of forage in dairy
diets coupled with the decline in dairy (milk) prices paid to farmers. Alfalfa requires different
management, equipment, and labor schedules than other major cropping systems such as corn
and soybeans. Transportation of bulky alfalfa hay or haylage to distant markets may be
prohibitively expensive (USDA APHIS, 2009, p. 34). In the 2009/2010 season (May 2009 to
April 2010), the average price farmers received for alfalfa hay was $1 15/ton, compared to
$101/ton for other hay (USDA ERS, 2010c).
Alfalfa is grown for forage in almost every U.S. state. U.S. production of hay/haylage and seed
harvested for the 2006 season is shown in Table 2-1 . Haylage is alfalfa that is chopped at
higher moisture content than hay, and stored in silos, bunkers or plastic bags to enable
controlled fermentation to preserve the nutritional content. The major U.S. alfalfa producing
regions include the Southwest, PNW, Inter-Mountain, Plains, North Central, and East-Central.
The North-Central and the East-Central regions are the highest acreage hay and haylage
regions in the U.S.; whereas, the Southwest and PNW regions produce the most seed in the
U.S, (USDA NASS, 2010b).
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Table 2-1 Alfalfa Forage and Seed Production by State
2006 National Agricultural Statistics Service Date
State
Acres by State
{1000s)
Dry Hay and
Hay Hayiage
2006 2006
Hay and Hayiage
Harvested
Average Forage
Yield T/A Tons
Harvested
Seed
Production
Acres
Average
Yield
(Ibs/A)
Seed Lbs
Harvested
Southwest
AZ
250
250
8.3
2,075
4
500
2,000,000
CA
1,050
1,070
6.9
7.426
38
550
20,900,000
NM
220
234
51
1,184
2
400
800,000
Total
1,520
1,554
10,685
44
23,700,000
PNW
ID
1,180
1,230
4.5
5,523
28
7Q0
19,600,000
NV
270
270
5.1
1,377
5
600
3,000,000
OR
430
430
4.4
1,892
5
650
3.250,000
WA
440
455
4.9
2.239
15
750
11,250,000
Total
2,320
2,385
11,031
53
37,100,000
Inter-
CO
780
780
3.8
2,964
0.6
200
390,000
Mountain
MT
1,550
1,550
2.1
3.255
5.5
200
3,025,000
UT
560
560
4
2,240
2.2
200
1,320,000
WY
500
500
2.8
1,400
7.5
400
4,125,000
Total
3,390
3.390
9,859
15.8
8,860,000
Plains
KS
950
965
3.8
3,677
0.5
200
100,000
NE
1,250
1.265
3.3
4,212
0.4
200
80,000
OK
380
380
2.1
798
0,4
200
80,000
TX
150
160
4.4
707
1
400
400,00
Total
2,730
2,770
9,394
2.3
660,000
North
lA
1,180
1,230
4
4.908
0
0
0
Central
MN
1,350
1,500
3.6
5,460
0
0
0
ND
1,450
1,450
1.2
1,740
0
0
0
Wl
1,650
2,400
3.9
9,336
0
0
0
SD
1,800
1,820
1.6
2,930
7
250
1,750,000
Total
7,430
8,400
24,374
7
1.750,000
East
CT
7
7
2.1
16
0
0
0
Central
DE
5
5
3.9
20
0
0
0
IL
440
460
4.2
1,918
0
0
0
IN
360
360
4.1
1.476
0
0
0
ME
10
10
1.9
19
0
0
0
MD
40
40
3.9
156
0
0
0
MA
13
13
2.3
30
0
0
0
Mi
830
980
4
3.940
0
0
0
MO
390
400
3
1,184
0
0
0
NH
8
8
2.4
19
0
0
0
NJ
25
25
2.5
63
0
0
0
NY
370
610
3.3
2,019
0
0
0
OH
470
550
4
2,195
0
0
0
PA
500
660
3.8
2,515
0
0
0
Rl
1
1
3
3
0
0
0
VT
45
90
3.6
322
0
0
0
Total
3,514
4,219
12,894
0
0
Source: USDA APHIS, 2009, Table 3-20
Cultural practices
Seeding and planting. The objectives of seedbed preparation are to manage crop residue (the
leftover vegetative matter from the previous crop), minimize erosion, improve soil structure, and
eliminate early season weeds. Alfalfa requires a good establishment for a long-lived productive
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stand. Results from seed failure include poor seedbed preparation, seeding too deep or too
shallow, low moisture availability, freezing, diseases, insects, damage from herbicides, and
excess competition for light and nutrients from a companion crop or from weeds. Slight
differences in seeding may be in the equipment used, such as, drills, broadcasting, or aerial
broadcasting. Seeding time during the year varies from region to region. Northern areas will
generally seed in spring to avoid major freezing damage of young seedling plants whereas all
other areas will seed in the fall. Recommended seeding times are based on the previous crop,
soil water availability throughout the year, and the time of year. The recommended soil
preparations are similar in all regions unless no-till planting is used and no-till planting can be
used in all regions (USDA APHIS, 2009, p. 84). No-till productions systems do not have any
associated tillage where weed control is entirely through chemical means.
Fertilizing. The only differences in fertilizing among alfalfa growers occur in the composition of
the fertilizer used because of the different soil types in different regions. All regions generally
recommend good availability of phosphorus and potassium. Nitrogen fertilizer is generally not
recommended unless considerable refuse from the previous crop exists (USDA APHIS, 2009, p.
84),
Harvesting. Alfalfa grown for forage can be used for grazing or harvested as greenchop,
haylage/silage or hay. The only major difference for harvesting in different regions is the total
number of han/ests per year. The northern regions typically have up to two or three harvests
per year due to shorter growing seasons. Southern regions can have six or more harvests per
year. The major differences are in the adaptation of different varieties to the different climates
of the U.S. and differing levels of various pests (weeds, disease, and insects) (USDA APHIS,
2009, p, 84).
Harvesting, Alfalfa grown for forage can be used for grazing or harvested as greenchop,
haylage/silage or hay. The only major difference for harvesting in different regions is the total
number of harvests per year. The northern regions typically have up to two or three harvests
per year due to shorter growing seasons. Southern regions can have six or more harvests per
year. The major differences are In the adaptation of different varieties to the different climates
of the U.S. and differing levels of various pests (weeds, disease, and insects) (USDA APHIS,
2009, p. 84).
Crop rotations. Crop rotations can help maintain soil fertility, reduce soil erosion, avoid
pathogen and pest buildup, adapt to weather changes, avoid allelopathic effects (effects to
reduce the growth of one plant due to chemical releases by another) and increase profits.
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Weeds can be a problem in alfalfa, but once alfalfa is established, it acts as a suppressor of
weeds and is commonly used in rotations for weed reduction. Alfalfa is also used in crop
rotations because it provides nitrogen to the soil, which decreases fertilizer inputs in other
rotations. Rotating perennials, such as alfalfa, with annuals also helps control weeds and
improves soil tilth. Using other crops to rotate with alfalfa is likewise advisable because mature
alfalfa is autotoxic to seedling alfalfa. (USDA APHIS, 2009, p. 73 and 75),
2.2.2 Organic alfalfa hay production
Between 2000 and 2005, the number of acres in certified organic alfalfa hay production
fluctuated slightly, but overall showed an increasing trend. The percentage of total alfalfa hay
acres certified as organic per year was between 0.51 to 0.92 percent nationally during this time
period (see Table 2-2). During 2005 (the most recent year for which certified organic alfalfa
acres are reported), there were 204,380 acres in certified organic production, which was
approximately 0.92 percent of the U.S. alfalfa dry hay total (USDA APHIS, 2009, p. 48).
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Table 2-2 Organic Alfalfa Hay Harvested Acreage.
Acreage
2000
2001
2002
2003
2005
Total
113,157
116,608
155,437
135,717
175,260
204,380
Share of Total
U.S. Acreage
0.51%
0.49%
0.67%
0.58%
0.81%
0.92%
Source: USDA-ERS, 2005; USDA-NASS, 2007; USDA APHIS, 2009, p. 48
Organic alfalfa hay production is similarly distributed geographically to conventional hay.
However, production of organic alfalfa hay is a more significant proportion of total alfalfa hay
production in some States. In 2005, for example, more than 4 percent of all alfalfa hay acreage
in Idaho was organic, compared to just 0.92 percent nationally. Organic alfalfa, like organic
dairy, also seems to occur in pockets, with 72 percent of organic acreage located in just 6
States — Idaho, Wisconsin, Minnesota, North Dakota, South Dakota, and California. These 6
States account for about 41 percent of total U.S. alfalfa acreage (USDA APHIS, 2009, p. 48).
The increased price per ton of hay received by organic growers is partially offset by a reduction
in forage quality (due to increased weeds in the hay) and an approximately 12.5 percent
reduction of alfalfa yield per acre (Long et al., 2007). The 2005 national average yield per acre
for all alfalfa hay production was 3.39 tons. Based on differences in organic and conventional
alfalfa yield from Long et al. (2007), the total estimated U.S, organic hay production in 2005 was
about 606,242 tons; the total U.S. production of alfalfa hay in 2005 was approximately
76,149,000 tons. The resulting eaverage organic alfalfa yield per acre, in 2005, was 2.97 tons.
This estimate is approximate, however, and is oniy presented here for iliustrative purposes
(USDA APHiS, 2009, p. 48).
2.2.3 Seed production
Maintaining seed purity, Identity and quality
The Federal Seed Act and its implementing regulations®* establish basic standards for
certification of seed, which are carried out by state seed certifying agencies. A state seed
certifying agency is created by state law, has authority to certify seed, and has standards and
procedures approved by USDA “to assure the genetic purity and identity of the seed certified."
Seed certifying agencies’ standards and procedures must meet or exceed those specified in the
®*7C.F.R. §201.
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USDA regulations.^® Federal law also allows for international seed certification. Through the
certification process, the certifying agency “gives official recognition to seeds produced of a
cultivar or named variety under a limited generation system which ensures genetic purity,
identity, and a given minimum level of quality" (USDA, 2009a), In the case of alfalfa, State Crop
Improvement Associations (or sometimes Seed Grower Associations) provide certifications that
seed production followed minimum standards, such as isolation between different alfalfa
varieties, absence of prohibited noxious weeds in the field, inspection of conditioning
(separation) facilities, maintaining traceability of seed lots, and seed testing (USDA APHIS,
2009).
The most common levels of certification that would normally be available for consumer
purchase would be “registered seed” or “certified seed,” Breeder seed is controlled by the seed
developer and is the source for the production of the other classes of certified seed, and
foundation seed is normally used to establish new production fields (USDA, 2009a and 7 C.F.R.
§ 201 .2). Standards are highest for Breeder/Foundation seed, next highest for Registered;
while “Certified” has the least stringent requirements of the certified categories. In all cases, the
party seeking the certification is responsible for ensuring the requirements are met.
Certified seed must have a label indicating, among other things, the percent of pure seed, inert
matter, other crop, and weed seed. Seed purity standards vary between states but remain high,
particularly for foundation seed stock. At least 99 percent of each seed harvest must contain the
pure seed variety (i.e. < 1 percent genetic off-types), and there are strict limits on the allowable
amounts of other crops, weeds and inert matter. After seed crops have been evaluated by seed
labs, they are tagged with seed labels in accordance with law. The Association of Official Seed
Certifying Agencies (AOSCA) requires that a representative sample from each submitted crop
undergo multiple tests at a seed lab. All types of seed crops must be accurately labeled. The
Foundation and Certified seeds are identified by a special tag that includes variety, kind, origin,
net weight, percent pure seed, percent other materials, amount of noxious seed and weeds, and
identification of the seed lab performing the analysis (USDA APHIS, 2009).
California, the leading producer of alfalfa seed, provides an example of typical rules for field
eligibility (past use and spatial isolation) and seed purity standards. These rules are followed by
most states. For cultivating Foundation seed (seed of the highest purity), alfalfa must not have
grown on the land in the previous four years. For Certified seed, alfalfa must not have been
grown on the land in the previous one to two years. These past use requirements may vary
7 U.S.C. §15S1(a)(25); 7 C.F.R. §201.67,
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depending on the intervening crops. The boundaries of the field must be clearly set and all
noxious weeds and volunteer plants must be eradicated before planting. Foundation seed fields
must be isolated from alfalfa of different varieties by 900 feet (ft). Certified fields must be
isolated by 165 ft However, a “10 percent rule” provides some flexibility for Certified fields.
Under this rule, if 10 percent or less of the Certified field is in the 165 foot isolation zone, then
the entire field is considered Certified. However, if more than 10 percent is in the isolation zone,
then that part of the field must be separated and not harvested as Certified seed (USDA APHIS,
2009).
Summary of practices for alfalfa seed production
Unlike alfalfa hay production, alfalfa seed production is largely concentrated both geographically
and in the number of producers. Seed production occurs primarily in niche areas of the western
U.S. on approximately 100 to 120 thousand acres under intensive management and irrigated
field conditions (see Figure 1-1). It requires a long growing season with a very warm
temperature, very low humidity during seed ripening, and specialized equipment. Most
professional seed producers use cultured bees and specialized equipment associated with bee
culture (USDA APHIS, 2009, p. 68).
Based on the 2007 Census of Agriculture, the top three seed producing states, accounting for
over 60 percent of production, were California with 31 percent of produced seed, Washington
with 17 percent, and Idaho with 15 percent. The remaining seed production was highly
concentrated in the western states of Nevada, Oregon, Wyoming, Montana, and Utah (USDA
APHIS, 2009).
As shown in Table 3-9 of the draft EIS (included as Figure 1-1 of this ER), within the seed
producing states seed production is localized to certain counties, In the most recent USDA-
NASS Census of Agriculture (2007), during 2002 and 2007, 1 ,234 and 806 farmers grew alfalfa
seed on 1 1 0.6 and 120 thousand acres, respectively. This is a small number of growers in
comparison to those growing alfalfa for forage (i.e., 344,000 and 290,000 alfalfa hay growers in
2002 and 2007, respectively). During 2007, 90 percent of the U.S. seed crop tonnage was
grown by 304 seed growers operating farms with at least 100 acres of alfalfa seed (USDA-
NASS, 2009). Therefore, most of the alfalfa seed production is managed by a relatively small
number of large professional seed producers. Nearly all large growers have at least one
proprietary seed production contract with one of the four national alfalfa seed production
companies (USDA APHIS, 2009, p. 68-69).
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Cultural practices used to produce seed are distinct from those used to produce forage.
Professional seed growers usually grow seed under terms of a two or three year term seed
company contract, by variety name. The contracting seed company supplies the stock seed
(e.g., foundation seed) to the seed producer and the genetic source variety of the seed is
documented. In contrast, seed companies purchasing or growing “common seed" or “catch
crop” seed typically use lower management and inputs, the genetic identity of the stock seed is
often unspecified/unknown and the resultant product quality is highly variable and cannot be
certified as to cultivar or variety identity (USDA APHIS, 2009, p. 69),
Typically, seed fields are planted in the fall and clipped back in late spring so that bloom within
the field is uniform, synchronous and optimally timed for the warm dry season and optimal
pollinator activity. Weed and in-crop volunteer controls (herbicides and cultivation) are applied
mainly prior to the start of pollination or after seed harvest. Flowering begins in approximately
mid-June. Insecticides (primarily for Lygus control) and other pesticides are applied prior to bee
release to avoid insecticide damage to the bees. At approximately 50 percent flower (early to
mid-July), cultured bees are gradually moved into the seed field for pollination with their domicile
or hive for local shelter. The field is actively pollinated for approximately one month, allowed to
ripen seed for approximately 4 weeks more, and then, chemically desiccated or swathed several
days prior to combining the seed. At the end of the pollination period and just prior to
desiccation, the pollinating generation of bees is either at the end of their lifecycle (i.e.,
leafcutter or alkali bees), or are transported by the honeybee keeper to a different location to
forage on fall-flowering plant species. Seed is harvested in mid August to late September
depending on geography. In long-growing season regions, the cool-season alfalfa forage growth
between seed crops is sometimes mechanically harvested or grazed (USDA APHIS, 2009, p.
69).
Stands of alfalfa grown for seed production only are usually maintained for an average of three
production seasons. The length of the seed stand is generally predetermined by the seed
production contracts and AOSCA variety certification standards. In contrast to forage stands,
most alfalfa seed planted for seed production purposes is planted at a low density in widely
spaced rows and not cut monthly. Consequently, weeds in the seed fields have more open area
and time to proliferate and compete with the alfalfa. Therefore, weeds, insects, and pests are
intensively managed in seed production systems. Weed seeds and weed debris in grower seed
lots directly reduce the purity and yield of alfalfa seed and drive up growers’ costs to remove
them (USDA APHIS, 2009, p. 69-70).
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RRA seed production since 200S
In 2006-2007, RRA seed was produced in the U.S. on a widespread basis for the first time since
deregulation in 2005. This presented an opportunity for FGi to implement an internal seed
quality program to monitor the efficacy of the FGI Best Practices for RR Stewardship during
Seed Production (“FGI Best Practices"). Conventional alfalfa seed lots grown and/or processed
in proximity to RR seed in 2006 and 2007 were tested for the adventitious presence (AP) of the
RR trait. The data showed that the AP of the RR trait in FGI conventional seed lots occurred
infrequently and, in all cases if detected, was at a very low level — 0.004 to 0.180 percent. This
was well within the FGI’s goal of <0.5 percent AP. This large-scale commercial validation of FGI
Best Practices supports research-based isolation standards and demonstrates the effective
implementation of quality control programs at both the grower and processor level. FGI believes
that this, and more recent industry reviews together demonstrate that reasonable tools are
available and are being used by seed producers to allow successful coexistence of diverse
alfalfa seed market sectors and preserve conventional seed and hay market choices (USDA
APHIS, 2009). In late 2007, following the Court’s Decision, the FGI Best Practices were
extensively reviewed by the Steering Committee of the National Alfalfa & Forage Alliance
Peaceful Coexistence Workshop (October 10, 2007). The steering committee was composed of
a broad array of alfalfa industry stakeholders. In January, 2008, NAFA’s Board of Directors and
all genetic suppliers of NAFA adopted the NAFA BMP (Appendix C) as requirements for RRA
seed producers. A third-party panel of State Seed Certification Agencies has reviewed 2008
and 2009 conventional alfalfa seed crop year data and has stated that the NAFA BMP appear to
be working to achieve coexistence, i.e., conventional and RRA varieties have been produced
successfully during the period following widespread cultivation of RRA.
All alfalfa seed production since 200S
The latest information of total alfalfa seed production is from the 2007 Census of Agriculture,
when 121 ,467 acres of alfalfa seed were harvested producing approximately 62 million pounds
of seeds at an average productivity of approximately 510 Ibs/acre.
Alfalfa seed acreage and production increased between 2002 and 2007, reversing the trend of
decreases in alfalfa seed production over the preceding few years. Economic, social and
competitive challenges face both U.S. alfalfa seed and forage growers. These challenges
include: changes in global seed demand and production, economics, environmental constraints,
regulatory issues, and insect control and weeds. The presence of weeds can have a greater
impact on costs In alfalfa seed production than alfalfa forage production. Post-harvest
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separation of weed seed from the alfalfa seed is costly; therefore, the control of weeds in the
field is a more desirable method of seed quality control. No primary or secondary noxious
weeds are allowed for certified seed (USDA APHIS, 2009, p. 43-44).
Seed availability
All four of the major U.S. seed genetic suppliers and seed production companies (FGI, Pioneer
Hi-Bred, Dairyland Seeds and CalAA/est Seeds) sell conventional and/or organic seed products.
Prior to the federal court injunction, these varieties were sold alongside of one or more RRA
varieties. RRA was sold by more than 20 seed brands all of which continued to offer
conventional cultivar products (USDA APHIS, 2009).
During the 2005-2007 period of deregulation of RRA, approximately 200,000 and 18,000 acres
of RRA hay and seed, respectively, were grown with no substantiated disruption of the market
for conventional alfalfa hay or seed (USDAS APHIS, 2009; McCaslin, 2007).
Organically certified and conventionally grown seed lots are routinely marketed to U.S. organic
forage producers for the establishment of organic alfalfa forage fields. Although a small amount
of organic alfalfa seeds used in the U.S. are purchased from U.S. seed distributors, little or none
of the organic alfalfa seeds appear to have been originally grown in the U.S. (McCaslin, 2007).
There is little information available to indicate if there are any certified organic alfalfa seed
producers in the U.S. (USDA APHIS, 2009). Organic alfalfa seed sold in the U.S. by U.S. seed
companies is therefore most likely to have been wholly or largely imported from organic
producers in Canada or eisewhere, where insect pests in alfalfa seed production are less
catastrophic and base production costs for seed are much lower (McCaslin, 2007).
2.3 GENE FLOW
This section provides background information on gene flow, which is relevant to the impacts
analysis provided in Section 3 of this ER,
Gene flow has been defined as the "incorporation of genes into the gene pool of one population
from one or more populations” (Futuyma, 1998). Gene flow is a basic bioiogical process in plant
evolution and in plant breeding, and in itself does not pose a risk (Bartsch et al., 2003; Ellstrand,
2006, p. 116),
There are several factors that influence the probability of gene flow between alfalfa fields. The
following is a list of factors adapted from Putnam, 2006 (USDA APHIS, 2009, p. 1 00):
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• Probability of synchronous flowering (e.g., the percentage of days where several plants
flower simultaneously);
• Relative availability and abundance of pollen from various sources (e.g., the percentage
of bloom during each day of synchronous flowering);
• Presence of pollinators and pollinator types
• Pollinator activity on days of synchronous flowering and placement of bee hives (e.g.,
influenced by timed bee release and weather);
• Distance between fields (alfalfa populations);
• Probability of seed maturation; and
• Probability of seed germination.
2.3.1 Hybridization
In plant biology, when gene flow occurs between individuals from genetically distinct populations
and a new plant is formed, the new plant is called a hybrid (Ellstrand, 2003, p. 10).
Hybridization is usually thought of as the breeding of closely related species or subspecies
resulting in the creation of a plant that has characteristics different from either parent. Usually
this occurs through deliberate human efforts; however, it can also occur indirectly from human
intervention, or in nature, For example, when plants are moved to a new environment (with or
without human intervention), they may hybridize with plants of a closely related species or
subspecies in that new location.
For natural hybridization to occur between two distinct populations, the plants from the two
populations must flower at the same time, they must be close enough so that the pollen can be
carried from the male parent to the female parent, fertilization must occur, and the resulting
embryo must be able to develop into a viable seed that can germinate and form a new plant
(Ellstrand, 2003, pp. 11-13).
Characteristics that favor natural hybridization between two populations when the above
requirements are met include (Mallory-Smith and Zapiola, 2008, p. 429):
• Presence of feral populations (domestic populations gone wild) and uncontrolled
volunteers
• Presence of a high number of highly compatible relatives
• Self-incompatibility
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• Large pollen source
• Large amounts of pollen produced
• Lightweight pollen
• Large insect populations (insect pollinated)
• Long pollen viability
Feral populations are discussed in Section 2.6. Volunteers are plants from a previous crop
that are found in a later crop and are also discussed in Section 2.6.
There are no sexually compatible wild relatives of alfalfa present in the U.S. (Mallory-Smith
and Zapiola, 2008; Van Deynze et al., 2008, p. 7). Therefore, movement of the CP4 EPSPS
gene found in RRA varieties can only occur within or among cultivated or feral alfalfa
populations (USDA APHIS, 2009, p. 94).
Alfalfa {Medicago sativa L.) is predominantly self-incompatible; that is, fertilization does not
occur between the male and female parts on the same plant. Self-incompatible plants must be
cross-pollinated (also known as “out-crossed”) to form viable seed: that is, for fertilization to
occur, the female part of the flower (the stigma) must successfully receive pollen from the male
part of a second plant (the anther). The majority of cross-pollination in alfalfa is effected by
bees visiting plants growing in very close proximity (i.e., within four meters) (St. Amand et al.,
2000 ).
As discussed in Section 2.1.2, alfalfa is exclusively insect-pollinated, and, in seed production
areas, farmers must stock bees to ensure economic levels of seed production.
Gene flow via seed mixtures
Nearly all alfalfa forage producers purchase seeds for planting, largely because grower-
produced grower-saved-seed is only possible In the niche seed-growing geographies.
Commercially produced seed is generally produced under a contract from a seed company: the
foundation stock seed is provided to the contract grower by the seed company and seed lots are
harvested, transported and conditioned by variety name and lot code. Such contracts and the
typical use of official seed certification schemes maintain field and seed lot segregation, identity
and varietal purity. Seed certification standards set limits on the percentage of other variety off-
types that are allowed. Therefore, seed growers and seed producers are aware of the
importance of routine cleaning of field equipment, seed transportation containers and seed
processing equipment as means to mitigate off-types and weed seed presence to very low
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levels. Regardless of stringent management, commercial agricultural seeds are not and cannot
be 100 percent pure. Therefore, it is widely recognized that some seed admixtures may still
inadvertently occur, and that, in all but exceptional cases they are likely to pose no safety,
economic or regulatory issues.
2.3.2 Seed-to-seed gene flow studies
FGI performed gene flow studies in Idaho from 2000 to 2002 using leafcutter bees for
pollination, however, the presence of feral and native bees were also noted. These studies
showed a mean gene flow of 1 .39 percent at 500 ft and 0.0000 percent at % of a mile
(Fitzpatrick et al., 2002). Table 2-3 and Figure 2-1 below summarize the findings of these field
studies.
Table 2-3. Summary of FGI Idaho Gene Flow Studies (Fitzpatrick et al., 2002)
lh<il:ili«>n ilistuiuT
\ttir2iHH '
W:ir
(Umill Metiii
^eitc Ruu
(i*( ii"„ (.- [ !.:[S(vr Ruiiid)
»f( iSminr I’hni
II .Ni
SiwwilJ' Ai
\iuiw f ! .A 1
5HI) il
I<en^ {.4 nii.i ,.\.N '
fi 72"„i
‘MtO n
Kepl;».7A. N.
Ren:: 1.6 A.N1-..
(0..*4%t
HMMI I I
Kens i-4 iHi.t A. N '
H,.*:"-.. i04.«“.r.t
Rep.s 1*4: 0.1)5 .-V N.''
Hen 1; I.oA. W.
16 0 ' o A N W
Hop 1: ! A.N.A.
R. p ■< 1 \ tsl-
O.OS".. (0..1.^"nl
:hih) n
Ren i :."r\. Mtt.'
H.H0''r,(llM5"f.t
2f'4» It li ’ lili)
Kep 1; 1 A.N.VS.
Rep 2; lA.. S.l
O.IMI.l"., 10.02"., i
.19MI II (.V4 mi)
Kep i : 1 A. .S .W
Kep 2; 1 /V S.l: .
IM)HIM)'M0.0|",.|
IMI mi)
Kep 1: i A. N S\
Kep 2: 1 A. S i- .
o.iimx)".. io.o!"->i
Mcuti lit), hwal tested
ivrtr.in tlisStmcc
14.750
4i.:50
00.01)0
Notes: Isolation distance between trap and source, number of replicates per distance, replicate plot size (acres), trap
plot cardinal direction from source and, interplot land cover a,b,c, the mean observed gene flow and the upper bound
of true gene flow (i.e,, the 99.9 percent confidence interval upper limit) are given. Interplot land covera various crop
species typical for the area (e.g., onions, corn, wheat, etc.); b roadways, or c fallow. indicates distance not tested.
Events J101 and J163
Environmental Report
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Affected Environment
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902
Figure 2-1 - Gene Flow
UC — Davis, Monsanto/FGI performed a gene flow study during the 2003 growing season using
honey bees. The pollen-mediated gene flow at isolation distances of 900 ft, 5,000 ft, and 2.53
miles were 1 .49 percent, 0.2 percent, and sO.06 percent, respectively (Teuber et al., 2007).
A mixed honey bee and leafcutter bee gene flow study was performed in the San Joaquin Valley
of California in 2006 and 2007 (Teuber et al., 2007; Van Deynze et al., 2008). Summary data
from those studies are presented in the Table 2-4 below.
Table 2-4 Seed to Seed Gene Flow (Teuber et al., 2007)
Distance Gene Flow
165 ft.
(% adventitious presence)
2.3
900 ft.
0,9
4,000 ft.
0.6
1 mile
0.2
3 miles
0,03
5 miles
Not detected
FGl conducted a gene flow study subsequent to the 2006 growing season which validated the
FGI Best Practices (FGl, 2007). The observed gene flow ranged from 0.09 percent at an
isolation distance of one mile to 0.01 percent at an isolation distance of three miles. At distances
of 5 miles or greater, the gene flow was not detected.
Events J101 and J163
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Affected Environment
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To summarize, data collected under actual seed production conditions found gene flow ranging
from 0.00 to 0.18 percent when FGI Best Practices were used. This is well below the FGI
Company’s domestic market goal of less than 0.5 percent adventitious presence. As required
by the NAFA BMP (2008a), a third-party review panel has annually conducted a review of
conventional seed crop gene flow data. In each of the two annual reviews, the panel has
validated that NAFA BMP are working on a commercial scale to enable coexistence among
conventional and RRA seed producers (NAFA, 2009; Fitzpatrick and Lowry, 2010).
2.3.3 Gene flow potential
This ER addresses potential gene flow pathways as follows:
• Potential for gene flow from RRA forage crops to conventional and organic forage crops
(Section 3.3)
• Potential for gene flow from RRA forage crops to native alfalfa (Section 3.4)
• Potential for gene flow due to feral alfalfa populations (Section 3.5)
• Potential for gene flow from RRA forage crops to rangeland alfalfa (Section 3.6)
• Potential for gene flow from RRA forage crops to conventional or organic alfalfa seed
production areas (Section 3.7)
• Potential for gene flow from RRA to any of the above receptors, in alfalfa seed
production (Section 3.8)
2.4 ALFALFA WEED MANAGEMENT
2.4.1 Weed characteristics and concerns
While a weed can be defined as any unwanted plant, problem weeds are those that are
competitive and persistent. Healthy, productive stands of alfalfa require attention to manage
pests (including weeds), fertilizer inputs, Irrigation (if applicable), and harvest timing. Weeds
can be a problem in alfalfa particularly at establishment of a new stand and after the stand has
started to thin toward the end of its life. Once a dense stand of alfalfa has been established, the
competition of the alfalfa plants with weeds and the fact that alfalfa is cut at regular intervals
during the production season act as suppressors of weeds. Weed control at establishment is a
particularly important time since good weed control at this time leads to the establishment of a
dense, healthy stand for the life of the crop.
Events J101 and J 163
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Several years after sowing alfalfa when plants weaken and stands become thin weeds become
more competitive with alfalfa and can contribute to a significant decline in alfalfa yield and
forage value. Certain weed species found in alfalfa stands are particularly difficult to control, are
poisonous to livestock, negatively affect palatably or livestock performance, impart off flavors to
milk products, and may be noxious regulated species (USDA APHIS, 2009, p. 73).
Competition for light, water and nutrients. A grower tries to capture the plant resources on
his land - primarily light, water, and nutrients - for his crop; however, competitive weeds often
secure some of these resources for their growth, at the expense of the crop. Some common
characteristics of competitive weeds are rapid seedling establishment, high growth rates, prolific
root systems and large leaf areas.
Weed persistence. Persistent weeds are able to survive year after year on a given piece of
ground, in spite of a farmer's efforts to control them. Some plants are both competitive and
persistent through the production of large numbers of seeds. The bushy wild proso millet, for
example, shatters upon contact when mature, and can produce 400 to 12,000 seeds per square
foot. While high reproductive rates also contribute to a weed’s persistence, seed dormancy is
also an important trait in persistence. Cultivated soils typically contain thousands of seeds per
square meter, waiting for the opportunity to germinate. Some seeds, for example, velvetleaf,
can remain viable in the soil for up to 50 years. Many perennial weed species have the ability to
reproduce from root fragments. Canada thistle, for example, has a deep, spreading root system
that can continue to send up shoots after the surface plant has been removed multiple times.
Some weeds have the ability to alter their characteristic in response to stress; for example,
some weeds respond to drought by flowering and going to seed early (Tranel, 2003; McDonald
etal.,2003, pp. 9-12).
Weeds are controlled in conventional alfalfa and RRA with chemicals (herbicides), cultural
methods (rotation, mowing, companion crops, monitoring), and mechanical methods (tillage).
The cultural and mechanical methods are permitted for organic farmers. RRA systems allow for
the use of one additional herbicide, glyphosate.
2.4.2 Problem weeds in alfalfa production
The following weeds have been identified as problem weeds in alfalfa that prevent production of
maximum yields: Barnyardgrass, Bermudagrass, Bluegrass (annual), Bromes, Buckhorn
plantain. Bulbous bluegrass. Burning nettle, Canarygrass, Chesseweed, Chickweed (common),
Coastal fiddleneck, Cupgrass, Dandelion (common), Dodder, Filarees, Field bindweed.
Events J101 and J163
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Flixweed, Foxtail (green), Foxtail (yellow), Foxtail barley, Goosegrass, Groudsel (common).
Hare barley, Johnsongrass, Junglerice, Knotweed, Lambsquarter (common), London rocket,
Miner’s lettuce. Mustards, Nettleleaf, Nightshade, Nutsedges, Palmer Amaranth, Pepperweeds,
Prickly lettuce, Quackgrass, Redmaids, Russian thistle. Ryegrass, Shepardspurse, Sowthistle,
tinkgrass. Wild oats, WId Radish, Witchgrass, and Yellow starthlstle (UC IPM, 2006) . These
weeds are summarized in Table 2-5. Most of these weeds, and others, are present throughout
all the alfalfa growing regions. Certain weeds are classified as annual, biennial or perennial. An
annual or biennial is a plant that completes its life cycle to produce seed in one or two years (or
less), respectively. Perennials are plants that live for more than two years. They may reproduce
by seeds, rhizomes (underground creeping stems) or other underground parts. Weeds are
further classified as broadleaf (dicots) or grasses (monocots).
Table 2-5 Weeds In Alfalfa
Common Name
Scientific
GR
Types
Season
Name and
Biotype
c
s
Synonyms
Reported
2
2
ti
in
c
c
in U.S.
c
a>
U
M
«
0
1
Q
Q>
£
3
sf
c o
SI
s
1
e e
« "5
o ^
*0 3
o o
0
1
s
iS
z
m
o
0.
S S
&>
Barnyard grass
Echinochloa
cruS'galli,
cockspur grass,
Japanese millet
walergrass
cockspur
watergrass
NA
Grass
SA
X
X
X
X
X
X
Bennudagrass
Cynodon spp.
NA
Grass
P
X
X
X
Bluegrass
Poa annua
NA
Grass
WA
X
X
X
(annua!)
walkgrass,
annual
bluegrass
Bromes
Bromus spp.
NA
Grass
WA
X
Buckhorn
Planiago
No
Broadleaf
P
X
X
plantain^
lanceolata
Bulbous
bluegrass
Poa bulboaa
NA
Grass
P
X
Burning nettle
Uriica dioic
California nettle
slender nettle
stinging netUe
tali nettle
NA
Broadleaf
A
X
Canarygrass
Phalaris
arundinacea
NA
Grass
WA
X
canarygrass
reed
canarygrass
Phalaris
canarlansts
canary grass
Phalaris minor
canarygrass
littleseed
canarygrass
Chesseweed
Malva neglecia
buttonweed
NA
Broadleaf
WA-P
X
X
Events J101 and J163
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906
Common Name
Chickweed
(common)
Coastal
fiddleneck
Cupgrass
Dandelion
(common)
Dodder
FItarees
Field bindweed
Fiixweed
Foxtail (green)
Foxtail (yellow)
Scientific
GR
Types
Season
Name and
Biotype
—
c
o
Synonyms
Reported
2
2
■o a
<0
c
c
in U.S.
c
o
O
iO
c
o
o
f
ts
9
X
3
1 1
11
c o
CL
«
£
I
e c
2 2
o c
T3 3
1
3
iS
z
<0
ii
0
a
S I
<0
cheeseplant
Bttle mallow
common mallow
Stellaria media
NA
Broadleaf
WA
X
X
X
X
X
Amsinckia
NA
Broadleaf
WA
X
menziesn var.
intermedia
coast buckthorn
coast fiddleneck
common
fiddleneck
fiddlenedc
Eriochloa
gracilis
southwestern
cubgrass
tapertip
cupgrass
Eriochloa
contracia
prairie cupgrass
Eriochloa villosa
wooly cupgrass
Taraxacum
officinale
blowbali
common
dandelion
faceclock
Cuscuta
50 common
names for the
species in the
genus
Erodium spp.
Convolvulus
arvensis
creeping jenny
European
bindweed
morningglory
perennial
morningglory
Smallflowered
morningglory
Descurainia
Sophia
fiixweed
pinnate
tansymustard
Sataria viridis
bottle grass
green
bristlegrass
green foxtail
green millet
pigeongrass
wild millet
Setaria giauca
pearl millet
pigeongrass
NA Broadleaf SA
X X X X
NA Broadleaf WA XXXXXXXX
NA Broadleaf P X X
NA Broadleaf WA XXX
NA Grass SA XXXXXXX
NA Grass SA X X X X X X
Events J 101 and J 163
Environmental Report
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Common Name
Foxtail barley
Goosegrass^
Groundsel
(common)
Hare barley
Johnsongrass^
Junglerice^
Knotweed
Lambsquarter
(common)
London rocket
Miner’s lettuce
Mustards
Mustards
Nettleieaf
Nightshade
Scientific
OR
Types
Season
Name and
Biotype
Synonyms
Reported
in U.S.
wild millet
yellow
bristlegrass
yellow foxtail
Hordeum
jubatum
NA
Grass
P
Eleusine indica
crowsfoot
No
Grass
SA
grass
Indian
goosegrass
manienie aiii’i
silver
crabgrass
wiregrass
Senecfo vulgaris
ragwort
oW-man-in-the-
NA
Dicot
WA
Spring
Hordeum
leporinum
hare barley
leporinum
NA
Oicot
WA
barley
wild barley
Sorghum
Yes (1)
Grass
P
halepense
aieppo
milietgrass
herbe de cuba
State
sorgho d‘ Alep
sorgo de alepo
zacate Johnson
Echinochloa
colona
No
Grass
SA
Jungle rice
watergrass
Polygonum
arenastrum
NA
Broadteaf
SA
common
knotweed
doonveed
matweed
ovaiieaf
knotweed
prostrate
knotweed
Chenopodium
album
Yes
Broadleaf
SA
Lambsquarlers
VWiite goosefoot
Sisymbrium irio
NA
Grass
WA
Claytonia
parfoMa
NA
Dicot
WA-P
Brassica spp.
NA
Broadleaf
WA
Brassica spp.
NA
Broadleaf
SA
Chenopodium
NA
Broadleaf
SA
murale
Solanum^
sarracholdes
NA
Broadleaf
SA
Hairy
nightshade
«
(6
Ui
X
X
X
X X
X
X
X
If
C 9
il
X
X
X
X
X X
X
tt 3
o o
s s
X
X
X
X
X
X X
XXX
X
X
X
Events J101 and J163
Environmental Report
50
Affected Environment
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908
Common Name
Scientific
Name and
Synonyms
Hoe nightshade
GR
Biofype
Reported
in U.S.
Nutsedges
Cyperus
esculentus
yellow nutgrass
yellow nutsedge
Cyprus rotundus
chaguan
Humatag
cocograss
kili'o'opu
nutgrass
pakopako
purple nutsedge
NA
Palmer
Amaranthus
Yes (8)
Amaranth'
palmeri
carelessweed
<type of
pigweed)
States
Pepperweeds
Lepidium
densiflorum
Cwnmon
pepperweed
Greenflower
pepperweed
peppergrass
NA
Prickly lettuce
Lactuca serriola
China lettuce
wild lettuce
NA
Quackgrass
Elytrigia repens
couchgrass
quackgrass
quickgrass
quitch
scotch
twitch
Elymus repens
couchgrass
dog grass
NA
Redmaids
Calandrinia
dilate
NA
Russian thistle
Salsola kali
tumbleweed
Salsola iberica
prickly Russian
thistle
tumbleweed
tumbling tttistte
NA
Ryegrass'
LoUum
multiforum
Italian ryegrass
annual
ryegrass
Yes (3)
States
Shepardspurse
Capsella
bursapastoris
Shephardspurse
NA
Sowthistle
Sonchus spp, (5
species)
NA
Stlnkgrase
Eragrostis
citianensis
candy grass
lovegrass
strongscented
NA
Types Season
Grass P
Broadleaf SA
Broadleaf WA
Broadleaf WA
Grass P XX
Broadleaf
WA
Broadleaf
SA
X
Grass WA X
Broadleaf WA X X X
Broadleaf P
Grass SA
sf
c o
is
c
a!
X
X
X
X
X X
s
z
Q.
X
X
X X
X X
X X
X X
X
XXX
X
X
Events J101 and J163
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51
Affected Environment
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909
Common Name
Scientific
GR
Types
Season
Name and
Biotype
—
c
o
Synonyms
Reported
1
ra
f 1
v>
1
in U.S.
c
o
O
%
(9
c
e
o
f
o
Q>
x:
3
O
« 3
X o
5 =
£ S
s.
13
S
s
z
e c
S S
a> c
XS 3
o o
1
3
o
Hi
z
<0
O
0.
SS
0)
lovegrass
Wild oats
Avena fatua
flaxgrass
oatgrass
wheat oats
NA
Grass
SA-WA
X
X
X
X
Wild Radish
Raphanus
raphanistrum
NA
Broadieaf
SA
X
X
X
W'rtchgrass
Panicum
capiltare
NA
GrsBs
SA
X
X
panicgrass
ticklegrass
tumble panic
tumbleweed
grass
witches hair
Yellow
Cantaurea
NA
Dicoi
WA
X
X
starthistle
solstitialis
1 - Glyphosate resistant weed
Note: Refer to Table G-8 in the draft EIS for Glyphosate resistant weed infestations by state
Source; (yC IPM. 2006), <USDA APHIS, 2009, Tables G-3 and G-7), and (USDA, 2010b)
2.4.3 Use of herbicides to control weeds
Herbicides are used at three different phases in conventional alfalfa farming, which include
stand establishment (to prepare the ground), established stands (to control weeds), and during
stand removal (to kill alfalfa). The 17 EPA-registered herbicides that are used for stand removal
or to control volunteer alfalfa include:
Herbicide
2,4-DB (Butyrac, Butoxone)
Benfluralin (Balan)
Bromoxynil (Buctril) -
Clethodim (Prism, Select)
Diuron (Karmex, Direx)
EPTC (Eptam)
Hexazinone (Velpar)
Imazamox (Raptor)
Imazethapyr (Pursuit)
Metribuzin (Sencor)
Norfluzaon (Solicam)
Paraquat (Gramoxone Inteon)
Mode of Action
- Synthetic Auxin; Growth regulator
- Dinitroanalines; Microtubule assembly inhibition
- Nitriles; Photosystem II inhibitors
- Acetyl-CoA carboxylase (ACCase) inhibitors
- Ureas, Amides; Photosystem II inihitors
- Thiocarbamates; Seed growth inhibitors (shoot)
- Photosystem II inhibitors
- Acetolactate synthase (ALS) inhibitors
- ALS inhibitors
- Photosystem II Inhibitors
- Carotenoid biosynthesis inhibitors
- Bipyridiliams; Cell membrane disrupter
Events J101 and J163
Environmental Report
52
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910
Pronamide (Kerb)
Sethoxydim (Poast)
Terbacil (Sinbar)
Trifluralin (Treflan/TR-IO)
- Dinitroanilines; Microtubule assembly inhibition
- ACCase Inibitors
- Photosytem II Inhibitors
- Dinitroanilines: Microtubule assembly inhibition
Source: (USDA APHIS, 2009, Table G-1) and (Heap, 2010)
Table 2-6 summarizes the effectiveness of the herbicides on broadleaf weeds in seedling
alfalfa, Table 2-7 summarizes the effectiveness of the herbicides on grass weeds in seedling
alfalfa, and Table 2-8 summarizes the effectiveness of herbicide combination control on weeds
in seeding alfalfa.
Alfalfa stands are usually thinning and vulnerable to weeds after 2 to 8 years. Alfalfa stands are
typically removed by killing the alfalfa by either tillage, herbicide application, or both. RRA
cannot be removed using glyphosate; therefore, just like conventional alfalfa, RRA can be
removed using tillage and/or labeled, non-glyphosate herbicides.
Events J101 and J163
Environmental Report
63
Affected Environment
8/5/2010
Table 2-6
911
2ZZ2 2 Z Z ZZZZ ZZZZ Z ZZ ZZ ZZZ Z ZZ
ZZZZ ZZZ ZZZZ ZZZZ Z ZZ ZZ ZZZ Z ZZ
O Z'>ZZQ. ZZZZ 0-0 OOOZ ZZZO I ZO ZQ. OOZ Z ZQ.
K ZOCLOQ-Z OO-O-D. ZOZ OOOZ Q. Q. Z O ' OZ 0.0 O Z O O OZ
OZZZ ZOZ OOOZ OZZ'
OZ ZO OZZ Z ZZ
OOOZ OOO OOZO ZOOO < ZO OZ O 'O o
N ZOZOOZ OZOZ OOO OOZO ZOOO ‘ ZO OZ O'O
s
> ZOZOOO OOOZ OOO ZOZO ZOOO O ZO OO OOO O ZZ
< ZOZOOZ OZOZ zoo ZOZO ZOOO Z ZO OO OOO
s
K O-OOOZ <000 Z'O OOZZ -OZO ' OO OZ OOO o ZZ
J O lOOOO OOOO OOO OOOO OOOO ' OO OO OOO
o
lU ZZZZZZ ZZZZ ZZZ ZZZZ ZZZZ Z ZZ ZZ ZZZ Z ZZ
ZZZZ ZZZ ZZZZ ZZZZ Z ZZ ZZ ZZZ Z ZZ
O ZZZZOZ ZOZO zoo OZOZ OOZO O OO OZ O'O O OZ
Q ZZZZOO OZZO zoo OZOZ OOOO O ZO OZ ozo
Q ZZZZOO ZZZO zoo OZOZ ZOZO O ZO OZ ozo o OZ
Q ZZZZOO ZZZZ ZOZ OZOZ ZZZO • ZO ZZ
w 2 Z- 5? ’K oi
sllsl Jl .■
i if 1| S||
% all
i f
£ ^
IT a
^ o
-O q :
O flj
^ o
C .h=
o >
> c
LU LU
912
2 2 Z 2 2 2
222 222
■ 02 22 -
OO O Q. Q. 2
O'' 222
... O ■ •
... O - •
0 2 2 O OO
0 2 2 O OO
• O O O O ■
■O' O O '
z z z z z z
z z z
• z o
Z Z 0.
2 2 2
2 Z Z
2 2 Z
Z Z Z
OQ. •
0 2 2
O a. O
O Z O
0 2 0 .
ilii«
illll
fO
2 O
IT Q.
I!
^ cc
ra g
o g
^ E
fr
B §
Table 2-7 Susceptibility of Grass Weeds in Seedling Alfalfa to Herbicide Control
913
I-
1 S ^
O X
q:
LU .
5 >f ^
ui o
P i g. i
S » « fcS
o -• c g*« =
0 <9 3 5. <5 -S ^
01 o a c'£ S >
Environmental Repoi
914
invironmental Repoi
915
Table 2-8 Susceptibility of Weeds in Seediing Alfalfa to Herbicide Combination Control
POSTEMERGENT COMBINATIONS
BROADLEAF
BRO
BRO
BRO
BRO
BRO
iMA
IMA
IMA
SET
IMA
iMA
WEEDS
IMA'
24DB'^
SET^
CLE*
HEX*
24DB’*
CLE^
SET®
24DB®
PAR’®
hex”
burclover
N
N
N
N
P
N
N
N
N
N
p
buttercup
C
N
N
N
N
C
C
C
N
C
c
celery, wild
N
N
N
N
N
N
N
N
N
P
p
chickweed
C
N
N
N
C
C
C
C
N
C
c
cocktebur
C
C
C
C
C
C
C
c
C
c
c
dock, curly
C
C
N
N
N
P
N
N
C
N
p
{seeding)
doverfoot
C
P
N
N
N
c
C
C
P
C
c
fiddleneck
C
C
C
C
C
N
N
N
N
P
p
nilarees
C
N
N
N
P
P
P
P
N
c
c
groundsel,
C
C
C
C
c
N
N
N
C
c
c
common
henbit
P
N
N
N
p
N
N
N
N
N
N
jimsonweed
C
C
C
C
c
C
C
C
C
C
C
knotweed
P
P
P
P
p
C
P
P
P
P
c
(seedling)
lambsquarters
c
C
C
c
c
C
N
N
C
c
c
lettuce, miners
c
N
N
N
p
C
C
C
N
c
c
lettuce, prickly
c
C
C
C
c
C
N
N
C
c
N
mallow, little
c
N
N
N
N
C
P
P
N
c
C
(cheeseweed)
milkthistle
p
P
N
N
N
N
N
N
P
p
mustard, black
c
C
C
C
C
C
C
C
P
c
C
nettle, burning
c
N
N
N
N
C
P
P
N
p
C
nightshade,
c
C
C
C
C
C
C
C
C
c
C
hairy
oxtongue.
p
P
C
C
P
.
N
N
P
.
P
bristly
pineappieweed
p
C
C
C
P
N
N
C
c
pigweed.
c
C
P
P
c
c
C
C
c
c
c
redroot
radish, wild
c
P
P
P
p
p
P
P
p
p
c
rockpurslane,
c
N
N
N
N
c
C
c
N
c
c
desert
rocket, London
c
C
C
C
P
c
C
c
C
c
c
rush, toad
c
.
.
C
c
C
c
N
c
c
shepherd's*
c
c
c
C
C
p
P .
p
P
p
c
purse
smartweed.
c
c
c
c
c
c
c
c
C
c
c
swamp
sowthistle
c
c
c
c
c
N
N
N
c
c
N
speedwell,
N
N
N
N
N
N
N
N
N
N
N
thymeleaf
spurge, petty
c
N
N
N
N
C
C
C
N
c
C
spurry, com
N
N
N
N
C
N
N
N
N
c
C
starthistle.
C
C
C
C
c
H
N
N
N
c
-
yellow
sunflower, wild
C
C
C
C
c
C
C
C
C
c
c
swinecress
c
N
P
P
-
C
C
C
P
c
c
willowherb.
c
C
-
.
-
C
c
C
C
c
c
panicle
GRASS
WEEDS
barley, hare
N
N
C
c
N
N
c
P
C
p
N
bamyardgrass
C
N
c
c
N
C
c
C
C
c
c
bluegrass,
N
N
N
p
N
N
c
N
N
c
p
annual
brome, ripgut
N
N
P
c
N
N
c
P
P
p
N
canarygrass,
P
N
C
c
N
P
c
C
C
p
P
hood
fescue, rattail
N
N
N
.
N
N
N
N
p
N
foxtail, yellow
P
N
C
c
N
N
c
C
C
p
P
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BROADLEAF
BRO
BRO
BRO
BRO
BRO
IMA
IMA
IMA
SET
IMA
IMA
WEEDS
IMA’
24DB’^
SET*
CLE*
HEX*
2408**
cle’’
SET*
24DB’®
PAR’”
HEX”
goosegrass
N
N
P
N
N
N
p
P
P
N
N
oat, wild
P
N
C
C
N
P
c
C
C
P
P
punagrass
N
N
P
-
N
N
p
P
P
N
N
ryegrass,
Italian
N
N
c
c
N
N
c
c
C
C
N
wheat,
volunteer
P
N
c
c
N
N
c
c
G
P
P
Source: {UC IPM, 2009)
Ratings Legend
G = control (100-80% control)
P = partial control (79-65% control)
N = no control (less than 65% control)
- = no information
Chemical Legend
’ = bromoxynil (Buctril 0.25) + imazethapyr (Pursuit 0.064)
^ = bromoxynil (Buctril 0.25) + 2,4-DB*(Butoxone 1 .0, etc.)
’ = bromoxynil (Buctril 0.375) + sethoxydim (poast 0.375)
= bromoxynil (Buctril 0.375) + clethodim (Prism 0.25)
® = bromoxynil (Buctril 0.25) + hexazinone (Velpar 0.125)
® = imazethapyr (Pursuit 0.063) + 2,4-DB*(Butoxone 0.5, etc.)
^ = imazethapyr (Pursuit 0.063) + clethodim (Select Max 0.1)
® = imazethapyr (Pursuit 0,063) + sethoxydim (Poast 0.375)
® = sethoxydim (Poast 0.375) + 2,4-DB*(Butoxone 1.5, etc.)
= imazethapyr (Pursuit 0.063) + paraquat* (Gramoxone 0.25)
” = imazethapyr (Pursuit 0.094) + hexazinone (Velpar 0.25)
Comments
NOTE: Weed size and spray coverage impact weed control as will herbicide rate, adjuvant
type, spray volume, and environmental conditions.
* Permit required from county agriculture commissioner for purchase or use.
2.4.4 Non-herbicide weed management practices
Weeds can also be controlled through cultural and mechanical methods. Weed management
options include:
• Rotation of crops
• Winter crops In rotation
• Mowing or flash grazing
• Companion crops/co-cultivation/interseeding/nurse crop
• Cover crops (smother crops) (prior to planting alfalfa)
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• Field scouting for early detection
• Monitor for weed species and population shifts
• Mechanical removal
• Adjusting harvest frequency
• Burning
• Tillage cultivation (seed production only)
Forage harvest removes weed biomass and developing weed seedlings. Regular forage
harvest at late vegetative/mid bud stage combined with healthy competitive stands, effectively
manage many key weed species, especially during the middle stages of a specific stand. Crop
rotations can help maintain soil fertility, reduce soil erosion, avoid pathogen and pest buildup,
adapt to weather changes, avoid the effects to reduce growth of one plant due to chemicals
released by another, and increase profits. Alfalfa is also used in crop rotation because it
provides nitrogen to the soil, which decreases fertilizer inputs in other rotations. Perennials and
annuals promote and restrict different weeds, so rotating perennial and annual crops helps
control weeds in general. Rotating alfalfa is also advised because mature alfalfa is autotoxic to
seedling alfalfa (USDA APHIS, 2009, p. 74-75).
2.6 HERBICIDE RESISTANCE
Herbicide resistance is “the inherited ability of a plant to survive and reproduce following
exposure to a dose of herbicide normally lethal to the wild type" (WSSA, 1998).
Herbicide resistance is a result of natural selection. Plants within a population of a given
species are not all identical; they are made up of “biotypes" with various genetic traits. Biotypes
possess certain traits or characteristics not common to the entire population. Herbicides, that
suppress or kill weeds, can exert selection pressure on weed populations. When a herbicide is
applied, the plants with genes that can confer resistance to it, which had no special survival
qualities before the herbicide was introduced, become the survivors who are then able to
reproduce and pass on their genes. With repeated application of the same herbicide and no
other herbicide or weed control practice, the resistant biotype becomes the dominant biotype in
that weed community. In the mid-1950s. Harper (1957) theorized that annual, repeated use of
any herbicide could lead to shifts in weed species composition within a crop-weed community.
Similarly, Bandeen et al. (1982) suggested that a normal variability in response to herbicides
exists among plant species and tolerance can increase with repeated use of an herbicide.
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Indeed, as of June 27, 2010, 341 herbicide resistant weed biotypes have been reported to be
resistant to 19 different herbicide modes of action (Heap, 2010). Glyphosate-resistant weeds
account for 5 percent of the herbicide resistant biotypes (as documented on the
www.weedscience.org website) while weeds resistant to herbicides that inhibit acetolactate
synthase (ALS), such as Raptor and Pursuit, account for 31 percent of the herbicide resistant
biotypes (Wilson, 2010a, p. 6).
Figure 2-2 shows the increase in herbicide resistant biotypes with time. Among the herbicides
commonly used in conventional alfalfa. Prism, Poast and Select are ACCase inhibitors; Raptor
and Pursuit are ALS inhibitors; Butyrac and Butoxone are growth regulators, and Karmex and
Direx are in the category of photosynthesis inhibitors. Figure 2-2 shows only the number of
confirmed resistant biotypes. The total extent and distribution of resistant biotype varies widely.
Details of herbicide resistant weed in alfalfa are discussed in Section 3,1 1 .
For as long as herbicide resistance has been a known phenomenon, public sector weed
scientists, private sector weed scientist and growers have been identifying methods to address
the problem. For instance, when a farmer uses multiple weed control tools, each effective on a
particular species, herbicide resistance biotypes will be controlled and the resistance biotype
generally will not become the dominant biotype within a population (Gunsolus, 2002; Cole,
2010a, p. 4). By contrast, weed resistance is known to occur most rapidly in areas where there
is a sole reliance
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Figure 2-2. Herbicide resistance worldwide
on a single herbicide used repeatedly over multiple crop generations for the management of a
specific weed spectrum.
When a grower encounters a biotype that is resistant to an herbicide he is using, the grower
must use an alternate method of weed control. Management practices that can be used to
retard the development of resistance, such as those routinely used by alfalfa growers, include
herbicide mixtures, herbicide rotation, mowing, and crop rotation.. The WSSA reports: “Weed
scientists know that the best defense against weed resistance is to proactively use a
combination of agronomic practices, including the judicious use of herbicides with alternative
modes of action either concurrently or sequentially” (WSSA, 2010b).
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2.6 SEXUALLY COMPATIBLE RELATIVES INCLUDING CONSPECIFIC FERAL AND
VOLUNTEER ALFALFA
2.6.1 Native sexually compatible relatives
There are no sexualiy compatible native reiatives of alfalfa present In the U.S. (Mallory-Smith
and Zapiola, 2008; Van Deynze et al., 2008, p. 7). No native members of the genus Medicago
are found in North America (USDA APHIS, 2009, p. 20).
2.6.2 Feral and volunteer alfalfa
Feral crops are those that have become de-domesticated. Based on available data, de-
domestication has occurred in only a few crops. These feral crops are of minor importance
compared with other weeds (Gressel, 2005). In North America, the feral plants that cause much
of the economic damage are imported horticultural plants; for example, Japanese privet,
Japanese honeysuckle and kudzu (Gressel, 2005).
For purposes of this ER, unmanaged alfalfa planted for pasture, grazing or road-side
reclamation (and similar uses) is also considered feral as, once established, they receive no or
minimal agronomic inputs (e.g,, clipping), Cultivated and feral alfalfa populations source to the
same Medicago saiiva L. germplasms that were repeatedly introduced to North America over a
400 year period.
Rogan and Fitzpatrick (2004) summarize the extent of feral populations in six major alfalfa-
producing States— California, Washington, Idaho, Wyoming, Nevada, and Montana—
confirming that minor feral populations do exist in areas where alfalfa seed or forage is
produced (USDA APHIS, 2009, p. 22). Compared to cultivated alfalfa, feral alfalfa occurs at a
relatively low density and scale. Kendrick et al. (2005) performed a biogeographic survey of five
states (California, Idaho, Pennsylvania, South Dakota, and Wisconsin) In 2001 and 2002 and
found that feral plants were not present or were sparse in most agricultural areas.
Approximately 22 percent of the surveyed sites had dispersed or patches of feral alfalfa within
1 .25 miles of cultivated alfalfa (Kendrick et al. 2005; Van Deynze et al, , 2008). Relative to the
geographies in which only forage is grown, areas with seed production fields were found to have
fewer feral alfalfa plants growing in roadsides. Using herbicides or mechanical means, feral
alfalfa can be and is controlled by certified alfalfa seed growers as a standard method to help
assure isolation from other sources of pollen during varietal seed production (AOSCA, 2009).
Feral, or naturalized, alfalfa populations can escape agricultural fields and multiply by natural
regeneration throughout the U.S. Feral alfalfa can be found at airfields, canals, cemeteries,
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ditch banks, fence rows, highways, irrigation ditches, pipelines, railroads, rangeland, right-of-
ways, roadsides, and wastelands. Alfalfa plants that are not part of cropping systems generally
have no regular external inputs like irrigation, herbicides, insecticides, and fertilizers. All feral
alfalfa in the U.S., like alfalfa under cultivation, originated from introduced varieties.
In general, survival without management inputs requires feral plant populations to have traits
that may differ from those of cultivated plants. The most common traits include:
• variety of pollinators,
• continuous seed production,
• considerable seed output,
• seeds produced in several habitats,
• seed dispersal over short and long distances,
• seed dormancy (ability to form a seedbank),
• broad germination requirements,
• discontinuous germination,
• rapid vegetative growth,
• ability to withstand competition,
t tolerance to unfavorable biotic and abiotic conditions, and
• rapid flowering
A portion of alfalfa seeds may be temporarily impervious to water; these are "hard” seeds. The
hard seeds may decay in soil or lay un-germinated (dormant) for a period of time (e.g., a few
weeks to several years). Gradually, the hard seed coat ages and the seed will germinate or
decay. Alfalfa develops small fragile seedlings that if successfully established may become
volunteers in subsequent crops or in unmanaged areas. Hard seed likely contribute few
volunteer plants after one year, as, alfalfa seeds generally do not persist for more than one year
in field soil (Albrecht et al., 2008). Data for persistence of hard seed in seed production fields is
given and discussed in Van Deynze et al. (2008), this confirms Albrecht et al. where studies
were done in forage plantings in the Midwest. To guard against hard seed carryover, seed
growers take steps to eliminate residual alfalfa volunteers prior to planting (Putnam and
Undersander, 2009, attached as Appendix I). AOSCA varietal purity standards (2009) require
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land history of 2 or 4 years without alfalfa cultivation, for the Certified and Foundation alfalfa
seed generations, respectively. Little to no secondary seeds are formed on hay crop stems
because they are harvested in their juvenile stage (weeks before any new, viable seed is
formed). A mature alfalfa stand is highly competitive and highly autotoxic to fragile, emerging
secondary seedlings. Therefore, secondary seedlings are a very unlikely avenue for effective
gene flow into existing solid-seeded alfalfa plantings. The autotoxic reaction and inter-plant
competition severely limit germination and seedling vigor of alfalfa sown or dropped into existing
or newly terminated alfalfa stands. Solid-seeded cultivated alfalfa fields do not successfully self-
seed, Attempts to thicken existing alfalfa stands by deliberately inter-planting new seed into
them typically fail, which is why most agronomists do not recommend the practice (Canevari et
al., 2000; USDA APHIS, 2009, p. 18-19, 100).
Several scientists have reported that volunteer GT plants could become a problem in rotational
crops when both rotational crops are GT, however none provided specific information or data
(e.g., Cerdeira and Duke, 2006; Owen and Zelaya, 2005; York et al, 2004; NRC, 2010). RRA
volunteers would be expected to be more of concern in crops grown for seed, such as corn and
soybeans. Volunteer alfalfa plants — whether conventional or RRA — are controlled by use of
mechanical means (e.g., tillage) or by application of several registered non-glyphosate broad-
leaf herbicides. Feral alfalfa can also be controlled using these practices, or with glyphosate.
2.7 FOOD. FEED AND OTHER ALFALFA USES
Both food (sprouts, dietary supplements, and herbal or homeopathic medicine) and animal feed
(hay, haylage, or silage) are derived from alfalfa.
Alfalfa forage, primarily harvested as hay or haylage, is used as a source of fiber and protein In
animal diets. Most alfalfa forage is fed to dairy or beef cattle, but can also be an important part
of the diet for horses, sheep and goats.
A small fraction of alfalfa seeds are used to produce sprouts for human consumption. Any
alfalfa seed for sprouts must be certified as having been produced to food-grade specifications
and therefore food-grade seed is grown and distributed in an entirely separate channel from that
for general use, non-food-grade planting seeds. Food-grade seeds for sprouts are produced
throughout the world, but the major suppliers are Canada, Italy, U.S. and Australia. Sprouts are
cultivated from clean raw (non-coated, untreated) seeds in controlled environment sprouting
chambers for approximately 5 to 10 days before sale to consumers.
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FDA and equivalent regulatory bodies in Japan, Korea, Canada, Australia/New/ Zealand, etc.,
have granted full approval for the use of RRA as a food (see Section 3.1 1). Monsanto and FGl
have developed the RRA varieties for field planting purposes (only), and as such the companies
do not intend nor allow (give license to) any seed growers or seed purchasers to use RRA
varieties for food-grade sprout production (Hubbard, 2008; USDA APHIS, 2009, p, 18),
2.8 PHYSICAL AND BIOLOGICAL ISSUES
The affected environment for land use, air quality, water quality, ecology, threatened and
endangered species, and other sensitive wildlife is the alfalfa producing areas and the seed
producing regions. The affected environment for climate is global, as impacts on climate
change are a global issue.
2.9 SOCIOECONOMICS AND HEALTH
The affected environment for socioeconomic issues includes those individuals who could
potentially be economically impacted if their food or agricultural products are adversely affected
by RRA, and those who could be economically impacted if RRA becomes a deregulated article.
Potential impacts to the first group are discussed primarily in Section 3.10 and impacts to the
second group are discussed in Section 3.15. The potential for health impacts to individuals who
may come into contact with RRA or alfalfa seeds or other products derived from RRA is
discussed in Sections 3.10 and 3.14. Health effects of potential exposure to herbicides are
discussed in Section 3.14.
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SECTION 3.0 ENVIRONMENTAL CONSEQUENCES
3.1 PLANT PATHOGENIC PROPERTIES AND UNINTENDED EFFECTS
APHIS previously determined, based on scientific analysis and in accordance with its
obligations under the PPA, that RRA does not exhibit plant pathogenic properties (USDA
APHIS. 2009).
APHIS considered the potential for the transformation process, the introduced DNA sequences,
or their expression products to cause or aggravate plant disease symptoms in RRA and its
progeny or in other plants.
APHIS also considered whether data indicate that unintended effects would arise from the
genetic engineering of these plants. APHIS considered information from the scientific literature
as well as data provided by Monsanto/FGI in their petition that was developed from their field
trials (USDA APHIS, 2009).
Based on the analysis summarized below, there are no impacts resulting from plant pathogenic
properties, introduced or aggravated disease symptoms, or unintended effects under any of the
alternatives. Details of the Wlonsanto/FG! studies are included in the petition (Rogan and
Fitzpatrick, 2004).
3.1.1 Background
Plant genetic modification
Plant genetic modification by humans ranges from the simple approach of directed selection -
where seeds of plants with desired traits are saved and replanted - to complex methods such
as the use of rDNA (see definitions on next page). APHIS regulations define genetic
engineering as genetic modification through the use of rDNA technology Crossing (and then
recrossing) two sexually compatible plants by taking the pollen from one plant and brushing it
onto the pistil of another remains the mainstay of modern plant breeding (IM/NRC, 2004). Both
more traditional, “conventional breeding” and rDNA methods can involve changes in the
frequency, sequence, order, and regulation of genes in a plant and can use many of the same
enzymes. However, with conventional breeding all the tens of thousands of genes in the plant
are involved, and with the rDNA method only a few genes are Involved, In classical breeding,
crosses can be accomplished only between closely related species, and therefore only traits
that are already present in those species can be targeted. In contrast, the rDNA approach can
^°7C.F.R. §340.1.
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use genes from any living organism, thus opening the door to vast potential in trait development
(Lemaux, 2008, p. 774; AMA, 2000).
Other examples of plant genetic modification include cell fusion (the protective celt wall is
stripped and cells are fused by some external force) and induced mutagenesis (inducing
mutations in seeds by ionizing radiation or carcinogenic chemicals) (Ronald and Adamchak p.
88). Mutagenic techniques, which have been in use since the late 1920s, create random
mutations and are limited by their inability to target a desired trait (FDA, 1992; Lundqvist, 2009,
p. 39),
Agrobacterium
Agrobacterium tumefaciens (Agrobacterium) is a soil microbe that has been called “nature’s
own genetic engineer” because of its ability to transfer a fragment of its own DNA into a host
plant (AMA, 2000). (See definitions at right.) The transferred DNA is stably integrated into the
plant DNA, and the plant incorporates and expresses the transferred genes. The transferred
DNA (T-DNA) reprograms the host plant cells to grow into callus tissue and produce certain
amino acid derivatives that are a food source for the Agrobacterium. On a macro scale, the
callus tissue growth is called crown gall disease. In the early 1980s scientists developed strains
oi Agrobacterium with T-DNA that lacked the disease-carrying genes (“disarmed”
Agrobacterium). Agrobacterium transformation system has been utilized in the development of
a large number of genetically engineered plants in commercial production (IM/NRC, 2004, pp.
28-29). The method uses a DNA molecule called a vector that serves as a carrier to insert T-
DNA that contains specific genetic elements. These genetic elements are organized into a
gene cassette, which consists of a gene encoding for a single biological function plus other
genetic elements necessary for the expression of that gene when introduced into the plant.
Other elements in the gene cassette include a promoter, which can be thought of as the “on
switch” for the gene encoding for the desired trait; and a targeting sequence, which makes sure
the gene product, typically a protein, ends up in the right location within the cell (such as the
chloroplast).
Unintended effects from breeding
Most crops naturally produce allergens, toxins or other antinutritional substances; these often
serve the plant as natural defense compounds against pests or pathogens (FDA, 1992), Plant
breeders may monitor the levels of antinutritional substances relevant to their crop. For
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example, lignin is an indigestible cell wall component that limits forage digestibility. Alfalfa
breeders typically monitor lignin content of plants in their breeding programs.
Scientists from the Institute of Medicine (IM) and the National Research Council (NRC) ranked
breeding methods according to their relative likelihood of producing unintended effects, which
they hypothesized would correspond to the degree of genetic disruption associated with the
method. Selection from a homogeneous population was ranked at one end of the spectrum
(less likely to produce unintended effects) and induced mutagenesis (from chemicals or
radiation) was ranked at the other end (more likely). Agrobacterium transfer of rDNA was
among the methods ranked in between (IM/NRC, 2004, Figure ES-1). Recent studies in Europe
comparing transgenic and conventional barley suggest that conventional breeding may cause
more unintended effects than rDNA methods, likely because of the very large number of genes
that are affected in conventional breeding techniques (Sonnewald, 2010).
Glyphosate tolerance
As discussed in Section 2, glyphosate acts by inhibiting the action of the enzyme EPSPS, in
plants. EPSPS is a catalyst for a reaction necessary for the production of certain amino acids
essential for plant growth. When plants are treated with glyphosate the EPSPS enzyme is
inhibited, they cannot produce the amino acids needed for continued growth and eventually die.
The EPSPS protein and the reaction it catalyzes are present in all plants and microbes. There
are variations in the amino acid sequence of EPSPS among different plants and bacteria. GT is
achieved by introducing an EPSPS enzyme, termed CP4 EPSPS, that is not inhibited in the
presence of glyphosate. An Agrobacterium strain (designated CP4) was the source of the CPR
EPSPS gene that encodes for the CP4 EPSPS enzyme (Rogan and Fitzgerald, 2004). The
CP4 EPSPS enzyme carries out the same enzymatic reaction in the plant as the native EPSPS;
however, when plants that contain the CP4 EPSPS are sprayed with glyphosate, they are able
to continue to produce the essential amino acids needed for plant growth. The objective of the
genetic modification in RRA was to simplify and improve weed management practices in alfalfa
by the addition of the CP4 EPSPS enzyme to confer tolerance to glyphosate (USDA APHIS,
2005),
Transformation system
RRA was developed using a disarmed Agrobacterium-mediated transformation system of sterile
alfalfa leaflets. Post-transformation, the Agrobacterium were eliminated from tissues by a 7-
week culture on antibiotic-containing medium. Glyphosate was used to select for transformed
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tissues containing the EPSPS gene construct. This technique of using a disarmed
Agrobacterium strains followed by selection has a 20-year history of safe use and has been
used for transformation of a variety of plant species and tissues. The plant material used for
development of RRA was FGI proprietary alfalfa clone R2336 from a high yielding, fall dormant
breeding population. The initial plants, selected for tolerance to glyphosate, were designated
J101/J163, and various populations were developed from these events to provide the data
presented in the petition (USDA APHIS, 2005).
DNA sequences inserted into RRA
Data supplied in the petition and reviewed by APHIS indicate that the CP4 EPSPS expression
cassette inserted into alfalfa events RRA contains the CP4 EPSPS coding sequence under the
regulation of the 35S promoter, a heat shock protein intron (HSP70), a chloroplast transit
peptide (CTP2) sequence and a E9 3’ polyadenylation sequence. The CTP2 CP4 EPSPS
coding region used to produce events J101/J163 is the same as that employed in several other
RR crops such as soybean, which have been previously reviewed and granted non-regulated
status by the USDA. The CP4 EPSPS gene does not cause disease and has a history of safe
use in a number of GE plants (e.g., corn, cotton, and soybean varieties),
3.1.2 Evaluation of intended effects
Anaiysis of inheritance
Data were provided by Monsanto/FGI and reviewed by APHIS that demonstrate stable
integration and inheritance of the EPSPS gene cassette over several breeding generations.
Statistical analyses show that GT is inherited as a dominant trait in a typical Mendelian manner
(M).
Anaiysis of gene expression
Monsanto/FGI collected data on EPSPS protein concentrations from field trials conducted at
several locations. The companies determined EPSPS protein concentrations using standard
laboratory techniques. EPSPS concentrations on a fresh weight basis averaged 257
micrograms (pg)/gram in plants with event J101 , 270 pg/gram in plants with event J163, and
252 (jg/gram in plants from the population containing both events J101/J163. EPSPS is
ubiquitous in plants and microorganisms and has not been associated with hazards from
consumption or to the environment. Crops that contain this protein and have been granted non-
regulated status have included corn, soybean, cotton, rapeseed, and sugar beet (USDA APHIS,
2010a). In 2009, significant acreages of corn (59 million acres or 68 percent of the total), upland
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cotton (6.3 million acres or 71 percent of the total) and soybean (70.5 million acres or 91
percent of the total) grown in the U.S. were planted with herbicide tolerant varieties (USDA
NASS, 2010c). Although these acreages include all herbicide tolerant varieties, GT ones
(containing CP4 EPSPS) predominate. All have also undergone FDA review (FDA, 2010).
Analysis of the intended trait
Monsanto/FGI conducted numerous field trials to evaluate RRA in different environments.
Standard field trials evaluated (1) agronomic performance, (2) disease and pest resistance
performance, and (3) seed multiplication. Agronomic practices used to prepare and maintain
each field trial were characteristic of each representative region. Where the glyphosate
herbicide Roundup® was used in trials, no negative impacts from application were noted
(Rogan and Fitzpatrick, 2004).
3.1.3 Evaluation of possible unintended effects
Disease and pest susceptibility
On the basis of pest and disease susceptibility data reviewed by APHIS, RRA populations were
no different from control or conventional alfalfa populations in the prevalence of or response to
diseases or pests. Since the deregulation of RRA in 2005, there have been no reports of any
change in disease or pest interactions in RRA compared to conventional alfalfa (USDA APHIS
2009).
During field trials from 1 999 to 2003 and after deregulation of RRA in 2005, RRA has been
grown over a broad geographic distribution of sites in the U.S. This has exposed RRA to a wide
range of naturaiiy occurring diseases. The principal alfalfa diseases in the U.S. affect the foliar,
crown, root, vascular, and seedling health of alfalfa plants. Fungi are the primary pathogen type
involved in most alfalfa diseases. Nematodes, bacteria, viruses, and other microbes can also
reduce alfalfa production. The major economic diseases that occurred during field trials
included: seedling damping-off (fungal genera such as Pythium, Phytophthora, Aphanomyces):
foliar diseases (fungal genera such as Leptosphaerulina, Colletotrichum, Peronospora, Phoma,
Stemphylium, Cercospora, and stem nematodes like Ditylenchus); and root rots, vascular wilts
and crown diseases (fungal genera such as Phytophthora, Aphanomyces, Verticilllum,
Fusarium, Phoma, and bacterial wilt caused by Clavibactei) (USDA APHIS, 2009).
The major insect pest species affecting alfalfa vary between regions in the U.S. During field
trials and after deregulation of RRA in 2005, RRA has been exposed to a wide range of
naturally occurring insect pests. The principal economic insects included: potato leafhoppers
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{Empoasca fabae), aphids [pea {Acyrthosiphon pisum), blue (A. kondoi) and spotted alfalfa
aphids (Therioaphis maculata)], alfalfa weevil (Hypera postica), lygus bugs {Lygus species),
other plant bug species (family Miridae) and alfalfa caterpillars (various Lepidopteran species).
The disease and pest susceptibility obsen/ations for the field trials were provided to APHIS.
These observations consistently showed no significant differences in the disease and insect
susceptibility between events J101/J163 (or synthetic populations developed using both events)
and the conventional control lines or commercial reference varieties. Although occasional
differences were noted at some field sites, there were no concurrent trends of differences
across field sites or years. This suggests that these differences were likely due to random
variation. Additional disease ratings taken as part of the phenotypic comparative studies also
indicate that diseases and pest incidence are unchanged in RRA compared to the control and
that RRA is not more or less susceptible to pests or diseases than conventional alfalfa.
Commercial experience and additional research conducted since the 2005 deregulation
decision are consistent with the findings from field trials during the regulated period (USDA
APHIS, 2009).
Gene silencing
In evolutionary biology, a homologous trait is one derived from a common ancestor that appears
in multiple species. Homology may be manifested on a macro scale, for example, in the
similarity in mammal forelimbs, and on a genetic scale, in DNA sequences. Al-Kaff et al. (1998)
have noted gene silencing effects when transgenic plants have been infected by a virus with
DNA sequence homology to a portion of the introduced genes. The only virus-derived DNA in
the introduced gene cassette is the promoter, which is from the figwort mosaic virus. None of
the viral diseases of alfalfa is related to figwort mosaic virus (Whitney and Duffus, 1986), so
silencing of the EPSPS gene would not be expected and has not been observed.
Compositional changes
The composition of forage produced by RRA plants containing either event J101, J163, or the
paired events J101 X J163 was measured and compared to the composition of control and
conventional alfalfa forage (Rogan and Fitzpatrick, 2004). Monsanto/FGI analyzed alfalfa for
compositional changes as part of their submission to FDA in the consultation process. While
FDA uses these data as indicators of possible nutritional changes, APHIS views them as
general indicators of possible unintended changes.
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Compositional analyses evaluating carbohydrates, protein, ash, minerals, fiber, lignin, fat, and
18 amino acids (a total of 35 different components) identified three statistically different values
compared with the control population for J101, seven statistically different values for J163, and
1 1 statistically different values for the paired J101 X J163 population. However, all analyses fell
within the 99 percent tolerance interval developed from the conventional varieties grown in the
same locations, providing additional evidence that J101, J163 and the paired J101 X J163
populations do not exhibit unexpected or unintended effects (USDA APHIS, 2005).
3.2 WEEDINESS PROPERTIES AND FERAL CROPS
This section addresses two questions:
1 . What are the weediness properties of alfalfa?
2. Is RRA any more likely to become a weed than conventional alfalfa?
For information on feral alfalfa or volunteer alfalfa, refer to Section 2.6.2.
3.2.1 Weediness properties of alfalfa
Alfalfa (Medicago saliva L.) is not listed as a serious weed in A Geographical Atlas of World
Weeds (Holms et al., 1991) or as a weed in World Weeds: Natural Histories and Distribution
(Holms et al., 1997), Weeds of the North Central States
(hltp://www.aces.uiuc.edu/vista/html_pubsA/VEEDS/list,html ), Weeds of the Northeast (XJva et
al.,1997), or Weeds of the Wesf (Whitson et al., 1992). Alfalfa is not listed as a noxious weed
species by the U.S. Federal Government (7 C.F.R. Part 360) and is not listed as a weed in the
major weed references (Crockett, 1977; Holm, Pancho et al., 1979; Muenscher, 1980) (USDA
APHIS. 2009).
Although feral (free-living) populations of alfalfa are fairly common and volunteers may occur
among succeeding crops, alfalfa is not considered a serious weed, a noxious weed, or an
invasive species^' in the U.S. The Interactive Encyclopedia of North American Weeds, Version
3.0, includes alfalfa (NCWSS, 2005). But this reference does not indicate why alfalfa is
considered a weed. It may be included based on its potential occurrence as an unwanted
volunteer in agricultural settings (USDA APHIS, 2009 p. H-13).
41
A species that is not native to a particular ecosystem and whose introduction does or is likely to cause economic
damage or environmental harm or harm to human health. Executive Order 131 12 -Invasive Species (1999); USDA
National Agricultural Library, 2010.
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3.2.2 RRA and weediness
Some scientists, for example, Ellstrand (2006), have raised the question of “unintended crop
descendents from transgenic [GE] crops.” Ellstrand states (p. 116): “The possibility of
unintended reproduction by transgenic crops has raised questions about whether their
descendents might cause problems. These problems have fallen into two broad categories:
first, the direct feral descendents of the crops may prove to be new weeds or invasives, and
second, that unintended hybrids between transgenic crops and other plants could lead to certain
problems." This section discusses the weediness properties of RRA, and addresses the
concern of direct descendents of the crop that "may prove to be new weeds or invasives,"
Hybridization is addressed in several later sections.
Alfalfa does not naturally hybridize with any wild relatives in North America. Having established
that there are no related, sexually compatible wild relatives in the U.S,, movement of the CP4
EPSPS gene can only occur to cultivated or feral alfalfa populations through pollination by bees,
dropped seeds or seed admixtures.
RRA events J101/J163 were field tested in North America from 1999 to 2003 and planted
commercially after deregulation in 2005. APHIS reviewed data on characteristics that might
relate to or have an effect on increased weediness. These included seed dormancy, seed
germination, seedling emergence, seedling vigor, spring stand, spring vigor, seed yield,
vegetative growth or plant vigor, plant dormancy, growth habit, flowering properties, and effect
on symbiotic organisms (USDA APHIS, 2009). No unusual characteristics were noted that
would suggest increased weediness of J101/J163 plants relative to the control populations.
In a separate evaluation, the Canadian Food Inspection Agency (CFIA), whose responsibilities
include regulation of the introduction of animal food and plants (including crops) to Canada,
reached the same conclusion about the weediness potential of events J101/J163 compared with
non-transgenic alfalfa. In 2005, the CFIA authorized the “unconfined release into the
environment and livestock feed use of alfalfa events J101/J163’' (CFIA, 2005). In its evaluation
of events J101/J163, CFIA "determined that stand establishment, enhanced growth, vigour or
stand longevity; changes in susceptibility to plant pests and diseases common to alfalfa;
increases In forage and seed yield and increases in seed dormancy were within the normal
range of expression of these traits currently displayed by commercial alfalfa varieties” (CFIA,
2005). The CFIA reached the following conclusions (CFIA, 2005):
No competitive advantage was conferred to these plants, other than that
conferred by tolerance to glyphosate herbicide. Tolerance to Roundup®
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agricultural herbicides will not, in itself, render alfalfa weedy or invasive of natural
habitats since none of the reproductive or growth characteristics were modified.
The above considerations, together with the fact that the novel traits have no
intended effects on alfalfa weediness or invasiveness, led the CFIA to conclude
that alfalfa events J101/J163 have no altered weed or invasiveness potential
compared to currently commercialized alfalfa.
3.2.3 Impacts
Alternative 1: No Action
Under Alternative 1 , there would be no impacts from RRA on weediness properties of alfalfa or
feral alfalfa because new RRA would not be grown commercially.
Alternative 2: Partial Deregulation of RRA
APHIS has concluded that alfalfa does not exhibit weediness properties, and that RRA does not
exhibit any altered weediness properties when compared with conventional alfalfa. Therefore,
Alternative 2 would not impact the weediness characteristics of alfalfa.
Feral, non-RRA exists throughout the U.S. RRA does not exhibit any increased feral growth
potential when compared to conventional alfalfa. Therefore, Alternative 2 would not affect the
feral growth potential of alfalfa.
Under Alternative 2, RRA volunteers in crop production would be controlled by mechanical
means (e.g., tillage) or by application of one of several registered non-glyphosate herbicides.
3.3 IMPACTS OF RRA FORAGE CROPS ON CONVENTIONAL AND ORGANIC FORAGE
CROPS
This section considers the possibility of impacts from RRA forage crops on conventional and
organic forage crops through gene flow (refer to Section 2.3 for a general discussion of gene
flow), or by mixing in harvesting or transportation.
3.3.1 Pollen sources In forage production fields
As discussed in Section 2.3, alfalfa is a short-lived perennial crop plant that peaks in forage
yield during the second and third year. In the hay production fields, alfalfa is grown for its high
nutritional value for cattle and horses. The nutritional value is at its highest during the plant's
young vegetative state. As the plant approaches full flower, Its nutritional value decreases.
Therefore, alfalfa grown for hay is managed to limit growth to the juvenile state. Most alfalfa hay
in the U.S. is harvested before 10 percent of the stems have one or more open flowers. Thus,
most forage fields are cut before most plants have produced any pollen and prior to when they
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could be pollinated. This practice is widely recommended so that hay production and nutritional
quality of the hay are optimized to maximize the farmer’s economic productivity (USDA APHIS,
2009, p. 18-19, 100).
3.3.2 Potential for gene flow in forage production fields
Cross-pollination, if it occurred could potentially result in adventitious (inadvertent) production of
embryos with the GT gene in a conventional or organic hay production field. Because alfalfa
forage is typically managed for high quality and harvested before 10 percent bloom, and RRA
forage producers are concerned with high quality, there is little potential for cross-pollination
because the availability of pollen is minimized as a consequence of normal harvest activities.
Furthermore, as mentioned in Section 3.3, in all but exceptional cases, native populations of
bees are insufficient to effect economic levels of alfalfa seed pollination so they are augmented
using cultured bee colonies. Unlike seed farmers, forage producers do not stock bees to
produce the forage crop because they do not want or need pollination of their fields (USDA
APHIS, 2009, p, 94; Rogan and Fitzpatrick, 2004),"'^
Nonetheless, if cross-pollination occurs in forage fields, the inadvertently pollinated plants are
without gene flow consequence because they are almost always harvested before developing
embryos mature to become viable seed. For effective gene flow from a RRA hay field to a
conventional/organic hay field, each of the following must occur: (1) cross pollination between
RRA and conventional plants; (2) delayed harvest allowing mature seed to form in the
conventional/organic field; (3) mature RRA seed shattering and falling to the ground rather than
being removed in forage harvest; (4) successful establishment of the new RRA seedling in the
established conventional/organic alfalfa stand. Each of these requirements are unlikely and the
combination of all of them happening is remote (Putnam, 2006; Van Deynze et al., 2008). Even
in instances where weather or equipment failures delay harvesting of GT or non-RRA hay fields,
there is little risk of unwanted GT gene flow into alfalfa production (Van Deynze et al., 2008),
Alfalfa hay normally is harvested at or before first flower, 6 to 9 weeks before the ripe seed
stage (Putnam, 2006; USDA APHIS, 2009 p.100). Regardless of proximity and management of
a potential neighboring RRA hay field, a conventional/organic hay producer can eliminate any
risk of potential pollen-mitigated RRA gene flow by simply harvesting prior to ripe seed stage.
^ An exception to the foregoing are an unknown number of conventional alfalfa forage producers who Inadvertently
or by agreement allow a honeybee keeper to forage bees on the alfalfa field to produce a honey crop or brood, (See
USDA, 2009 at Appendix 0.) This would be unlikely for RRA forage producers because producers generally cut
before blooms are useful for honey production. Honeybees would be unlikely to forage on RRA forage fields because
bloom would be managed to maintain high quality forage.
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3.3.3 Potential consequences of gene flow in forage production fields
As discussed above, because alfalfa hay is harvested well before ripe seed is produced, gene
flow into or between RRA and conventional forage crops is expected to be de minimis.
3.3.4 Growing and marketing alfalfa
Dairy farmers would be the most likely users of RRA hay because they often depend on pure
alfalfa stands that are free of weeds and grasses, whereas, beef cattle producers and horse
owners typically feed their animals a mix of alfalfa-grass hay (Putnam, 2005; USDA APHIS,
2009, p. 17).
The dairy industry has widely accepted biotechnology-derived products, including recombinant
bovine somatotropin (rBST) used to increase a cow's milk production, and GT crops such as
corn, soybean, canola, and cottonseed meal used in feed. However, organic dairy producers
have rejected GT crops and require hay from organically grown (non-RRA) crops. Although
organic milk production has grown considerably, it is still less than one percent of the total U.S.
production (Miller, 2005; Putnam, 2006). Additionally, some horse owners may prefer using
non-RRA feed. However, because many horses are sickened or die from poisonous weeds in
hay, many horse owners may choose RRA. Like organic milk production, organic beef
production will require non-RRA alfalfa. However, organic beef production is less than one
percent of the total beef production industry, and the non-organic beef industry is not expected
to be sensitive to RRA (NCSA, 2005; Putnam, 2006).
Less than two percent of U.S. alfalfa hay production is exported (NAFA, 2008b). The export of
alfalfa hay is of particular economic interest in the Columbia Basin of Washington and the
Imperial Valley of California, where local exporters, supported by local hay producers, have
developed this market. Seven states in the western U.S. export approximately 4-5 percent of
their production (NAFA, 2008b). The largest importers of U.S. produced alfalfa hay are Japan,
South Korea, and Taiwan. RRA has been approved for import into these three countries, and to
Canada and Mexico, These five countries together represent over 90 percent of total U.S. hay
exports (USDA APHIS, 2009, Table 3-15, p. 55). Although there are no regulatory barriers for
the vast majority of this market, customer preference may demand testing for adventitious
presence (AP) of the RRA trait in conventional hay sold for export. Protein-based test strips and
testing protocol have been developed to test hay destined for AP sensitive markets (Woodward
et al., 2006). These low-cost testing methods have been widely adopted by the export industry
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to service the market segment requiring such tests, successfully avoiding any disruption of this
important hay industry segment. (See USDA APHIS, 2009, p. Q-19).
3.3.5 Potential for and consequences of mechanical mixing
Alfalfa has small seeds that are planted, harvested, transported and processed for sale using
large equipment designed especially for alfalfa seed crop handling. Seed growers and seed
processing companies utilize lot segregation and equipment cleaning routines to remove seeds
from equipment. Effective lot identification, segregation and equipment cleaning are practices
required for the production of certified quality seeds. Vacuums, compressed air, sweeping,
partial or complete disassembly, washing with water, etc. are effective means used to clean
planting, harvesting, transportation, seed conditioning and seed treatment/coating equipment
before or after use. These widely-adopted sanitation routines have been successful helping to
assure negligible content of off-types, weed seeds, inert and non-crop mixtures (AOSCA, 2009).
As in all other agricultural production practices, there is possibility for mixtures between seed
crops due to residual seeds in equipment, seed spillage, planting or lot blending mistakes or
other human errors, however, the potential for impact is highly managed and therefore limited.
Conventional seed crop handling practices vary widely and depend on the producer’s end
product quality targets (e.g., common seed to certified seed markets). Historically (i.e., 20-50
years ago), conventional alfalfa seed has sometimes been transported in trucks or trailers and
seed escapes along transportation routes were commonplace. In contrast, first, all RRA seed
growers are uniformly obligated under their FGI seed grower contracts to observe certified seed
standards for seed identification, segregation and handling (AOSCA, 2009). Second, RRA seed
producers are obligated to following the NAFA BMP requirements for contained transportation of
seeds, equipment sanitation, and obvious seed lot labeling, etc. (see below). FGI provides
training and the secure, labeled seed bins to each RRA grower and monitors compliance to the
contract requirements. The NAFA BMP stipulates the following sanitation, identification and
segregation requirements that must be followed for all RRA seed production:
Sanitation requirements . Manage equipment to minimize seed mixture potential
between different varieties and or variety types, Growers shall use dedicated
equipment for planting and harvesting RRA seed production, when possible.
Zero tolerance for seed admixture is not feasible under commercial production
conditions; however, grower must take reasonable steps to assure that
equipment is clean prior to and after use in the Roundup Ready seed field.
Examples: Planter inspection, clean-down before and after use; Combine
inspection, clean-down thoroughly before and after use; RRA seed bins may only
be used for RRA seed; maintain physical separation of varieties In storage;
inspect bins before use; Handle all like-trait varieties together; plan for harvest
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sequence of fields to maintain best separation of varieties by trait type; Clean all
seed handling equipment to avoid mixing RRA and conventional seed; Return
unused, unopened stock seed to the contracting seed company for credit;
maintain in clean storage areas; When a contract harvester is used for RRA seed
harvest, Growers must notify the contract harvester, in advance, that the field to
be harvested is RRA (NAFA, 2008a).
Mechanical mixtures between lots in forage harvesting are possible, but mixing is limited in
extent by the following common alfalfa forage practices (NAFA, 2008b): (1) Most hay (>75
percent) is harvested and fed on the same farm of production, therefore, growers know the type
of variety planted in each field and fields are harvested separately. Fields lots are typically
harvested separately and because each field may have a different feed quality level, the
harvests are typically placed into separate storage areas for feeding. (2) Hay is not fungible
during marketing, that is typically, each hay lot is identified, segregated and traceable to the field
of origin during transportation, brokerage and sale. This is especially the case for organically
certified crop products which must remain segregated from non-organically produced crops
throughout all handling steps. (3) Some GE-sensitive hay marketers or feed processing
facilities (meal, cubes, pellets) use commercial testing kits to test for the presence of the RRA
trait in hay, thereby, offering a post harvest means to assure RRA hay segregation from non-
RRA hay.
3.3.6 Impacts
Alternative 1 ; No Action
Under Alternative 1 , there would be no impacts to growers of organic or conventional hay
because RRA hay would not be grown commercially.
Alternative 2: Partial Deregulation of RRA
Based on the above discussions, RRA hay production under Aitemative 2 would be expected to
result in minimal impact for the following reasons;
• The reproductive biology of the alfalfa plant combined with normal harvest management
for alfalfa forage provide for a de minimis likelihood of gene flow from one forage
production field to another.
• Hay fields would be out before seed is produced.
• A combination of geographic restrictions and gene flow mitigation measures (e.g harvest
management requirements) significantly reduce the forage-to-seed gene flow interface.
Gene flow mitigation measures (MT/SA and Technology Use Guide) are contractually
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required for all RRA hay producers. These mitigation measures are practicable, contract-
enforced, science-based, and market-driven. They have been designed to enable
coexistence by mitigating all or nearly all unwanted gene flow between dissimilar crops
and to aid in protecting non-GT, export, and organic hay and seed alfalfa crops. There
have been negligible impacts since commercial seed production began in 2005 due to
the efficacy of these BMP,
• Low-cost testing procedures are readily available to meet the needs of market requiring
such tests.
• The conservative measures associated with this alternative include additional
conservative forage/hay production restrictions that will ensure an extremely low
likelihood and extent of gene flow from one production field to another.
• The biology, cultivation and marketing practices typically used in conventional alfalfa hay
production limit the potential for physical and handling mixture to very low levels. The
likelihood and extent of RRA and non-RRA mixtures are highly constrained by RRA seed
grower practices stipulated and enforced under RRA seed grower contracts.
• RRA seed bag labeling and a unique purple seed colorant will be required for all RRA
seed, which will notify RRA forage growers of the presence of the RRA trait and the
limitations for product use. The colorant and bag labeling will reduce the likelihood of
inadvertent planting by any organic or non-GE producer.
• As discussed in Section 3.8,1 , conventional and organic alfalfa seed will continue to be
available.
3.4 IMPACTS FROM RRA FORAGE CROPS ON NATIVE ALFALFA
As discussed in Section 2.6.1, no native members of the genus Medicago are found in North
America. Therefore, there would be no impacts to native alfalfa under either alternative,
because none exists.
3.4.1 Impacts
Because there are no native alfalfa populations in the U.S., there would be no impact with either
alternative.
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3.5 IMPACTS FROM RRA FORAGE CROPS ON FERAL ALFALFA POPULATIONS
The M. sativa species has naturalized populations in all 50 States (USDA APHIS, 2009, p. 23).
Synchronous flowering of hay or seed production fields neighboring feral alfalfa will likely lead to
cross-pollination. Feral alfalfa has the potential to act as a bridge for gene flow from GT alfalfa
crops to non-GT alfalfa crops. First, the RRA hay or seed production field could serve as a
pollen donor to the feral non-RRA. The subsequent feral GT offspring could then serve as the
pollen donor to the non-GT hay or seed production field. Feral alfalfa near hay and seed fields
should be controlled to avoid gene flow to the feral population (USDA APHIS, 2009, p. 101).
Feral alfalfa in roadsides, ditchbanks and pastures is commonly controlled by mowing, disking,
cultivation or the use of herbicides. Biogeographic survey data documents that, although
climate and cropping practices are favorable for seed propagation, feral alfalfa is actually less
abundant in seed producing geographies than other regions (Rogan and Fitzpatrick, 2004;
Kendrick et al., 2005). Possible explanations for this observation are that, as seed producers
follow seed certification standards requiring isolation, they routinely practice effective mitigations
to control or prevent feral alfalfa populations (mowing, herbicides, cultivation). Also, alfalfa
would not be intentionally planted in species mixtures in roadsides, pastures or rangelands
where professional seed production occurs.
The barriers to gene flow into conventional/organic hay fields described in Section 3.3 also
apply to pollen-mediated gene flow from RRA forage to feral alfalfa plants. These barriers also
apply to pollen-mediated gene flow from feral alfalfa plants to conventional or organic alfalfa
forage and will limit potential feral-to-hay gene flow to extremely low levels. Additionally, feral
alfalfa will have low seed production plus damage from lygus bug and infection from seed-borne
fungi when seed develops under damp conditions. (Putnam and Undersander, 2009 attached
as Appendix I). The primary limitations to feral-to-seed gene flow is the relative
paucity/abundance of pollen and proximity of pollinators in the field optimally managed for seed
production, compared with a low density of feral plants growing some distance away and
without the benefit of water, nutrient or pest control inputs (Van Deynze et al., 2008). A further
mitigating factor is that Certified seed production requires a minimum 165 ft isolation between
the seed production field and any feral alfalfa allowed to flower. Many seed growers have
historically produced Certified seed.
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3,5.1 Impacts
Alternative 1: No Action
Under Alternative 1 , there would be no impacts regarding feral alfalfa because no RRA hay or
seed would be produced commercially.
Alternative 2: Partial Deregulation of RRA
Based on the above discussions, Alternative 2 would be expected to result in minimal impact to
feral alfalfa for the following reasons:
• The reproductive biology of the alfalfa plant combined with normal harvest management
for alfalfa forage provide for a de minimis likelihood of gene flow from an RRA forage
production fields to feral alfalfa and from feral alfalfa to conventional or organic forage
production fields.
• The proposed limitations on the scope of allowed RRA seed production will be defined
and stringently controlled as a means to mitigate the likelihood and possible extent of
gene flow to non-RRA crops. The proposed restrictions have been designed to enable
coexistence by mitigating all or nearly all unwanted gene flow between dissimilar crops
and to aid in protecting non-GT, export, and organic hay and seed alfalfa crops. The
restrictions include but are not limited to the following: isolation distance, seed field
reporting, labeling, segregation and all other contractually required components of the
NAFA BMP. All RRA seed acres will be grown under FGI contracts that require each
field to be grown and inspected to meet State Seed Certification requirements including
the requirement to isolate the field from other alfalfa within 165 ft.; this, therefore,
includes control of feral alfalfa. These mitigation measures are practicable, contract-
enforced, science-based, and market-driven. There have been negligible impacts since
commercial seed production of RRA began in 2005 in large part due to the
demonstrated efficacy of these BMP (NAFA, 2009; Fitzpatrick and Lowry, 2010 attached
as Appendix K).
• The conservative measures associated with this alternative include additional
conservative seed production and forage/hay production restrictions that will ensure an
extremely low likelihood and extent of gene flow from one production field to feral alfalfa
from feral alfalfa to conventional or organic forage production fields.
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3.6 IMPACTS FROM RRA FORAGE CROPS TO RANGELAND ALFALFA CROPS
Commercially cultivated alfalfa and feral alfalfa populations properly belong to the M. saliva
complex, a group of closely related subspecies that are reproductively compatible. The most
commonly cultivated alfalfa in the world is M, saliva subsp. saliva, but subspecies falcata is also
cultivated on a limited basis, primarily under rangeland conditions and in colder regions (USDA
APHIS, 2009, p. 30).
Rangeland alfalfa populations might increase if certain ranchers intentionally seed alfalfa to
increase hay quality and soil nitrogen (Waggener, 2007; High Plains Midwest Ag Journal, 2008),
As has historically been the case, seed producers will remain aware of seeding practices in
neighboring rangelands, ditchbanks, pastures, roadsides, or other minimally-managed areas.
Both subspecies M. saliva subsp. saliva and M. s. subsp. faicala, have been historically used to
derive alfalfa cultivars in North America. In addition to M. s. subsp. saliva (purple flowered
alfalfa), M. s. subsp. faicala has been used as a winterhardy germplasm source by alfalfa
breeders since at least the early 1950s. Therefore, the potential for natural gene flow between
subspecies saliva and faicala is well documented and well understood (Monsanto-FGI comment
to the DEIS Appendix 1 p. 14). It is reasonable to predict that hybridization between rangeland
faicala subspecies and RRA varieties with mostly saliva parentage would occur, but they would
present no novel or unstudied risk. The limited number of acres of falcata and the barriers for
gene outflow from cultivated hay field sources (Putnam, 2006; Van Deynze et al., 2008) will limit
the likelihood and extent of effective gene flow from RRA forage production to any synchronous
alfalfa plants naturalized in the rangeland. Additionally, gene flow from a naturalized faicala x
saliva plant to neighboring conventional or organic forage or production fields would be limited
by the expected very low frequency of RRA varieties in rangeland usage and the array of gene
flow barriers described in Van Deynze et al. (2008).
3.6.1 Impacts
Altemative 1: No Action
Under Alternative 1 , there would be no impacts to rangeland alfalfa because no RRA hay or
seed would be produced commercially.
Altemative 2: Partial Deregulation of RRA
Based on the above discussions, Alternative 2 would be expected to result in minimal impact to
rangeland alfalfa for the following reasons;
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• The reproductive biology of the alfalfa plant combined with normal harvest management
for alfalfa forage provide for a de minimis likelihood of gene flow from one forage
production field to another.
• Gene flow mitigation measures (MT/SA, FGI Stewardship Program, and NAPA BMP for
RRA Seed Production) are contractually required for all RRA seed producers. These
mitigation measures are practicable, contract-enforced, science-based, and market-
driven, They have been designed to enable coexistence by mitigating all or nearly all
unwanted gene flow between dissimilar crops and to aid in protecting non-GT, export,
and organic hay and seed alfalfa crops. There have been negligible impacts since
commercial seed production began in 2005 due to the efficacy of these BMP (NAPA,
2009; Fitzpatrick and Lowry, 2010).
• Glyphosate is minimally used in rangeland situations, and therefore there would be no
selective advantage for RRA plants in the rangeland. (USDA APHIS, 2009, p. 98-99).
• The conservative measures associated with this alternative include additional
conservative seed production and forage/hay production restrictions that will ensure an
extremely low likelihood and extent of gene flow from one production field to another.
• As discussed in Section 3.8.1 , conventional and organic alfalfa seed will continue to be
available.
3.7 IMPACTS FROM RRA FORAGE CROPS TO CONVENTIONAL OR ORGANIC
ALFALFA SEED PRODUCTION AREAS
There is potential for cross-pollination due to synchronous flowering in a RRA forage crops and
adjacent non-RRA seed crops, As seed producers follow AOSCA isolation distances for seed
certification, gene flow will be minimized because gene flow decreases exponentially with
distance from crop (Van Deynze et al., 2008) (see also discussion in Section 2.3). Research
from Teuber et al. (2007) showed that hay-to-seed gene flow is low if the AOSCA certified seed
isolation distance of 165 ft from sexually compatible crops is observed. In that study, at a
distance of 165 ft, the extent of gene flow to nearby seed fields was less than 0.5 percent even
when neighboring alfalfa hay fields were harvested at 20 or 50 percent bloom. (Hay fields are
typically harvested before 10 percent bloom.) When the isolation distance from the edge of the
seed crop to neighboring alfalfa forage fields was increased to 350-600 ft, the gene flow
decreased to a mean of 0.01 percent (Van Deynze et al., 2008).
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3.7.1 Impacts
Alternative 1: No Action
Under Alternative 1 , there would be no impacts from RRA forage crops to conventional or
organic seed production crops because no RRA hay or seed would be produced commercially.
Aiternative 2: Partiai Dereguiation of RRA
Based on the above discussions, Alternative 2 would be expected to result in minima! impact
from RRA forage crops to conventional and organic seed production areas the following
reasons:
• Alfalfa forage production fields are generally cut prior to 10 percent bloom and before
seed is allowed to set.
• Gene flow mitigation measures (MT/SA and Technology Use Guide) are contractually
required for all RRA hay producers. These mitigation measures are practicable, contract-
enforced, science-based and market-driven. They have been designed to enable
coexistence by mitigating all or nearly all unwanted gene flow between dissimilar crops
and to aid in protecting non-GT, export, and organic hay and seed alfalfa crops. There
have been negligible impacts since commercial seed production began in 2005 due to
the efficacy of these BMP,
• Under Restriction Enhancement A of the proposed measures, in states where alfalfa
seed production fields were historically (2007) or are currently present, if the RRA forage
field is located within 165 ft of a commercial, conventional, seed production field, the
RRA grower must harvest forage before 10 percent bloom. This restriction is the
science- and market-based, industry recognized isolation distance for certified alfalfa
seed crops, and the potential and extent of gene flow of 10 percent bloom hay to nearby
seed crops is de minimis at a distance of 165 ft (Teuber and Fitzpatrick, 2007; Van
Deynze et al., 2008).
• Additionally, in states where there is more than 100,000 lbs. of annual alfalfa seed
production, additional restrictions apply by county to further reduce the potential for gene
flow. In counties without seed production, RRA forage growers must report the GPS
location of all RRA fields. Under Restriction Enhancement C, in counties with seed
production, no new RRA forage plantings are allowed.
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• As discussed in Section 3.8.1, conventional and organic alfalfa seed \will continue to be
available.
3.8 IMPACTS FROM RRA SEED PRODUCTION
3.8.1 Cross-pollination
The greatest potential for cross-pollination and mixing among crop species occurs in seed
production because that is where pollination is intended to, and does, occur (see description in
Section 2.1.2). The relationships between isolation distance, pollinator species and pollen-
mediated gene flow in alfalfa seed production has been studied extensively (Van Deynze et at,
2008). This science informed the current industry standards for isolation in NAFA Best
Practices for RRA Seed Production (wvw.alfalfa.org) and was validated in 2008 and 2009 in
large scale surveys of adventitious presence of the RRA trait in conventional seed (Fitzpatrick
and Lowry, 2010). Physical mixing of seeds can occur during harvesting, seed cleaning,
packaging, and transport. These activities are also governed by NAFA Best Practices for RRA
Seed Production, and are components of adventitious presence evaluated in the annual third
party audit/validation conducted on commercial seed lots.
The production of non-RRA alfalfa seed and forage both rely on continued availability of non-
RRA parent seed, with non-detectable levels of the RRA trait. There is a clear consensus in the
industry that there will always be a market (domestic and international) for non-RRA varieties
developed and produced in the U.S. There is no reason to believe that industry and/or
university alfalfa breeders will not continue to develop varieties for these markets. The
production of Breeder seed generation (Synl) alfalfa seedstock is often done in a screen cage
to exclude incoming pollinators, so there should be no new incremental effort required to avoid
low level gene flow from neighboring RRA seed or hay production. The production of
Foundation (Syn2) alfalfa seedstock requires adherence to AOSCA standards, which include
extraordinary isolation from all neighboring alfalfa (seed, hay or uncultivated sources). The
standard Foundation seed required isolation of 900 ft is often sufficient to eliminate gene flow
from neighboring RRA alfalfa seed or hay production, but occasionally very low levels of
adventitious presence are found. When a non-detect standard for Foundation seed is adopted
by the breeder, use of an additional isolation distance would decrease the risk of low level gene
flow. As a general practice of stringent quality control. Breeder and Foundation seed is routinely
evaluated for trueness-to-type, including a lack of off-types. In the event of a low incidence of an
off-type, such as presence of the RRA trait in conventional alfalfa, breeders routinely cull the off-
type plants and repeat the variety seed increase (APHIS, 2009, Appendix V). Adherence to
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AOSCA standards for certified seed production and attention to detail in quality control of
seedstocks has been a successful strategy for high quality U.S. seed production by American
seed companies (Monsanto/FGI Comments to draft EIS at p, 6-7). Additionally, in cooperation
with several U.S. alfalfa seed companies, AOSCA (2010) has developed a new seed production
protocol for the production of alfalfa seed. The new protocol is tailored to meet the needs of
seeds destined for export, organic and other sensitive market channels where biotechnology
traits are expressly excluded. Meeting the specific and incremental requirements of this
"speciar AOSCA certification program allows the seed producer to label the seed with a
statement certifying adherence to the AOSCA program (Monsanto/FGI Comments to draft EIS
at p. 5; NAFA, 2008b; NAFA, 2008c; NAFA. 2008d).
3.8.2 Seed Mixing
The biology, cultivation and marketing practices typically used in conventional alfalfa seed and
hay production limit the potential for physical and or handling mixtures to very low levels. The
likelihood and extent of RRA and non-RRA mixtures are negligible and highly constrained by
RRA seed grower practices stipulated and enforced under RRA seed grower contracts. Organic
or other GE sensitive hay producers will opt to plant non-GE seeds and will follow their routines
for maintaining segregation between hay lots. The impacts to non-RRA markets are expected
to be negligible, especially because all RRA seed and hay growers must manage their crop
according to their obligations under contracts, licensing, seed certification standards and or
segregation standards for organic crops.
RRA is compositionally similar to seed and forage from conventional alfalfa. Therefore, from a
food and or feed safety perspective, the impact of mixtures between RRA and non-RRA seeds
or forage is negligible. However, as discussed elsewhere in this document (Sections 3.3.4,
3.3.5, 3.15 and 4.10) and extensively throughout the DEIS (USDA APHIS, 2009), there is a
segment of consumers and markets that due to their rejection of GE crops or traces thereof,
may experience socio-economic concerns and nominal (and voluntary) GE mitigation/avoidence
costs (e.g., testing costs).
3.8.3 Impacts
Alternative 1: No Action
Under Alternative 1 , there would be no impact from RRA seed production on organic or
conventional alfalfa seed production because no RRA hay or seed would be produced
commercially.
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Alternative 2: Partial Deregulation ofRRA
Under the partial deregulation alternative, there would be no or negligible impacts to growers of
organic or conventional alfalfa seed for the following reasons:
• Gene flow mitigation measures (FGI Stewardship Program, and NAFA BMP for RRA
Seed Production) are contractually required for all RRA seed producers. The isolation
distances and other mitigation measures required by the NAFA BMP are practicable,
contract-enforced, science-based and market-driven. They have been designed to
enable coexistence by mitigating all or nearly all unwanted gene flow between dissimilar
crops and to aid in protecting non-GT, export, and organic hay and seed alfalfa crops.
There have been negligible impacts since commercial seed production began in 2005
due to the efficacy of these BMP. The eight RRA seed grower consortia authorized to
plant under partial deregulation would meet or exceed the NAFA BMP parameters with
enhanced additional isolation requirements. The minimum required isolation from
conventional, commercial seed fields will be 4 miles and 1 mile when honeybees or
leafcutter bees are the managed pollinating species, respectively. The potential for gene
flow at the NAFA BMP isolation is de minimis (Van Deynze et al., 2008), and the
proposed increase to the isolation requirement would further ensure de minimis gene
flow potential from RRA seed fields to conventional seed crops should they be present.
• The biology, cultivation and marketing practices typically used in conventional alfalfa
seed production limit the potential for physical and handling mixture to very low levels.
The likelihood and extent of RRA and non-RRA mixtures are highly constrained by RRA
seed grower practices stipulated and enforced under RRA seed grower contracts.
• Conventional and organic alfalfa seed will continue to be readily available to growers,
3.9 LIVESTOCK PRODUCTION SYSTEMS
RRA alfalfa will be used in livestock production systems as feed for livestock. Therefore, its
only potential impacts to livestock production systems would be related to animal feed, which is
discussed In Section 3.10.
3.10 FOOD AND FEED
Both food (sprouts, dietary supplements, and herbal or homeopathic medicine) and animal feed
(hay, haylage, or silage) are derived from alfalfa. In this section we summarize the large body
of scientific evidence that has been developed that supports the conclusion that food and feed
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derived from RRA are as safe and healthy as food and feed derived from conventional alfalfa.
While the evidence has largely been developed by Monsanto and/or FGI, it has been evaluated
and peer reviewed by FDA and by panels of government scientists from Canada, Japan,
Australia, New Zealand, Mexico, Korea, and the Philippines, all of whom have approved, or
recommended for approval, the use of products from RRA In their countries.
We begin with a summary of FDA’s authority and policy under the FFDCA with regard to
ensuring the safety of food and feed derived from genetic engineering, documenting each
element FDA evaluated in its consultation process. We then summarize the evaluations and
conclusions of several other international scientific oversight groups.
3.10.1 FDA authority and policy
FDA policy statement. In 1992, the FDA issued a policy statement clarifying its interpretation
of the FFDCA regarding foods (including animal feed) derived from new plant varieties,
including plants developed by genetic engineering. The purpose of the policy is "to ensure that
relevant scientific, safety, and regulatory issues are resolved prior to the introduction of such
products into the marketplace" (FDA, 1992). FDA is the “primary federal agency responsible for
ensuring the safely of commercial food and food additives, except meat and poultry products”
and “FDA has ample authority under the FFDCA safety provisions to regulate and ensure the
safety of foods derived from new plant varieties, including plants developed by new techniques.
This includes authority to require, where necessary, a premarket safety review by FDA prior to
marketing of the food” (FDA, 1992). Under section 402(a)(1) of the FFDCA, a food is
adulterated and thus unlawful “if it bears or contains an added poisonous or deleterious
substance that may render the food injurious to health or a naturally occurring substance that is
ordinarily injurious” (FDA, 1992).
FDA has the authority to ensure safety of new foods. FDA considers its existing statutory
authority under the FFDCA and its implementing regulations "to be fully adequate to ensure the
safety of new food ingredients and foods derived from new varieties of plants, regardless of the
process by which such foods and ingredients are produced" (FDA, 1992). “The existing tools
provide this assurance because they impose a clear legal duty on producers to assure the
safety of foods they offer to consumers; this legal duty is backed up by strong enforcement
powers; and FDA has authority to require premarket review and approval in cases where such
review is required to protect public health" (FDA, 1992).
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Developers have the responsibility to evaluate the safety of new foods. “It is the
responsibility of the producer of a new food to evaluate the safety of the food and assure that
the safety requirement of section 402(a)(1) of the act is met, FDA provides guidance to the
industry regarding prudent, scientific approaches to evaluating the safety of foods derived from
new plant varieties, including the safety of the added substances that are subject to section
402(a)(1) of the act. FDA encourages informal consultation between producers and FDA
scientists to ensure that safety concerns are resolved" (FDA, 1992).
Foods developed by new methods do not present greater safety concerns. “FDA believes
that the new techniques are extensions at the molecular level of traditional methods and will be
used to achieve the same goals as pursued with traditional plant breeding. The agency is not
aware of any information showing that foods derived by these new methods differ from other
foods in any meaningful or uniform way, or that, as a class, foods developed by the new
techniques present any different or greater safety concern than foods developed by traditional
plant breeding” (FDA, 1992).
FDA’s goal is to ensure the safety of all food and feed. “The goal of the FDA’s evaluation of
information on new plant varieties provided by developers during the consultation process is to
ensure that human food and animal feed safety issues or other regulatory issues (e.g. labeling)
are resolved prior to commercial distribution” (FDA, 1997).
3.10.2 FDA biotechnology consultation note to the file BNF 000084
FDA makes the contents of its biotechnology notification files (BNFs) available on the internet
(see reference FDA, 2004; RRA is BNF 000084). FDA documented its RRA consultation with
Monsanto/FGI in a note to the file dated December 8, 2004 (FDA, 2004). That information is
summarized below.
Characterization, inheritance, and stability of the Introduced DNA
Using standard analytical techniques, Monsanto/FGI verified that events J101/J163 contained a
single copy of the CP4 EPSPS cassette, and that all components were intact (FDA, 2004;
Rogan and Fitzpatrick, 2004).
Monsanto/FGI conducted crosses using conventional breeding techniques. These studies
indicate that the introduced trait (glyphosate tolerance) was stably inherited as a dominant trait
(FDA, 2004; Rogan and Fitzpatrick, 2004).
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Using standard analytical techniques, Monsanto/FGI demonstrated the stable integration of the
T-DNA over five generations (Rogan and Fitzpatrick, 2004).
Introduced substance - CP4 EPSPS enzyme
As discussed in Section 3.1.1, EPSPS is a catalyst for a reaction necessary for the production
of certain aromatic amino acids essential for plant growth and has a similar function in bacteria
and fungi (for example, baker’s yeast). While EPSPS is present in plants, bacteria and fungi, it
is not present in animals; animals do not make their own aromatic amino acids, but rather obtain
them from the foods they consume. Thus, EPSPS is normally present in food and feeds derived
from plant and microbial sources (Harrison et al., 1996). There are variations in the genetic
makeup (amino acid sequences) of EPSPS among different plants and bacteria. The EPSPS
used in Agrobacterium sp. strain CP4 is just one variant of EPSPS. A unique characteristic of
CP4 EPSPS is that, unlike EPSPS commonly found in plants, it retains its catalytic activity in the
presence of glyphosate (FDA, 2004; Rogan and Fitzpatrick, 2004).
Concentrations in alfalfa. CP4 EPSPS protein levels in sample extracts were measured using
standard methods, with the resulting average concentration of approximately 0.02 to 0.03
percent (192 to 317 parts per million) (Rogan and Fitzpatrick, 2004).
Toxicity of CP4 EPSPS. The FDA concluded that “the CP4 EPSPS protein produced by RRA
lines J101/J163 was biochemically and functionally equivalent to CP4 EPSPSs produced by
other RR crops, and to the family of EPSPS proteins that naturally occur in crops and
microbiologically-based processing agents that have a long history of safe consumption by
humans and animals” (Hendrickson and Price. 2004). This similarity of the CP4 EPSPS protein
to EPSPS's in a variety of foods supports the lack of health concerns and extensive human and
animal consumption of the family of EPSPS proteins (Rogan and Fitzpatrick, 2004).
Studies were conducted on mice, using CP4 EPSPS doses of 400, 100, and 40 milligrams (mg)
of CP4 EPSPS per kilogram (kg) of body weight per day (mg/kg body wt -d). For a typical 0.03-
kg mouse, the 400 mg/kg body wt -d dose equated to 12 mg per mouse per day. The study
was designed to reflect a 1 ,000-fold factor of safety on the highest possible human exposure to
CP4 EPSPS, based on assumed exposures to soybean, potato, tomato, and corn at the time
the study was done (Harrison et al., 1996). The daily CP4 EPSPS content in the maximum
mouse exposure was equivalent to the amount in approximately 160 pounds of RRA. No
treatment-related adverse effects were observed, and there were no significant difference in any
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measured endpoints between the CP4 EPSPS treated mice and the control group (Harrison et
al.. 1996, p. 735).
Monsanto/FGI also compared the amino acid sequence of CP4 EPSPS to protein sequences in
the public domain ALLPEPTIDES database using the PASTA algorithm, and reported no
biologically relevant sequence similarities between CP4 EPSPS protein and known toxins were
observed (Bonnette, 2004). A peptide is a molecule consisting of several linked amino acids
(GMO Safety, 2010a).
Allergenicity. Allergens can be derived from many sources: in animal hair, pollen, insect bites,
dust mites, plants, pharmaceuticals, and food. Approximately 20,000 allergens have been
identified. Most allergens in food are high molecular weight proteins and are rather resistant to
gastric acid and digestive enzymes (GMO Safety, 2010a).
Monsanto searched a comprehensive database of allergens (Hileman et a!., 2002) containing
sequences of known allergens, for amino acid homology to the CP4 EPSPS protein, and
concluded that there was no immunologically significant amino acid sequence homology
between the CP4 EPSPS protein and amino acid sequences of allergens in the database
(Bonnette, 2004).
At least two studies have been conducted on the mammalian digestibility of CP4 EPSPS. In the
first study, the CP4 EPSPS protein was exposed to simulated gastric (stomach) and intestinal
fluids that were prepared according to the U.S. Pharmacopoeia (1 990). The half-life of the CP4
EPSPS protein was reported to be less than 15 seconds in the gastric fluid, greatly minimizing
any potential for the protein to be absorbed in the intestine. The half-life was less than ten
minutes in the intestinal fluid (Harrison et al., 1996, p 738). The second study reported similar
results (Bonnette, 2004). Specifically, FDA (2004) noted the following from the Monsanto/FGI
submmittal: the soil bacterium used to create RRA is not a known allergen or pathogen (does
not cause allergic reactions or diseases); the CP4 EPSPS gene and protein lack structural
similarities to any allergen (it does not have the same structure as anything that causes allergic
reactions).
Food and feed uses of alfalfa
Alfalfa has a long history as a feed source for animals. Greater than 95 percent of alfalfa is used
as animal feed.
Human food uses of alfalfa are minor and it is consumed as compressed leaf material for dietary
supplements and herbal teas or as fresh sprouts. The seeds germinated for sprouts are
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produced and marketed in a distinct, food-grade channel from those for field (non-food)
purposes (Section 2,7). A small fraction of alfalfa seeds are used to produce sprouts for human
consumption. Any alfalfa seed for sprouts must be certified as having been produced to food-
grade specifications and therefore food-grade seed is grown and distributed in an entirely
separate channel from that for general use, non-food-grade planting seeds. Food-grade seeds
for sprouts are produced throughout the world, but the major suppliers are Canada, Italy, U.S.
and Australia. Sprouts are cultivated from clean raw (non-coated, untreated) seeds in controlled
environment sprouting chambers for approximately 5 to 10 days before sale to consumers.
FDA and equivalent regulatory bodies in Japan, Korea, Canada, Australia/New Zealand, etc.,
have granted full approval for the use of RRA as a food (see Section 3. 1 1 ). Monsanto and FGi
have developed the RRA varieties for field planting purposes (only), and as such the companies
do not intend nor allow (give license to) any seed growers or seed purchasers to use RRA
varieties for food-grade sprout production (Hubbard, 2008; USDA APHIS, 2009, p. 18). The FGI
mandated purple seed coating for all commercial RRA seed helps mitigate unintended use of
RRA seed for sprouts.
Alfalfa is the principal forage for cattle and horses because of its high nutritional content. The
nutritional content of alfalfa is highest in young vegetative alfalfa plants and decreases as plants
approach full flower. Dairy cows are generally fed the highest quality alfalfa hay (vegetative to
bud stage). Beef cattle, horses, heifers, and non-lactating dairy cows are fed hay that is higher
in fiber and lower in protein. Forms of storage include hay, haylage, and silage. Grazing Is
sometimes used as an alternative to harvesting alfalfa. However, grazing presents a risk of
animal loss due to bloating and difficulties in alfalfa stand maintenance if grazing is continuous
(Rogan and Fitzpatrick, 2004).
Honey bee hives commonly use alfalfa and clover as nectar sources. Therefore, managed and
wild bee hives are often associated with alfalfa fields (FDA, 2004; USDA, 2009 draft EIS
Appendix O),
Compositional analysis
To assess whether alfalfa events J101/J163 are as safe and nutritious as conventional alfalfa
varieties, the composition of forage produced by Roundup Ready alfalfa plants containing either
event J101, J163, or the paired events J101 X J163 was measured and compared to the
composition of control and conventional alfalfa forage. This study was conducted under USDA
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Notification Number 01 -029-1 2n. Forage was harvested from plants grown in field trials and
analyzed using standard methods or other suitable methods (Monsanto, 2004).
Forage samples were collected from all plots and analyzed for 35 different nutritional
components. Compositional analyses of the forage samples included proximates (protein, fat,
ash and moisture), acid detergent fiber (ADF), neutral detergent fiber (NDF), lignin, amino acids,
and minerals (calcium, copper, iron, magnesium, manganese, phosphorous, potassium, sodium
and zinc), as well as carbohydrates by calculation. In all, 35 different components were
analyzed to assess the composition of Roundup Ready alfalfa (Rogan and Fitzpatrick, 2004).
Statistical analyses were performed on the compositional data for the RRA containing events
J101/J163. As expected, statistically significant differences were observed for the concentration
of some of the analytes in comparison to the control. Where values were different, the mean
was within the 99 percent tolerance interval developed for the analyte using conventional alfalfa
reference varieties. Therefore, it is unlikely that these differences are biologically meaningful.
These data are consistent with the conclusion that forage produced by alfalfa plants containing
event J101 or J163 is comparable to forage produced by control or conventional alfalfa
varieties. These compositional data support the conclusions derived from other phenotypic
studies indicating that no biologically meaningful changes were associated with alfalfa
populations containing event J101 or event J163 (Monsanto, 2004).
Conclusion
Based on the data submitted, the FDA considered the consultation process to be complete and
acknowledged this in Biotechnology Consultation Note to the File BNF No. 000084 (FDA. 2004).
3.10.3 Health Canada approval 2005
Health Canada's Food Directorate has legislated responsibility for premarket assessment of
“novel foods.” Under Canadian regulations, foods derived from alfalfa lines containing events
J101/J163 are considered novel foods because they are derived from a plant that has been GM
to exhibit characteristics that were not previously observed in the plant (Health Canada, 2005).
Health Canada conducted a comprehensive assessment of GT alfalfa lines containing events
J101/J163 according to its “Guidelines for the Safety Assessment of Novel Foods," reviewing
the same information Monsanto/FGI provided to FDA in its consultation, and made the following
conclusion (Health Canada, 2005):
“Health Canada’s review of the information presented in support of the food use
of glyphosate tolerant alfalfa lines containing events J101/Jie3 concluded that
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the food use of alfalfa lines containing this event does not raise concerns related
to safety. Health Canada is of the opinion that alfalfa lines containing events
J101/J163 are as safe and nutritious as current commercial alfalfa varieties.”
3.10.4 CFIA approval 2005
The CFIA evaluated GT alfalfa events J101/J163 for use as livestock feed and approved their
use in 2005. Based on its evaluation of data provided by Monsanto/FGI, and as summarized in
its Decision Document DD2005-53, the CFIA “determined that these plants with a novel trait
(PNT) do not present altered environmental risk nor, as a novel feed, do they present livestock
feed safety concerns when compared to currently commercialized alfalfa varieties in Canada"
(CFIA, 2005).
3.10.5 Japan approval
Japan approved the food use RRA in 2005 and the feed use in 2006. Environmental approval
was also granted in Japan in 2006 (Japan Biosafety Clearinghouse, 2010; Center for
Environmental Risk Assessment, 2010).
3.10.6 Australia - New Zealand approval
Food Standards Australia New Zealand (FSANZ) is a bi-national government agency with
responsibility to develop and administer the Australia New Zealand Food Standards Code.
FSANZ approved the food use of RRA in 2006 (FSANZ, 2006). FSANZ found “no public health
and safety concerns. On the basis of the available evidence, including detailed studies provided
by the Applicant, food derived from GT lucerne J101/J163 is considered as safe and wholesome
as food derived from other commercial lucerne varieties.” (FSANZ, 2006, p. ii).
3.10.7 Other approvals
RRA was also approved for use as food and/or feed in Mexico in 2005 (Ministry of Health), in
the Philippines in 2006 (Department of Agriculture Bureau of Plant Industry), and in Korea in
October 2007 (Center for Environmental Risk Assessment, 2010). Environmental approval was
granted in Korea in January 2008 (Rural Development Administration).
3.10.8 Impacts
Alternative 1: No Action
Under Alternative 1 , there would be no impact from RRA on feed or food, or on consumer
choice.
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Alternative 2: Partial Deregulation of RRA
Health effects of consumption of RRA. Alfalfa is consumed as both animal feed
(hay/hayiage) and human food (e.g., alfalfa sprouts). Based on the scientific evidence
summarized in this section, health impacts from consuming RRA food or feed are not expected
from RRA. Feed derived from RRA is equivalent to feed derived from conventional alfalfa.
Although RRA has been found to be equivalent to conventional alfalfa by several international
scientific agencies, Monsanto/FGl have determined that RRA will not be licensed for use for any
human food purposes.
Health and consumer choice effects of consumption of food or feed derived from RRA.
Beef and dairy products may be derived from cattle/cows that have consumed RRA. The Food
and Agricultural Organization of the United Nations (FAO), the World Health Organization
(WHO), and the Organization for Economic Cooperation and Development (OECD) have made
statements regarding the potential for the protein encoded by the transgene (the CP4 EPSPS
protein) to transfer to animal-derived products intended for human consumption (FAO/WHO
1991; FDA 1992; OECD 2003). These reports, as well as the studies summarized above in this
section have concluded that the CP4 EPSPS protein is equivalent to other forms of the EPSPS
protein, and that food and feed containing the CP4 EPSPS protein is as safe and nutritious as
the conventional counterparts. As discussed in Section 3,10.1, the half-life of the CP4 EPSPS
protein in the digestive system is only a few minutes; no detectable amounts of the CP4 EPSPS
protein are expected to be found in beef or dairy products from animals fed RR alfalfa. Although
uncommon, fragments of transgenes have been found in dairy and animal products
(Flachowsky and others, 2005). If very low levels of transgenic fragments could be infrequently
found in dairy products and beef from cattle/cows consuming RRA, presumably they would also
be present in the same products, from the use of corn as cattle feed, as most corn grown in the
U.S. is genetically engineered. Honey from bees is mostly fructose and glucose; however,
possibly it could have minute fragments of transgenic DNA from pollen from RRA. The
presence of DNA fragments, GE or otherwise, is not a health issue (on the safety of DNA (FDA,
1992); however, depending on how “non-GE food" is defined, it could affect a consumer’s
choice to consume non-GE food. The minute levels that might potentially be found in honey,
beef or dairy products would, for example, be far below the threshold standards for non-GE food
proposed by the Non-GMO Project (Section 1 .5). A consumer with “zero tolerance” for beef or
dairy derived from GE products or that might contain minute fragments of transgenes would
have the choice of consuming organic honey, beef and dairy products. Presumably that
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consumer would already be consuming organic beef and dairy products because of the use of
GE corn as cattle feed. Market demand will ensure that conventional and organic alfalfa will still
be available to the dairy or cattle farmer who wishes to avoid RRA.
Summary. Based on the above analysis, Alternative 2 would be expected to have no or
negligible impacts on food or feed, or consumer choices regarding food or feed.
3.1 1 WEED CONTROL AND GR
3.11.1 Weed control with conventional alfalfa
Weed management is an important aspect of alfalfa production. Some of the negative effects of
weeds in alfalfa crops include the following:
• competition with weeds can reduce yield and cause thinning in the stand;
• weeds can lower the nutritional quality of alfalfa hay because many weeds are lower in
protein (50 percent less protein than alfalfa) and higher in fiber compared to alfalfa;
• poisonous weeds containing toxic alkaloids (a type of chemical) (e.g., common
groundsel, fiddleneck, yellow starthistle, and poison hemlock) can make alfalfa hay
unmarketable;
• under some conditions weeds can accumulate toxic nitrate concentrations (e,g„
lambsquarters, kochia, and pigweed);
• some weeds with a spiny texture can cause mouth and throat ulcerations in livestock
(e.g., foxtail, wild barley, cheatgrass, and bristlegrass);
• weeds that are unpalatable to livestock result in less feeding and, therefore, less
productivity (of either beef or milk);
• some weeds can contribute to off flavors in milk (e.g., wild celery, Mexican tea, creeping
swinegrass, and mustards); and
• weeds that contain higher moisture content than alfalfa (e.g., dandelion) can cause bale
problems such as mold, off-color hay, and high bale temperatures, which are a fire
hazard.
(Canevari et al., 2007; Canevari et al., 2006; Van Deynze et al., 2004; Loux et al., 2007; Miller
et al., 2006; Orloff et al., 1997; Orloff et al„ 2009, attached as Appendix D; USDA APHIS, 2009
pp. 105-06),
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Without weeds, alfalfa can grow at a density of about 12 plants per square foot. Heavily weed-
infested stands can have less than one alfalfa plant per square foot (Canevari et al., 2007). In
California, if weeds are not effectively controlled, they can represent up to 76 percent of the first
cutting yields (USDA APHIS, 2009, p. 106).
3.1 1 .2 Weed control with RRA
The following discussion of RRA and weed management was based largely on the technical
report, Effects of Glyphosate-Resistant Weeds in Agricultural Systems (USDA APHIS 2009,
Appendix G, attached as Appendix E of this ER).
RRA can be used by farmers for weed management in alfalfa crops. Its unique characteristics
allow for effective weed control throughout the growing season of an alfalfa crop, and, alfalfa
and alfalfa farming practices per se have characteristics that will complement the weed control
provided by glyphosate and, as such, will aid in the suppression of the development of GR
weeds. The ability for alfalfa to fix nitrogen encourages the decision to follow alfalfa in the
rotation with a crop that requires additional nitrogen, such as the annual grasses of corn and
various cereal crops. These subsequently rotated crops can tolerate a spectrum of herbicides
substantially different from the herbicides used in alfalfa. This encourages rotation of crops and
herbicides, both of which are highly recommended for reducing the probability of developing
herbicide resistant weeds (Orloff et al., 2009; USDA APHIS, 2009, p. 109),
Alfalfa produced for forage purposes (e.g., hay and silage in GE, conventional, or organic
production systems) is mowed regularly at a recommended cutting height of 3 inches. This
removes all plant material higher than 3 inches including weeds (Orloff et al., 1997), which may
not have had time to produce flowers, pollen or seed. This regular removal of all plant mass
above 3 in. of the soil surface, including all vegetative weed material, greatly suppresses or
eliminates seed production in weed species, and Is especially effective in controlling annual
weeds (USDA APHIS, 2009, p. 109).
In a RRA farming system for forage, the combination of broad spectrum weed control from
glyphosate (which should lead to more vigorous alfalfa competition), and regular mowing, which
reduces the likelihood that any GR weeds in the RRA field have had time to produce pollen or
set seed, greatly decreases the probability of the development of GR weeds. In some parts of
the western U.S., alfalfa produced with irrigation requires multiple herbicide applications to
control repeated influx of weed seed introduced with irrigation water. In most oases the use of
one or more non-glyphosate herbicides with increased residual activity will be required to
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provide effective weed control (Orloff et al., 2009, attached as Appendix D). In seed production,
although an early spring or late fall mowing sometimes occurs, in-season mowing only occurs
once, as one seed crop is removed each year; thus, there is a potential for greater weed seed
production compared to alfalfa forage production. However, in order to maximize yield for a
seed crop and minimize weed seed content, alfalfa seed production (including RRA seed
production) currently receives significantly higher cultural and herbicide inputs (beyond
glyphosate only) to reduce weed cover than in alfalfa forage production. Glyphosate can only be
applied in alfalfa seed production when plants are in the vegetative state. Other herbicides will
be used to control weeds during the longest part of the growing season. These additional
herbicides with other modes of action will also work to reduce weed seed production and
minimize glyphosate-resistant weeds in the seedbank of fields where RRA is grown for seed
(USDA APHIS, 2009, p. 109).
3.11.3 Herbicide-resistant weeds
A number of genetic, biological/ecological, and operational factors are involved in determining if
a weed species will evolve a resistance to any herbicide (Georghiou and Taylor, 1986; Neve,
2008). Genetic factors include the frequency of genes in a weed species that promotes
resistance to a particular herbicide, the ability and rate of changes to genes to cause resistance,
the way genes for resistance are passed down to offspring, and the fitness of the plant (and
these genes) in the presence and absence of an herbicide. Biological and ecological factors
include how the weed species reproduces (selfing or outcrossing), seed production capacity,
seed bank turnover, and amount of gene flow within and between populations (Maxwell and
Mortimer, 1994; Jasieniuk et al., 1996; Neve, 2008). The genetic factors and
biological/ecotogical factors involved highlight that different species may present different risks
of resistance, depending on the genetics of the weed and the biology of the plant. Operational
factors involved in the evolution of weed resistance include the type of chemistry and how the
herbicide kills plants (e.g. mode-of-action), the frequency with which the herbicide is applied,
and the dose and pattern of herbicide application.
Alfalfa weed management, including major weeds in alfalfa, herbicides used, herbicide mode of
action, and herbicide resistance, was discussed in Sections 2.5. Measures to reduce herbicide
resistance were also discussed in Section 2,5.
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3.11.4 GR weeds
As discussed in Section 2, herbicide resistance is not a unique or new phenomenon. The
development of weeds resistant to a particular herbicide mode of action is an issue that growers
have faced for decades. As with other herbicide modes of action, not alt weeds respond the
same to glyphosate, and some species naturally vary in their tolerance to the herbicide.
Because of the nature of glyphosate and its history of use, generally speaking, there is a
reduced potential that there will be a selection for weed resistance, compared to other
herbicides. Glyphosate is a nonselective, foliar-applied, broad spectrum, post-emergent
herbicide compared to many other herbicide groups. It operates by binding to a specific
enzyme in plants thereby interfering with the plant’s required metabolic process. Glyphosate is
the only herbicide that binds with this enzyme, and therefore it is highly specific (Cole, 2010, p.
5; Orloff, 2009, p. 6, attached as Appendix D).
Accordingly, while glyphosate has been used extensively for over three decades, there have
been relatively few cases of resistance development, as compared to many other herbicides
and when considering the substantial glyphosate-treated acreage worldwide (approximately 1
billion acres) and the total number of weeds that the herbicide can control. In the U.S., there
are ten weed species where GR biotypes are known to exist in certain areas of the country (19
weeds have been reported to have developed GR at some location worldwide). These resistant
weeds represent a relatively small minority of the overall weed population. For example, in
2009, approximately 135 million of the 173 acres of corn, soybeans and cotton in the U.S. were
planted with a herbicide tolerant variety, with the most common tolerance trait being glyphosate
tolerance (USDA NASS, 2009a). At the same time, only about 6 percent of the total planted
corn, soybean and cotton acres in the U.S. are estimated to have some level of presence of
weeds resistant to glyphosate (Ian Heap as reported by WSSA, 2010b). As discussed above,
the characteristics of glyphosate itself reduce the potential for the development of herbicide
resistance as compared to other herbicide families. As such, certain herbicide families have
been classified according to their risk of resistant weed development. Beckie (2006) lists ALS
and ACCase inhibiting herbicides as “High" risk for resistance development, while glyphosate is
considered a “Low” risk herbicide for the development of herbicide resistant weeds. ALS and
ACCase inhibiting herbicides are commonly used in conventional alfalfa production, and weeds
resistant to these two herbicide groups are widely distributed across alfalfa growing regions of
the U.S. RRA can help delay resistance to these herbicides by adding to the diversity of
herbicide modes of action in alfalfa production.
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Use of herbicides with different modes of action, either concurrently or sequentially, is an
important defense against weed resistance (WSSA, 2010b). “Use of a single product or mode
of action for weed management is not sustainable. Some of the best and most sustainable
approaches to prevent resistance include diversified weed management practices, rotation of
modes of action and especially the use of multiple product ingredients with differing modes of
action” (WSSA, 2010b). in addition, cultural practices such as cultivation or mowing are
effective weed resistance management operations.
The WSSA reports higher levels of awareness among growers regarding the need to minimize
the potential for development of GR: “In a market research study that surveyed 350 growers in
2005 and again in 2009, in response to the question, ‘are you doing anything to proactively
minimize the potential for resistance to glyphosate to develop,' 67 percent said yes in 2005 and
87 percent said yes in 2009" (David Shaw, as reported in WSSA, 2010). “in a 2007 survey of
400 corn, soybean and cotton growers, resistance management programs were often or always
used by 70 percent or more of all three grower groups” (Frisvold and Hurley as reported by
WSSA, 2010b). There is widespread information available from universities and other sources
regarding GR. Public universities (i.e. University of California, North Dakota State University,
University of Minnesota), herbicide manufacturers (i.e. www.weedresistancemanagement.com,
www.resistancefighter.com) and crop commodity groups (i.e. National Corn Growers
Association, American Soybean Association) have internet web sites with information on
prevention and management of herbicide resistance, Monsanto’s TUG (attached to this
document as Appendix A) provides specific management practices for the prevention of
glyphosate resistant weeds. Additionally, the UC’s Integrated Pest Management website
( http://www.ipm.ucdavis.edu/PGM/weeds common.html) and at the UC Weed Research and
Information Website ( http://wric.ucdavis.edu/information/information.htmll provide information on
weed identification and specific weed management practices (Orloff et al., 2009; attached as
Appendix D).
Alfalfa growers have strong financial and practical interests in managing weeds effectively and
preemptively to reduce the development of herbicide resistance in order to maximize yield
potential. The development of GR weeds harms the economic return per acre for the individual
farmer and the entire alfalfa industry (Orloff et al., 2009, attached as Appendix D).
As such, strategies and recommendations to delay the development of GR weeds have been
developed for alfalfa (Orloff et al., 2009, attached as Appendix D; TUG, attached as Appendix
A). In general, weed scientists recommend the following to mitigate the risk of herbicide
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resistance in alfalfa: (1) Apply integrated weed management practices. Use multiple herbicide
modes-of-action with overlapping weed spectrums in rotation, sequences, or mixtures; (2) Use
full recommended rate and proper application timing for the hardest to control weed species
present in the field; (3) Scout fields after herbicide application to ensure control has been
achieved; (4) Avoid allowing weeds to reproduce by seed or to proliferate vegetatively; (5)
Monitor site and clean equipment between sites; (6) Start with a clean field and control weeds
early by using a burndown treatment or tillage in combination with a preemergence residual
herbicide as appropriate; (7) Use cultural practices such a cultivation and crop rotation, where
appropriate; and (7) Use good agronomic principles that enhance crop competitiveness.
(HRAC, 2009), Similarly, the TUG recommends scouting for weeds; starting with a clean field
using a burndown herbicide application or tillage; controlling weeds when they are small; crop
rotation with opportunities for other modes of action; crop rotation; and “the right herbicide
product at the right rate and at the right time.” (TUG, p. 10, attached as Appendix A). All RR
technology users, including alfalfa growers, are contractually obligated through the MT/SA to
follow the TUG. RRA seed growers are also required by the NAFA BMP to “[m]anage weeds
and volunteers using integrated weed control strategies (e.g., conventional practices
supplemented with Roundup agricultural herbicide formulations applied according to the label
for alfalfa seed production)” (NAFA, 2008).
Table 2-5 in Section 2.4.2 lists weeds known to be found in alfalfa and the biotypes known to be
glyphosate resistant. Since 1998, 14 new GR weeds have been found globally. Nine of these
have glyphosate resistant biotypes in the U.S. Of these nine, four species are known to be
common in alfalfa fields.
3.11.5 Impacts
Alternative 1: No Action
Under Alternative 1 , there would be virtually no effect on the potential for weeds to develop
resistance to glyphosate, given that glyphosate use is minimal with conventional alfalfa.
However, under Alternative 1 , the impact of weeds resistant to other herbicides is likely to
continue to increase as growers would continue to use conventional weed control methods,
including other herbicide modes of action.
As discussed above, glyphosate use in alfalfa can be an effective tool against weeds resistant
to non-glyphosate herbicides, such as ALS-inhibitors and ACCase-inhibitors. Weed resistance
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to glyphosate is not as common as resistance to many other herbicides (Orloff et al., 2009, p. 6,
attached as Appendix D).
Alternative 2: Partial Deregulation of RRA
Under Alternative 2, impacts, if any, with respect to the development of GR weeds due to
increased use of glyphosate associated with RRA crop production are expected to be very
small. First, as discussed above, the nature of glyphosate itself makes it less likely that new GR
weed populations will develop in alfalfa as a result of the use of glyphosate in RRA.
Specifically, there is a relatively low rate of resistance in weeds to glyphosate relate to the
widespread use of this chemical. (Orloff et al., 2009, p. 6; attached as Appendix D), Because
of this differential in weed resistance between glyphosate and other herbicides, the introduction
of this additional mode of weed control may have a net positive effect on weed resistance in
alfalfa production. Second, there is a high level of awareness about the potential for GR weeds
and many readily available resources to assist growers with management strategies (e.g,, Orloff
et al., 2009). Third, because herbicide resistance is a heritable trait, it takes multiple growing
seasons for herbicide tolerant weeds to emerge and become the predominant biotype in a
specific area (Cole, 2010a, p. 4). Researchers have concluded that even if growers completely
relied on only one herbicide, it is likely to take at least five years for an herbicide-resistant weed
population to develop (Kniss, 2010a, p. 4; Beckie, 2006, Neve, 2008; Werth et al., 2008), This
is a reason why crop monitoring and follow up by weed scientists in cases of suspected
resistance are important parts of all herbicide resistance stewardship programs. Fourth, RRA
growers are required to abide by the following requirements, which will operate to mitigate the
risk of glyphosate weed resistance in RRA;
• Read and follow all herbicide use directions and recommendations;
• Follow all stewardship practices outlined in Monsanto's TUG (Appendix A) which
includes weed resistance management practices; and
• • Follow the Weed Resistance Management Guidelines to minimize the risk of
resistance development (see Monsanto’s TUG, p, 4;
http://www.weedresistancemanaqement.com/auidelines.htmn .
3.12 PHYSICAL
The assessment of impact to land use in the sections below considers the impacts to land use
or current cultivation practices under the no action alternative and the proposed partial
deregulation alternative.
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3.12.1 Land Use
Alternative 1: No Action
Under Alternative 1 , there would be no impact to land use or current cultivation practices. There
would be no new planting of RRA for commercial purposes. It is anticipated that existing alfalfa
acres would continue to be planted with non-RRA or non-alfalfa crops.
Alternative 2: Partial Deregulation of RRA
Under Alternative 2, it is expected that RRA would be planted on existing alfalfa acreage for hay
or seed production provided that the proposed partial deregulation measures discussed in
Section 1.1.3 above are followed. Appendix G charts the anticipated adoption of RRA under
Alternative 2, However, the impact of this alternative on the overall amount of land devoted to
alfalfa cultivation is expected to be minimal, as under this alternative, land currently used for
alfalfa seed or hay production would continue to be used in the same manner. Alfalfa
production is largely a market-driven decision rather than a technology-driven decision. (USDA-
APHIS, 2009, p. 157). The availability of a new weed control option is not expected to impact
current land use management. However, since glyphosate controls a broad range of weeds,
farmers may choose to plant RRA on fields with greater weed potential. If the life span of RRA
can be extended longer than current alfalfa stand lifespans, this might impact land use decisions
regarding crop rotation practices, but is not expected to change the nature of land use into or
out of agricultural production.
3.12.2 Air Quality and Climate
The assessment of impacts to air quality and climate in the sections below considers impacts to
air quality and climate practices under the no action alternative and the proposed partial
deregulation alternative. Under Alternative 1, existing alfalfa acreage will continue to be planted
with non-RRA or non-alfalfa crops.
Alternative 1 : No Action
The no action alternative would result in an adverse impact to air quality and climate. The
continued regulation of RRA would result in continued planting of conventional and/or organic
alfalfa. Non-RRA requires greater tillage for weed control than does RRA. Weed control in non-
RRA is usually primarily accomplished by pre-plant tillage to prepare a weed-free seed bed,
and/or by clipping targeted to stop weed growth and competition (with or without crop harvest).
As glyphosate is a crop-safe, broad spectrum herbicide, it is possible that additional alfalfa
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acres, like other herbicide tolerant crops, would be established using no-till methods.
Comparatively, the tillage associated with non-RRA establishment requires greater use of farm
machinery which results in greater greenhouse gas emissions.
Alternative 2: Partial Deregulation of RRA
As previously stated, the partial deregulation of RRA is expected to result in an increase in the
total acreage of RRA crops. This would be accompanied by increased glyphosate application
and decreased tillage of alfalfa fields. Because glyphosate is non-volatile (i.e., does not
evaporate readily) at normal temperatures and is not considered an atmospheric contaminant
(ERA, 1993), the increased application of glyphosate is not expected to result in adverse
impacts to air quality. If glyphosate is applied aerially, any potential drift-related impacts can be
minimized by utilizing recognized practices for managing the potential for off target movement
(i.e., using of specific nozzle types, limiting applications to conditions less favorable for drift).
The overall impacts from aerial application are expected to be minimal because only around two
percent of glyphosate is applied aerially in the U.S. (USDA APHIS, 2009), The decreased tillage
of alfalfa fields under this alternative would have a net positive effect on air quality and climate
by reducing the operation of farm machinery and the associated greenhouse gas emissions.
Emissions related to global warming, ozone depletion, summer smog and carcinogenicity,
among others, were found to be lower in GT crop systems than conventional systems (Bennett
et al., 2004),
3.12.3 Water Quality
The assessment of impacts to water quality in the sections below considers impacts on surface
water quality and groundwater. Under Alternative 1 , alfalfa acres will continue to be planted
with non-RRA or non-alfalfa crops.
Alternative 1 : No Action
Surface water. Alternative 1 would have an adverse impact on surface water quality. Under
this alternative, growers would continue to plant conventional and organic alfalfa, resulting in the
continued reliance on tilling and/or multiple herbicides for weed control. The adverse Impact
would be due to the continued generation of runoff containing; 1) herbicides with greater
environmental impact than glyphosate; and/or 2) particulate matter derived from increased
tillage and soil erosion. Tillage causes widespread soil disturbance resulting in erosion and
topsoil loss, with a corresponding increase in sedimentation and turbidity in streams. This
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erosion can also transport herbicides used on the fields into the surface waters. The usage of a
GT cropping system such as RRA allows for cultivation with reduced tillage.
Groundwater. Alternative 1 would result in an adverse impact to groundwater. Adverse
impacts would result from the continued use of multiple herbicides to control weeds. The vast
majority of growers would continue to plant conventional alfalfa, resulting in the use of multiple
herbicides for weed control. Several non-glyphosate herbicides have a higher potential to leach
into groundwater, which results in groundwater contamination.
Alternative 2: Partial Deregulation of RRA
Surface water. Partial deregulation would result in increased planting (increased acreage) of
RRA. The associated increase in application of glyphosate for weed control would reduce the
impact on surface water quality by facilitating the adoption of conservation tillage methods and
reducing the use of other herbicides with greater potential for adverse impact. Conservation
tillage reduces disturbance of the soil and associated soil erosion from wind and water, and is
facilitated by use of a GT cropping system such as RRA. The net effect would be lower
amounts of herbicide and suspended sediment in runoff, which would improve water quality in
streams and lakes (Wiebe and Gollehon, 2006).
Groundwater. The increased application of glyphosate under Alternative 2 would have a
positive effect on groundwater quality by reducing the use of other herbicides that more readily
leach into groundwater.
3.13 BIOLOGICAL
Potential environmental effects of pesticide use are carefully considered as a part of the FIFRA
pesticide registration process. Prior to the approval of a new pesticide or a new use of that
pesticide (including a change in pesticide application rates and/or timing) and before
reregistering an existing pesticide, EPA must consider the potential for environmental effects
and make a determination that no unreasonable adverse effects to the environment will be
caused by the new pesticide, new use or continued use.
To make this determination, EPA requires a comprehensive set of environmental fate and
ecotoxicological data on the pesticide's active ingredient (40 C.F.R, Part 158). EPA uses these
data to assess the pesticide’s potential environmental risk {exposure/hazard). The required
data include both short- and long-term hazard data on representative organisms that are used
to predict hazards to terrestrial animals (birds, nontarget insects, and mammals), aquatic
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animals (freshwater fish and invertebrates, estuarine and marine organisms), and nontarget
plants (terrestrial and aquatic).
Information regarding the impacts of glyphosate on the biological environment is summarized
below. Additional information on this topic is also being considered in the USDA APHIS Draft
Environmental Impact Statement (DEIS) on the Deregulation of Glyphosate Tolerant Alfalfa
(Docket No. APHIS-2007-0044) (USDA APHIS. 2009).
3.13.1 Animal and plant exposure to glyphosate
Glyphosate is a non-selective herbicide with post-emergence activity on essentially all annual
and perennial plants. As discussed in Section 3.1.1, this activity is due to inhibition of EPSPS,
an enzyme involved in aromatic amino acid synthesis. As with any herbicide, a risk exists that
spray drift could pose issues for plants on the borders of the target field. However, EPA takes
the potential for spray drift into account when conducting the risk assessment it uses to
establish pesticide application rates and direction for use, which are designed to minimize spray
drift risks. Glyphosate binds tightly to agricultural soils and is not likely to move offsite dissolved
in water. Moreover, glyphosate is not readily taken up from agricultural soil by plants. This
limits the impact of glyphosate use on non-target plants, including aquatic plants.
Alternative 1: No Action
Plants. Under the no action alternative, RRA would remain regulated, and growers of
conventional alfalfa would continue to use multiple herbicides for weed control. Many of the non-
glyphosate herbicides are selective herbicides that kill only particular groups of plants such as
annual grasses, perennial grasses, or broadleaf weed species. Therefore, growers of
conventional alfalfa use more than one herbicide to achieve satisfactory weed control. In
addition, some of the other herbicides are applied at greater volumes compared to glyphosate.
The continued use of other herbicides would result in potential adverse impacts to non-target
plants. The herbicides used in conventional alfalfa production have been found, in general, to
have more significant environmental impacts than glyphosate (USDA APHIS, 2009), This is
consistent with the EPA decision to grant reduced risk status for glyphosate use in RRA.
Comparison of results from terrestrial and aquatic plant studies with predicted exposure from
herbicide use suggests that most of the herbicides used in conventional alfalfa systems may
have greater adverse effects than glyphosate on aquatic or terrestrial plant species.
Animals. Under this alternative RRA would remain regulated, and growers of conventional
alfalfa would continue to use an array of herbicides for weed control. Many of the herbicides
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used in conventional alfalfa production have been found to have higher toxicity to certain animai
species than glyphosate. Animal species within and adjacent to fields of conventional alfalfa
would continue to be exposed to these more toxic herbicides. The amphibian habitat in
watersheds where conventional and organic alfalfa are grown would continue to be impacted by
higher levels of tillage, soil erosion, sedimentation in runoff, and turbidity in ponds, lakes, and
rivers than would otherwise be the case if RRA were grown.
Under this alternative, alfalfa growers will continue to have difficulty controlling certain weed
species that sicken, poison or reduce growth of horses, cattle and other livestock. Livestock
illness and suffering related specifically to consumption of toxic weeds in alfalfa forage would
remain unchanged. Economic losses associated with veterinary service costs and livestock
productivity losses would remain unchanged.
Alternative 2: Partial Deregulation of RRA
Plants. With partial deregulation, the acreage of RRA and the associated use of glyphosate
would increase. The increased giyphosate use would be accompanied by a corresponding
decrease in the use of other herbicides that have a higher potential to impact non-target plant
life. So this alternative would have an overall positive effect on terrestrial and aquatic plants.
The EPA has concluded that glyphosate use on RRA poses reduced risk compared to the use
of other herbicides for weed control.^^ As is the case with aerial application of any herbicide,
terrestrial and aquatic plants in the vicinity of alfalfa fields may be incidentally exposed to
glyphosate by spray drift. However, if aerial applications are minimized and/or appropriate spray
drift reduction practices are utilized, this risk to non-target plants would be reduced; recall that
EPA has determined that no unreasonable adverse effects occur from spray drift of glyphosate
when applied according to labei directions. Each year there are millions of acres of GT crops
that are treated with glyphosate with minimal impact to adjacent non-target terrestrial plants
including crops, when appropriate drift minimization measures are practiced.
Because glyphosate binds strongly to soil particles and has no herbicidal activity after binding to
soil, no effects on aquatic plants will result from surface water runoff from glyphosate use on
RRA. Conservation tillage and no tillage practices have the potential to mitigate impacts to
aquatic plants through decreasing soil-laden runoff.
^ A reduced risk decision is made at the use level based on a comparison between the proposed use of the
pesticide and existing alternatives currently registered on that use site. A list of decisions regarding Reduced Risk
Status can be found at: httD://www eoa.oov/oDord001/workplan/reducedrisk.html
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Animals. With partial deregulation, the acreage of RRA and the associated use of glyphosate
would increase. The increased glyphosate use would be accompanied by a corresponding
decrease in the use of other herbicides that have a higher potential to impact animals.
Based on the data available on glyphosate usage, chemical fate, and toxicity, glyphosate is not
expected to pose an acute or chronic risk to the following categories of wildlife (EPA, 1993);
• Birds;
• Mammals;
• Terrestrial Invertebrates;
• Aquatic Invertebrates;
• Fish; and
• Soil Microorganisms.
Glyphosate is practically non-toxic to slightly toxic to birds, freshwater fish, marine and estuarine
species, aquatic invertebrates and mammals and practically non-toxic to honey bees (which are
used to assess effects on non-target insects in general) (EPA. 1993). Glyphosate has a low
octanol-water partition coefficient, indicating that it has a tendency to remain in the water phase
rather than move from the water phase into fatty substances. Therefore, it is not expected to
accumulate in fish or other animal tissues,
As a part of the reregistration evaluation under FIFRA, EPA conducted an ecologicai
assessment for glyphosate. This assessment compared the results from toxicity tests with
glyphosate conducted with various plant and animal species to a conservative estimate of
glyphosate exposure in the environment (Estimated Environmental Concentration (EEC)). In the
Reregistration Eligibility Decision (RED) for glyphosate (EPA, 1993), the exposure estimates
were determined assuming an application rate of 5.0625 lb active ingredient per acre (ai/A),
which exceeds 3.75 lb a.e./A, the maximum EPA labelled use rate for a single application for
agricultural purposes. When the EECs were calculated for aquatic plants and animals, the
direct application of this rate (5.0625 lb a.e./A) to water was assumed. Based on this
assessment, EPA concluded that effects to birds, mammals, fish and invertebrates are minimal
based on available data (EPA, 1993).
The glyphosate end-use products used in agriculture contain a surfactant to facilitate the uptake
of glyphosate into the plant (Ashton and Crafts, 1981). Depending on the surfactant used, the
toxicity of the end-use product may range from practically nontoxic to moderately toxic to fish
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and aquatic invertebrates (EPA, 1993). For this reason, the 1993 Glyphosate RED stated that
some formulated end-use products of glyphosate needed to be labeled as "T oxic to fish” if they
were labeled for direct application to water bodies. Due to the associated hazard to fish and
other aquatic organisms, glyphosate end-use products that are labeled for applications to water
bodies generally do not contain surfactant, or contain a surfactant approved for direct
application to water bodies.
Possible adverse impacts to amphibians resulting from the deregulation of RRA may be offset
by the shift from other herbicides used in alfalfa cultivation, which are considered to have higher
environmental impacts in general. Additionally, amphibian habitat in watersheds where RRA is
produced could be improved through conservation tillage, resulting in decreased soil erosion,
decreased sedimentation in runoff, and decreased turbidity in ponds, lakes, and rivers fed by
surface waters.
Glyphosate can theoretically be toxic to microorganisms because it inhibits the production of
aromatic amino acids through the shikimate pathway. However, field studies show that
glyphosate has little effect on soil microorganisms, and, in some cases, field studies have
shown an increase in microbial activity due to the presence of glyphosate (USDA FS, 2003).
Glyphosate itself is slightly toxic to amphibians; however, amphibians exhibited greater
sensitivity to Roundup® formulations than to glyphosate tested as an acid or isopropylamine
(IPA) salt. This could be due to the surfactant (POEA) used in agricultural formulations, which
has been found to be more toxic to amphibians and other aquatic animals than the herbicide
itself (Lajmanovich et al.. 2003). Some researchers have suggested that, in combination with
POEA, Roundup® could cause extremely high rates of mortality to amphibians that could lead
to eventual population declines (Relyea, 2005). However, the testing methods of the Relyea
(2005) study have been called into question due to the high exposure doses, which exceed
application rates of glyphosate (regulated by FIFRA), as well as the fact that this Roundup®
product is not approved for use in an aquatic setting (USDA APHIS, 2009). Considering the
potential for aquatic exposure to glyphosate formulations from terrestrial uses, EPA recently
evaluated the effect of glyphosate and its formulations on another amphibian species, the
California red-legged frog, and concluded that aquatic exposure to glyhphosate or its
formulations posed no risk to this threatened species (EPA, 2008). Because EPA considered a
wide range of application rates in their evaluation for the red-legged frog, this conclusion can
also be applied to amphibians exposed to glyphosate from applications on GT alfalfa.
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3.13.2 Threatened and endangered species
Alternative 1: No Action
Under this alternative RRA would remain regulated, and growers of conventional alfalfa would
continue to use a multitude of herbicides for weed control. Many of the herbicides used in
conventional alfalfa production have been found to have higher toxicity to certain animal species
than glyphosate. Threatened and endangered species within and adjacent to fields of
conventional alfalfa would continue to be exposed to these more toxic herbicides. The
amphibian habitat in watersheds where conventional and organic alfalfa are grown would
continue to be impacted by higher levels of tillage, soil erosion, sedimentation in runoff, and
turbidity in ponds, lakes, and rivers than would otherwise be the case if RRA were grown.
Alternative 2: Partial Deregulation of RRA
Under partial deregulation, the acreage of RRA would likely increase with a concomitant
increase of glyphosate use for weed control. Based on the information presented below, there
is no expected impact based on the ecological safety assessment conducted for glyphosate
discussed below (Mortensen et al., 2008) and growers implementation of glyphosate application
practices required by Monsanto that are designed to protect threatened or endangered species,
Monsanto recently performed an updated assessment of the impact to threatened and
endangered species of glyphosate application to GT crops. The results of this assessment were
submitted to USDA as Monsanto Report No. RPN-2007-227 (Mortensen et al., 2008).
Monsanto also prepared an endangered species assessment for terrestrial plants that was
submitted to USDA (Honegger et al., 2008). The findings of these assessments are as follows:
• Threatened or endangered terrestrial or semi-aquatic plant species are not at risk from
ground applications of glyphosate at rates less than 3.5 lb active ingredient per acre
(ai/A). Since the maximum single application rate before or after crop emergence in GT
alfalfa is 1.55 lb ai/A, no listed plant species are predicted to be at risk from ground
application of glyphosate to RRA.
• • Threatened or endangered terrestrial or semi-aquatic plant species are not at risk
from aerial applications of glyphosate at rates less than 0.70 lb ai/A. Since rates above
0,7 lb ai/A are needed to control a number of weed species, buffers for aerial application
have been proposed by Monsanto (using an EPA-accepted drift model) to permit aerial
application at rates up to 1.56 lb ai/acre while still predicting no impact on plant growth at
the edge of the buffer. Monsanto has developed a web site, www.Pre-Serve.org, to
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provide growers a means to determine if threatened or endangered plant species are
potentially at risk from glyphosate applications that they are planning on GT crops. The
requirement for growers to consult this web site has been incorporated into the
Monsanto Technology/Stewardship Agreement and Technology Use Guide, an
agreement that growers sign when purchasing any Monsanto GT seed. Through the
implementation of the Pre-Serve web site and its mandated use by growers, threatened
and endangered plant species are protected from potential effects from glyphosate use
on RRA.
• Other taxa (including birds, mammals, insects, fish, amphibians, aquatic invertebrates,
and aquatic plants) are not at risk from the use of glyphosate herbicides in alfalfa
production. In addition, other taxa are not at risk from indirect effects resulting from
habitat alteration from the use of glyphosate.
Amphibians use a wide range of aquatic habitats for their breeding sites and could be exposed
to glyphosate in surface water. Considering the potential for aquatic exposure to glyphosate
formulations from terrestrial uses, EPA recently evaluated the effect of glyphosate and its
formulations on the California red-legged frog (CRLF). EPA concluded that aquatic exposure to
glyphosate and its formulations posed no risk to this threatened species (EPA, 2008). As a part
of the endangered species effects assessment for the California red-legged frog, EPA evaluated
the effect of glyphosate at application rates up to 7.95 lb ai/A. Based on this assessment, the
application of glyphosate at the maximum, single, in-crop application rate specified on the EPA-
approved label for RRA (1 .55 lb ai/A) would have no effects on threatened and endangered
species offish, amphibians, birds, or mammals.
Although not specifically discussed in the assessment, it can also be determined that there
would be no effects of glyphosate or its formulations on threatened or endangered vascular
aquatic plants and aquatic invertebrates (EPA, 2008). For terrestrial invertebrates, it was
determined that there were no effects on non-endangered species. Although not specifically
stated in the CRLF assessment, exposure levels from spray drift to threatened or endangered
invertebrates adjacent to RR alfalfa fields are below the level^^ that would result in a conclusion
of risk. Additional information has been provided to EPA to also support a conclusion of no risk
for small terrestrial invertebrates that might be present in the field at the time of glyphosate
application. For terrestrial plants, the potential for effects on non-endangered species was
assessed, and using the endpoints and EECs provided, it could be determined that there would
44
Screening level drift assumptions are one percent for ground applications and five percent lor aerial applications.
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be no effects on terrestrial plants from ground applications at the maximum single in-crop
application rate for RRA.
3.1 3.3 Potential impact of exposure to RRA
APHIS analyzed the potential impacts to threatened and endangered species from directly
contacting, consuming, or hybridizing with RRA and/or their progeny. This analysis considered
the effect of production of RRA on designated critical habitat or habitat proposed for
designation. The results are as follows:
• RRA is not expected to become more invasive in natural environments or have any
difference in effect on critical habitat than their parental non-GT line in the absence of
glyphosate selection.
• Analysis of forage samples from several locations demonstrates that RRA is
compositionally and nutritionally equivalent to other alfalfa varieties currently on the
market. It is not expected to have adverse nutritional effects on any threatened and
endangered species that feeds upon it. The RRA CP4 EPSPS protein does not have
toxic or pathogenic effects that would affect threatened and endangered species or their
critical habitat.
• RRA is not expected to form hybrids with any state or federally listed threatened or
endangered species of plant or any plant species proposed for federal listing.
Based on this assessment, APHIS could not identify any difference between the impacts from
exposure to RRA and the impacts from exposure to other alfalfa varieties (conventional and
organic varieties). Consequently, there would be little or no differences between Alternatives 1
and 2 in terms of the exposure of threatened and endangered species to RRA.
3.14 HUMAN HEALTH AND SAFETY
3.14.1 Consumer health and safety
Because RRA is compositionally and nutritionally identical to non-RRA and because alfalfa
forage and seed are not directly consumed by humans, the main issue regarding consumer
health and safety is potential dietary exposure to glyphosate herbicide residues. The general
public may be exposed to herbicides used on RRA if they consume animal commodities arising
from livestock fed on the treated alfalfa. For the reasons described below, this risk is very small,
and there would be little or no differences between Alternatives 1 and 2 in terms of the impact of
regulation or partial deregulation of RRA on consumer health and safety.
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Consumption of adjacent crops impacted by spray drift is a theoretically possible route of
exposure, but is not a normal part of dietary risk assessment (EPA, 2000). The predominant
route of potential dietary glyphosate exposure to consumers linked to RRA is via consumption of
meat / milk from livestock fed on the treated alfalfa. EPA’s procedures to estimate dietary
exposure fully account for these processes (EPA, 2000; EPA, 1 993). EPA has determined that
there is a reasonable certainty that no harm will result from aggregate exposure to glyphosate
residues (71 Fed. Reg. 76180 (Dec. 20, 2006)). According to the RED (EPA, 1993), glyphosate
has relatively low oral and dermal acute toxicity and has been placed in Toxicity Category III for
these effects (Toxicity Category I indicates the highest degree of acute toxicity, and Category IV
the lowest). The acute inhalation toxicity study was waived because glyphosate is nonvolatile
and because adequate inhalation studies with end-use products exist and show low toxicity.
Glyphosate is already used for weed control with conventional alfalfa and other GT crops,
including GT corn, GT soybeans, and GT cotton. In addition, it is registered for use in weed
control with several fruits and vegetables, and tolerances are established in the consumable
commodities of these crops. The current upper estimates of exposure risk for glyphosate are
based on highly conservative fruit and vegetable intake rates with an assumed high estimated
amount of glyphosate residue. The current aggregate dietary risk assessment completed by
EPA concludes there is no concern for any subpopulation regarding exposure to glyphosate,
Including the use on many fruits and vegetables (71 Fed. Reg. 76180 (Dec. 20, 2006)),
Moreover, the potential exists for decreases in the applications and subsequent residues of
more toxic herbicides if RRA is partially deregulated.
The use of glyphosate does not result in adverse effects on development at non-maternally toxic
doses, reproduction, or endocrine systems in humans and other mammals (EPA, 1993; WHO,
2004; ECETOC, 2009). Under present and expected conditions of use, glyphosate does not
pose a health risk to humans (EPA, 1993). Additionally, the nature of glyphosate residue in
plants and animals is adequately understood, and studies with a variety of plants indicate that
uptake of glyphosate from soil is limited. The material that is taken up is readily translocated
throughout the plant. In animals, most ingested or absorbed glyphosate is eliminated in urine
and feces. As discussed in Section 3.10, no impacts from consumption of food or feed
containing the CP4 EPSPS protein would be expected.
3.14.2 Hazard identification and exposure assessment for field workers
The main issue regarding the health and safety of field workers and RRA is potential worker
exposure to glyphosate used for weed control. For the reasons described below, the health risk
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from field worker exposure to glyphosate is small when used in accordance with labeling. There
would be little or no differences between Alternatives 1 and 2 in terms of the impact of
regulation or partial deregulation of RRA on field worker health and safety.
Glyphosate is already used for weed control with conventional alfalfa and other GT crops,
including GT corn, GT soybeans, and GT cotton. In addition, it is registered for use in weed
control with several fruits and vegetables. So the potential for field worker exposure to
glyphosate will continue to exist whether RRA is regulated or deregulated.
With regard to subchronic and chronic toxicity, one of the more consistent effects of exposure to
glyphosate at high doses is reduced body weight gain compared to controls. Body weight loss
is not seen in multiple subchronic studies, but has at times been noted in some chronic studies
at excessively high doses S 20,000 ppm in diet (WHO, 2004). Other general and non-specific
signs of toxicity from subchronic and chronic exposure to glyphosate include changes In liver
weight, blood chemistry (may suggest mild liver toxicity), and liver pathology (USDA FS, 2003).
Glyphosate is not considered a carcinogen; it has been classified by ERA as a “Group E
carcinogen”, which means that it shows evidence of non-carcinogenicity for humans (ERA,
1993),
ERA'S human health analysis considers both the applicator and bystander as having the
potential for exposure to glyphosate. Based on the toxicity of glyphosate and its registered uses,
including use on GT crops, ERA has concluded that occupational exposures (short-term dermal
and inhalation) to glyphosate are not of concern because no short-term dermal or inhalation
toxicity endpoints have been identified for glyphosate (71 Fed. Reg. 76180 (Dec. 20, 2006)).
Additional evidence to support the ERA conclusion can be found in the Farm Family Exposura
Study, a biomonitoring study of pesticide applicators conducted by independent investigators
(Acquavella et al., 2004). This biomonitoring study determined that the highest estimated bodily
adsorption of glyphosate as the result of routine labeled applications of registered glyphosate-
based agricultural herbicides to crops, including GT crops, was approximately 400 times lower
than the reference dose (RfD) established for glyphosate. Furthermore, investigators
determined that 40 percent of field workers (applicators) did not have detectable exposure on
the day of application, and 54 percent of the field workers had an estimated bodily adsorption of
glyphosate more than 1000 times lower than the RfD (Acquavella et ai., 2004), Use patterns
and rates for RRA are typical of most glyphosate agronomic practices. Therefore, the partial
deregulation of RRA would not significantly increase the exposure risk to pesticide applicators.
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Finally, the biomonitoring study also found little evidence of detectable exposure to individuals
on the farm who were not actively involved with or located in the immediate vicinity of
application of glyphosate-based herbicides to crops. Considering the similarity of the use pattern
and application rates of the glyphosate products in this study compared to those registered for
use on RRA and GT crops in general, bystander exposure attributed to the use of glyphosate on
GT crops is expected to be negligible.
Based on the above information, the use of currently registered herbicide products containing
glyphosate in accordance with the ERA labeling requirements will not pose unreasonable risks
or adverse effects to field workers or bystanders. In general, the herbicidal activity of
glyphosate is due primarily to a metabolic pathway that does not occur in humans or other
animals, and, thus, this mechanism of action is not directly relevant to the human health risk
assessment. ERA considers glyphosate to be of low acute and chronic toxicity by the dermal
route of exposure. Glyphosate is considered a Category IV dermal toxicant and is expected to
cause only slight skin irritation (USDA ARHIS, 2009).
3.15 SOCIAL AND ECONOMIC IMPACTS OF THE PROPOSED PARTIAL
DEREGULATION
APHIS has studied the potential socioeconomic impacts of fully deregulating RRA (USDA
APHIS, 2009, pp. 125-145 & Appendix S). Although the types of potential socioeconomic
impacts discussed in the draft EIS under full deregulation would remain the same as under this
proposed partial deregulation, the scale (extent and scope) of each impact would be
significantly more limited. The proposal restricts (excludes) forage planting of RRA within
county-level proximity to 99.5 percent of the U.S. alfalfa seed crop production areas and it would
place highly stringent isolation conditions and other requirements on a small, pre-defined group
of RRA seed producers.
Simply stated, protection of conventional and organic seed purity has been identified as an
important component for the coexistence of GE, conventional and organic agricultural crops,
including alfalfa. As It is primarily a geographically-structured approach parsed to the county
level by seed vs. forage crop production criteria, the partial deregulation is intended to preclude
the possibility for socio-economic impacts (favorable or unfavorable) specifically inter-related
with gene flow into >99.5 percent of the U.S. alfalfa seed crop. The remaining approximately
0.5 percent of the seed crop is also unlikely to be impacted because when and if grown in local
proximity to a RRA forage crop (<165 ft), the RRA forage producers would be required to
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mitigate the amount of available RRA pollen by cutting the RRA hay crop prior to 10 percent
bloom,
USDA has clearly endorsed coexistence of GE, conventional and organic growers, crops and
markets. During the period in which USDA/APHIS finalizes a court-ordered EIS and prepares a
record of decision on the deregulation of RRA, the terms of the proposed Partial Deregulation
cautiously parse out the areas of primary "gene flow interface" between RRA and conventional
alfalfa, enabling immediate RRA grower benefits without interfering with conventional and
organic crops and markets. The proposed partial deregulation conditions will enable, without
restriction, the continued supply of conventional variety seeds and basic generation seeds for
export, organic or domestic use. It would also allow producers to choose to use or not use RRA
on approximately seventy-eight percent (78%) of U.S. forage production acres and enable a
nominal number of RRA seed growers on seed production acres where extraordinary isolation
exists. The actual adoption of the technology by forage growers is anticipated to be some
fraction of the eligible (allowed) alfalfa acreage total in each region of the U.S. (Appendix G).
Those most likely to adopt the technology are those producers serving dairy herd forage needs.
However, pending completion of an EIS and a final deregulation decision, this partial
deregulation would not uniformly enable all forage or seed growers the choice to participate in
the socio-economic benefits of the technology, and moreover, in future years, it is possible that
RRA seed supplies could fall short of RRA seed demand or that forage market inequities might
develop between competing geographies with and without the technology.
It Is likely that through improvements to weed management, the widespread adoption of the
RRA technology by growers could result in economic benefits related to the quantity and
improved forage quality of U.S, hay supplies (see below). Forage producers and dairy
producers may most directly benefit from more abundant supplies of dairy quality forage with
fewer weeds. Organic forage, dairy, and other food producers would also be likely to
economically benefit from increased market share related to the newly-heightened market
differentiation between organic and non-organic dairy and forage production strategies, e.g,, the
organic dairy food customer base may increase if a proportion of conventional consumers begin
to purchase organic foods due to a negative perception of GE alfalfa. Since the RRA crops
were first grown (2005-2007) the organic dairy sector has experienced market growth.
According to several independent analyses (Putnam and Undersander, 2009, attached as
Appendix I; Van Deynze et al,, 2008; NAFA, 2008d; Putnam, 2006; Putnam, 2007), organic
forage supplies and organic farming practices are unlikely to be at economic risk, adversely
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impacted, or materially affected by the deregulation or growing of RRA. Simple, minimal/no-
cost effective methods are available to organic and conventional forage producers wishing to
avoid RRA irrespective of their neighbor's choice to grow RRA seed or hay crops. Specifically,
organic or non-GE forage producers need only to cut their hay before seed ripens, purchase
non-GE planting seeds qualified for organic use and maintain organic hay lot segregation: i,e„
follow current routine farm plans required by the NOP. Organic dairy or livestock producers will
continue to grow and/or purchase only organically qualified (identity-preserved, segregated)
feedstuffs; i.e., follow current routine farm plans required by the NOP. A minority, approximately
3 to 5 percent, of total alfalfa production may be sensitive to GE traits (Putnam, 2007).
Therefore, it may be reasoned that a similar percentage of U.S. alfalfa forage growers would opt
to take these nominal steps to avoid RRA trait presence in their conventional hay crops.
Forage production. Benefits to farm socio-economics include improvements to grower
profitability, consistent and abundant on-farm forage supply, and, the ease and flexibility of
weed control.
As indicated above, in the defined geographies where RRA forage production would be allowed
with restrictions for new plantings (Table 1-1 and Appendix B of this ER), forage producers
would have a new tool available for weed management throughout the life of the stand. Forage
producers (n=201) who have previously commercially used the RRA technology report an
average increase in productivity of 0.9 total acres per year (T/A/yr) which translates to
approximately $100 acre per year (A/year) incremental crop value at an average hay price of
$110 total (T) (RRA Satisfaction Study. Market Probe, 2008, attached as Appendix H). Over the
life of the stand (e.g., 3 to 5 years), the approximate incremental value of RRA forage
production is $300 to $500 per acre (A).
Like growers of other GE crops, many growers of RRA also report experiencing intangible social
benefits (see examples of Public Comments to draft EIS included in Appendix F). Specifically,
growers report that the RRA technology improves their farming experience in that weed control
is easier, simpler, more reliable (less risk of failure), herbicide timing is more flexible and crop
injury (stress) is lessened. They also acknowledge the lessened risk to water sheds and to
herbicide applicators (self, family and employees) compared to several other herbicide choices.
Relative to their economic benefits and risks, currently available weed management strategies
may not be implemented at all because they can be expensive, ineffective on target weeds,
restricted in use due to environmental or worker safety issues, difficult to apply at the correct
time for good control, and some measures reduce alfalfa crop yield or stand longevity more than
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the weeds (e.g., early clipping, companion and cover crops). RRA growers note that the RRA
technology is especially beneficial for weed control during the early seedling establishment
period when the new planting can be at risk of failure (complete loss) due to unchecked weed
competition. Although there are many reasons why alfalfa plantings fail in the first year, growers
who adopt RRA would likely have less exposure to economic risk and intangible uncertainty
associated with the possibility of losing their valuable planting inputs, meanwhile ensuring a
more consistent supply of nutritious forage for livestock than the alfalfa growers not adopting the
technology.
Seed Production. Socio-economic benefits related to RRA seed production include: improved
profitability for RRA seed growers; the benefits described above associated with improved weed
control; and a seed supply of new RRA varieties targeting new production niches, thus enabling
the forage benefits described herein.
The seed producer consortia outlined in Table 1-2 have several things in common. These
growers all produced RRA seed in 2006, 2007, 2008 and/or 2009. They will receive FGI
training on RRA Seed Production Best Practices and will be monitored by FGI for compliance as
required by the NAFA BMP and the proposed conditions for partial deregulation. These
growers also all produce seed in a setting that allows substantial isolation from conventional
alfalfa seed production. Table 1-2 shows the existing isolation, and the minimum required
isolation required in future years under the terms of this partial deregulation. In all cases the
required Isolation exceeds the NAFA RRA Seed Production Best Practices.
Pollen-mediated gene flow is inversely proportional to isolation distance, and varies by
introduced pollinator species. Any new RRA seed production with the growers and production
areas outlined In Table 1-2 will have a minimal impact on conventional or organic seed
production targeted for either U.S. or export markets.
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SECTION 4.0 CUMULATIVE IMPACTS
This section discusses the cumulative impacts that may be associated v/ith Alternative 2, when
combined with other recent past, present, and reasonably foreseeable future actions within the
affected environment. Cumulative impacts that will occur are expected to be negligible.
Cumulative impacts occur when the effects of an action are added to the effects of other actions
occurring in a specific geographic area and timeframe. The cumulative impact analysis follows
CEQ’s guidance: Considering Cumulative Effects Under the National Environmental Policy Act
(CEQ, 1997). The steps associated with the analysis include:
• Specify the class of actions for which effects are to be analyzed.
• Designate the appropriate time and space domain in which the relevant actions occur.
• Identify and characterize the set of receptors to be assessed.
• Determine the magnitude of effects on the receptors and whether those effects are
accumulating.
4.1 CLASS OF ACTIONS TO BE ANALYZED
This analysis addresses regional and national actions that may have impacts that may
accumulate with those of the proposed partial deregulation measures.
4.2 GEOGRAPHIC AND TEMPORAL BOUNDARIES FOR THE ANALYSIS
As described in Section 2, over the past 60 years, the number of alfalfa hay acres harvested
annually in the U.S. has ranged between 20.7 million acres (2010) and 29.8 million acres
(1957), with peak tonnage of hay production in the mid-1980s (USDA ERS, 2010a). In 2006,
20.9 miilion acres of aifaifa was harvested for forage. (In contrast, 122.1 acres of alfalfa was
harvested for seed.) Alfalfa is grown for forage throughout the U.S. Based on 2008 production
data by county, the four major U.S, alfalfa producing regions include the north-central, west,
northeast, and south, with the north-central and the west regions being the highest producing
regions in the U.S.
Under this proposal, we anticipate that any future aifaifa planting under partiai deregulation will
conform to the geographic use restrictions described herein, with the exception of a minimal
number of acres (e.g. less than 1 00 acres) that may be produced under APHIS permit. In the
event this proposal is granted, the small and declining number of RRA acres planted under
APHIS permit will not have incremental cumulative impact on any of the resource areas.
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Activities relevant to the cumulative impacts analysis have been identified from reviews of
information available from government agencies, such as NEPA documents, land-use and
natural resource management plans, and from private organizations. Not all actions identified in
this analysis would have cumulative impacts on all resource areas,
4.3 RESOURCES ANALYZED
Issues evaluated in this cumulative impacts analysis include some of the resource areas
discussed in Sections 2 and 3 including land use, air quality and climate, water quality,
biological, and human health and safety. In addition, specific topics analyzed include:
cumulative impacts related to any possibility of development of glyphosate resistant weeds, and
cumulative impacts of potential increased glyphosate usage with the cultivation of GT crops.
4.4 CUMULATIVE IMPACTS RELATED TO THE DEVELOPMENT OF GLYPHOSATE
RESISTANT WEEDS
Glyphosate offers many benefits to the grower as a weed control product, Glyphosate controls a
broad spectrum of grass and broadleafweed species present in U.S. production fields, has
flexible use timings, and when used in GT crops, has a very high level of crop safety. As the
adoption of GT crops has grown, the use of glyphosate has increased over the past several
years. As discussed in Section 3, with the increased use of glyphosate, there is also the
potential for increased selection pressure for the development of new glyphosate-resistantweed
populations and/or new glyphosate-resistant weed species.
As discussed in Section 2.4, there is a low probability for the development of new glyphosate-
resistant weed populations and/or development of new resistance weed species from the use of
glyphosate herbicides in conjunction with plantings of RR alfalfa. The expected use pattern of
herbicides, including glyphosate, in alfalfa and the alfalfa production practices (e.g. frequent
mowing) provides a basis for retarding the development of new resistance. It also provides a
basis for managing resistance that may be present from movement of a resistant weed seed
into an alfalfa field or cross-pollination from a resistant weed to a sexually compatible weed
within an alfalfa field.
As discussed in Section 3.1 1 .14, market research studies indicate that growers of glyphosate-
tolerant crops are increasingly taking measures to minimize the potential for development of
glyphosate resistance. Based on the adoption of these measures by growers of other GT crops
such as GT corn, GT soybeans, and GT cotton (Frisvold et al., 2009), similar adoption of these
measures by GT alfalfa growers is anticipated. In all three of these other GT crops, growers are
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adopting best management practices, in particular the more frequent use of complementary
herbicides in a glyphosate-based weed management programs in corn (Givens et al., 2009;
Frisvoid et al., 2009). The key best management practices recommended by industry and
academics to control against weed resistance are as follows : a) identifying weeds and
monitoring for escapes to determine if current practices need to be modified to achieve
acceptable levels of weed control, b) using proper herbicide rates and timing, c) using crop
rotation to facilitate use of different modes of action over time, d) using agronomic management
practices to supplement herbicide weed control, e) alternating herbicides with different modes of
action, and e) tank mixing herbicides of different modes of action (HRAC, 2009; Orloff et al.,
2009; Monsanto, 2010a).
Increased glyphosate use is not expected in the major GT crops (corn, soybeans and cotton),
as GT usage in these crops is high and likely not to increase beyond current levels. As
discussed above and in Section 3.11, there is a high level of awareness among growers of
these crops of the need to minimize the potential for development of glyphosate resistance, and
evidence that growers are implementing management practices to prevent the development of
glyphosate resistant weeds.
These management practices for all glyphosate-tolerant crops, combined with the specific
alfalfa weed management practices discussed in Section 2.4, will together help minimize the
cumulative potential for development of glyphosate resistant weeds under Alternative 2. Thus,
Alternative 2 is not expected to contribute to cumulative adverse impacts on the development of
glyphosate-resistant weeds.
4.5 CUMULATIVE IMPACTS OF POTENTIAL INCREASED GLYPHOSATE USAGE
The increase in glyphosate used under the proposed interim measures described in this ER
(Alternative 2), would be minimal. Assuming a 50 percent market share, the amount of
glyphosate applied to RRA would be 1 ,627,500 lb a.e (0,5 x 21 million total alfalfa acres X 1 .55
lb a.e./A). Calculating from Table N-3 on page N-16 in the draft EIS, total use of glyphosate on
corn, cotton, soybean, and wheat is equal to 126,308,000 lbs. Therefore, even if glyphosate is
used on 50 percent of total alfalfa acres, the glyphosate use on alfalfa would be 1 .3 percent of
the glyphosate used on these four major crops.
According to the USDA ERS (2009), U.S. farmers have adopted genetically engineered crops
widely since their introduction in 1996. Soybeans and cotton genetically engineered with
herbicide-tolerant traits have been the most widely and rapidly adopted GE crops in the U.S.,
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followed by insect-resistant cotton and corn. Figure 4-1 shows the percentage of acres of
genetically engineered crops in the U.S. between 1996 and 2009. Appendix G charts data from
Monsanto/FGI of the anticipated adoption of RRA under Alternative 2 over a 10 year period.
Herbicide-tolerant crops, which are engineered to survive application of specific herbicides that
previously would have damaged the crop, provide farmers with a broader variety of options for
effective weed control. Based on USDA survey data, herbicide tolerant soybeans went from 17
percent of U.S. soybean acreage in 1997, to 68 percent in 2001 and 91 percent in 2009.
Plantings of herbicide tolerant cotton expanded from approximately 10 percent of U.S. acreage
in 1997 to 56 percent in 2001 and 71 percent in 2009. The adoption of herbicide tolerant corn
was slower in previous years, but has reached 68 percent of U.S, corn acreage in 2009 (USDA
ERS, 2009).
Corn growers use the largest volume of herbicides. Approximately 96 percent of the 62.2
million acres used for growing corn in the 10 major corn-producing States were treated with
more than 164 million pounds of herbicides in 1997 (USDA ERS, 2009), Soybean production in
the U.S. also uses a large amount of herbicides. Approximately 97 percent of the 66.2 million
soybean acres in the 19 major soybean-producing States were treated with more than 78 million
pounds of herbicides in 1997 (USDA ERS, 2009). Cotton production relies heavily on
Figure 4-1 Growth in Adoption of Genetically Engineered Crops in U.S.
Source: Graph from USDA ERS. 2009
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herbicides to control weeds, often requiring applicaUons of two or more herbicides at planting
and postemergence herbicides later in the season (Culpepper and York, 1998). Close to 28
million pounds of herbicides were applied to 97 percent of the 13 million acres devoted to
upland cotton production in the 12 major cotton-producing States in 1997 (USDA ERS, 2009).
Pesticide use on corn and soybeans has declined since the introduction of GE corn and
soybeans in 1996. Several studies have analyzed the agronomic, environmental, and economic
effects of adopting GE crops, including actual pesticide use changes associated with growing
GE crops (McBride and Brooks, 2000; Fernandez-Cornejo, Klotz-Ingram, and Jans, 1999, 2002;
Giannessi and Carpenter, 1999; Culpepper and York, 1998; Marra et at, 1998; Faick-Zepeda
and Traxler, 1998; Fernandez-Cornejo and Klotz-Ingram, 1998; Gibson et at, 1997; ReJesus et
at, 1997; Stark, 1997), Many of these studies have concluded that herbicide use is reduced
with herbicide-tolerant varieties (USDA ERS, 2009).
Studies conducted by the USDA shows an overall reduction in pesticide use related to the
increased adoption of GE crops. Based on the adoption of GE crops between 1997 and 1998
(except for herbicide-tolerant corn, which is modeled for 1996-97), the decline in pesticide use
was estimated to be 19.1 million acre-treatments, 6.2 percent of total treatments (USDA ERS,
2009). Most of the decline in pesticide acre treatments was from less herbicide used on
soybeans, which accounts for more than 80 percent of the reduction (16 million acre-treatments)
(USDA ERS, 2009).
The adoption of herbicide-tolerant crops such as RRA, GT soybeans, and GT corn results in the
substitution of glyphosate for previously used herbicides. The GT crops allow farmers to limit
and simplify herbicide treatments based around use of glyphosate, while a conventional weed
control program can involve multiple applications of several herbicides. In addition, and more
importantly, herbicide-tolerant crops often allow farmers to use more benign herbicides (USDA
ERS, 2009).
There are known benefits associated with the use of glyphosate herbicides compared to
herbicides currently used by alfalfa producers. Glyphosate has documented favorable
characteristics with regard to risk to human health, non-target species, and the environment
(Malik et al., 1989; Williams et al., 2000), Glyphosate is classified by the EPA as Group E
(evidence of non-carcinogenicity for humans) (57 Fed. Reg. 8739 (Mar. 12, 1992)). In 1998, the
EPA granted Reduced Risk status for an expedited review of the submitted residue data
package supporting the use of glyphosate.
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Petitions for non-regulated status are pending for additional events or lines of GT soybean,
corn, sugar beets, and creeping bentgrass (USDA APHIS, 2010). If deregulated, the production
of new GT crops would lead to increased glyphosate application, and in the instances that it is
cultivated in or near the same geographic areas where RRA is produced, this could lead to a
cumulative impact on non-target plants impacted by glyphosate. However, given that these
acres are already being used for agricultural production (in the case of corn and soybeans, most
likely through a RR cropping system), these plants are likely already exposed to glyphosate or
other pesticides.
Studies of the relationship between genetically engineered crops and herbicide use has shown
that an increase in GT crops can result in a decrease in mechanical tillage (Brimner et al., 2005;
Fernandez-Cornejo, 2006; Gianessi and Reigner, 2006; Kleter et al., 2007; Sankula, 2006;
Johnson et al., 2008). The potential cumulative impact from this reduction in mechanical tillage
is discussed in the following sections.
4.6 CUMULATIVE IMPACTS ON LAND USE. AIR QUALITY AND CLIMATE
As discussed in Section 2, alfalfa acreage has fluctuated little for the past 60 years, although
acreage has generally been declining since the mid-1980s. Acreage used for alfalfa would not
be expected to be impacted by increased RRA plantings. Therefore, as discussed in Section 3,
Alternative 2 is not expected to impact land use directly or indirectly, other than the anticipated
shift of certain acreage from conventional or organic alfalfa production to RRA production as a
result of a partial deregulation (See Appendix G charting anticipated adoption of RRA under
Alternative 2), and no cumulative impacts on land use are anticipated from Alternative 2.
As discussed in Section 3, Alternative 2 is expected to have positive impacts on air quality and
climate, primarily resulting from reduced tillage. Consequently, Alternative 2 Is not expected to
have any adverse cumulative impacts on air quality or climate.
4.7 CUMULATIVE IMPACTS ON WATER QUALITY
As discussed in Section 3, the advent of GT crops and the use of post-emergent herbicides that
could be applied over a crop during the growing season have facilitated the use of conservation
tillage farming practices, since weeds could be controlled after crop growth without tilling the soil
(USDA ERS, 2009). The use of GT crops (particularly soybeans) has intensified that trend
since it often allows a more effective and less costly weed control regime than using other post-
emergent herbicides (USDA ERS, 2009; Carpenter and Gianessi, 1999).
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The impact of conservation tillage (including no-till, ridge-till, and mulch-till) in controlling soil
erosion and soil degradation is well documented (Edwards, 1995; Sandretto, 1997). By leaving
substantial amounts of plant matter over the soil surface, conservation tillage 1) reduces soil
erosion by wind; 2) reduces soil erosion by water; 3) increases water infiltration and moisture
retention; 4) reduces surface sediment and water runoff; and 5) reduces chemical runoff (USDA
ERS, 2009).
Glyphosate may potentially be found in surface water runoff when erosion conditions lead to the
loss of surface particles. However, as discussed in Section 3, partial deregulation of GT crops
typically leads to an increase in conservation tillage and no tillage systems, which results in less
mechanical disturbance of the soil during alfalfa cultivation and thereby decrease the loss of
surface soil. Consequently, given that glyphosate binds strongly to soil particles and has no
herbicidal activity after binding to soil, no-tillage and conservation tillage are expected to further
reduce the likelihood of any impact of surface water runoff (Wiebe and Gollehon, 2006).
Therefore, no cumulative adverse impacts to surface water or groundwater are anticipated.
4.8 CUMULATIVE BIOLOGICAL IMPACTS
For non-target terrestrial species, available ecological assessments in EPA RED (EPA, 2003)
documents or registration review summary documents provide the support that the use of
glyphosate represents reductions in chronic risk to birds compared to benfluralin, norflurazon,
paraquat, sethoxydim, and trifluralin, and in acute risk to small mammals in comparison to
bromoxynil, EPTC, and paraquat. For other alfalfa herbicide products, as well as glyphosate, no
significant risks to birds or other non-target terrestrial species were indicated in the available
information.
For non-target aquatic species, Tables 4-1 , 4-2, and 4-3 provide summaries of the estimated
exposure and hazard information for the traditional herbicides used in conventional alfalfa
production, and present quantitative comparisons of the derived Risk Quotients. Exposure,
defined as the EEC, was calculated for all products using the assumptions (assuming aerial
application) of 5 percent drift of spray applied to a one-acre field onto water and 5 percent runoff
from 10 treated acres into a one-acre pond six feet in depth. Herbicide treatments were based
on the maximum single application rate for alfalfa taken from product labels. Hazard information
(LC50 or EC50) for each active ingredient was taken from the EPA Ecotoxioology One-Liner
Database (if available) or other EPA source documents and summarized in Tables 4-1 , 4-2, and
4-3 as the upper and lower values from the range of values reported. Hazard information for the
end-use formulated products is generally not readily available; thus, this analysis is a
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comparison based solely on the active ingredients. Any label warnings and other available
hazard and/or risk descriptions for non-target aquatic species are also included. The Risk
Quotient is determined for each active ingredient by dividing the EEC by the hazard (LC50 or
EC50) value.
Plants potentially at risk from the use of glyphosate are potentially at risk from the use of any
herbicide. Like most herbicides, plants are highly sensitive to glyphosate. Monsanto has
developed a program named Pre-Serve to address the use of glyphosate, including aerial
spraying, in areas where threatened plants may be located. Following use instructions on the
EPA-approved label and use limitations described in Pre-Serve would address any such risk of
exposure. Federal law requires pesticides to be used in accordance with the label.
Conservation tillage and no tillage practices provide additional assurance that the impact to
aquatic plants is reduced by decreasing soil-laden runoff.
The EPA-approved labels for products containing 2,4-DB, celthodim, sethoxydim, and trifiuralin
include warnings of toxicity or adverse effects to fish, and/or aquatic invertebrates and/or
aquatic plants. Risk Quotients that exceed the Trigger Value of 0.5 for aquatic animals and 1 .0
for aquatic plants are highlighted in bold text in Tables 4-1 , 4-2, and 4-3 as exceeding a Level of
Concern, based on EPA Ecological Effects Rejection Analysis and Deterministic Risk
Characterization Approach. Current alfalfa herbicide products containing benfluralin,
bromoxynil, diuron, hexazinone, metribuzin, norflurazon, paraquat, terbacil, and trifiuralin are
shown to exceed these Levels of Concern. As supported by the EPA designation of reduced
risk for application of glyphosate to alfalfa, glyphosate is a more environmentally preferred
herbicide compared to other herbicides currently used in alfalfa production since glyphosate Is
generally less toxic and has favorable degradation properties.
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Table 4-1. Comparison of Potential Effects of Glyphosate and Alfalfa Herbicides on Freshwater Fi
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Table 4-2. Comparison of Potential Effects of Glyphosate and Alfalfa Herbicides on Freshwater Aquatic Invertebrates
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Table 4-3. Comparison of Potential Effects of Glyphosate and Alfalfa Herbicides on Aquatic Plants (Algae and Duckweed
invironmental Repoi
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4.9 CUMULATIVE IMPACTS ON HUMAN HEALTH AND SAFETY
Where pesticides may be used on food or feed crops, EPA sets tolerances (maximum pesticide
residue levels) for the amount of the pesticide residues that can legally remain in or on foods.
EPA undertakes this analysis under the authority of the Federal Food, Drug, and Cosmetic Act
(FFDCA). Under the FFDCA, EPA must find that such tolerances will be safe, meaning that
there is a reasonable certainty that no harm will result from aggregate exposure to the pesticide
chemical residue. This finding must be made and the appropriate tolerance established before a
pesticide can be registered for use on the particular food or feed crop in question (USDA
APHIS, 2009).
Another potential impact of the use of glyphosate on human health is pesticide applicator
exposure related to the increased glyphosate usage. Biomonitoring of pesticide applicators
conducted by independent investigators has shown that bodiiy adsorption of glyphosate as the
result of routine, labeled applications of registered glyphosate-based agricultural herbicides to
crops, including to RRA, was thousands of times less than the allowable daily intake level
established for glyphosate (Acquavella et a!., 2004). Given similarity in use pattern and rates,
the commercialization of RRA wiii not significantly increase the exposure risk to pesticide
applicators. Furthermore, EPA, the European Commission, the WHO, and independent
scientists have concluded that glyphosate is not mutagenic or carcinogenic, not a teratogen nor
a reproductive toxicant, and that there is no evidence of neurotoxicity associated with
glyphosate (EPA, 1993; EC, 2002; WHO, 2004; Williams et al., 2000).
Bystander exposure to giyphosate as a result of pesticide application to RRA would be
negligible, since such applications would occur in an agriculturai setting in relatively rural alfalfa
fields, not in an urban setting. A biomonitoring study found little evidence of detectable
exposure to individuals on the farm who were not actively involved with or located in the
immediate vicinity of application of giyphosate-based herbicides to crops (Acquavella et al.,
2004) Considering the simiiarity of the use pattern and application rates of the glyphosate
products in this study compared to those registered for use on RRA and GT crops in general,
bystander exposure attributed to the use of giyphosate on GT crops is expected to be negligible.
4.1 0 CUMULATIVE SOCIAL AND ECONOMIC IMPACTS
As discussed above in Sec. 3.15, the potential for gene flow from RRA seed acreage to
conventional or organic alfalfa could have an adverse economic impact on conventional or
organic growers who expect to receive a premium for their crops in markets that demand non-
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RRA products. The partial deregulation measures proposed in Alternative 2, including isolation
distances associated with seed production, are specifically designed to render the risk of any
such impacts de minimis. Moreover, the reproductive biology of the alfalfa plant combined with
normal harvest management for alfalfa forage provide for a de minimis likelihood of gene flow
from one forage production field to another. Those producing organic or non-GE hay are likely
required to maintain cultivation standards required by the NOP or identity preservation contracts
that provide additional assurances against gene flow. While some of these growers may enter
into contractual agreements that require testing for the presence of GE plant material, those
tests are simple and inexpensive. Hay failing to meet contractual standards may still be sold as
commodity hay.
It is anticipated that growers who plant RRA under Alternative 2 will experience economic
benefits related to the quantity and improved forage quality of U.S. hay supplies. Growers have
reported other socio-economic benefits, including greater flexibility, safety, ease and simplicity
of weed control, APHIS has studied the potential socioeconomic impacts of fully deregulating
RRA (USDA APHIS, 2009, pp, 125-145 & Appendix S).
4.1 1 SUMMARY OF POTENTIAL CUMULATIVE IMPACTS
When considering the impact that the use of glyphosate could have on the human environment
in conjunction with other GT crops already being cultivated in the same affected environments,
the facts suggest that increased use of glyphosate on acreage that shifts from conventional or
organic alfalfa production to RRA production will have little, if any, additive effect. Alternatively,
this new use of glyphosate has the potential to reduce risks to the affected environment from the
use of other, more harmful, herbicides on these limited acreages. This is supported by the
assessment of the hazards associated with glyphosate when compared to other available
herbicides used for weed control in alfalfa production. Subsequently, there is no reasonably
anticipated adverse cumulative Impact on human health or the environment from the use of
glyphosate associated specifically with Alternative 2.
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J101 and J163: Request for Nonregulated Status, November 2009.
USDA APHIS, 2010a. U.S. Department of Agriculture, Animal and Plant Health Inspection
Service. Petitions of nonregulated status granted or pending by APHIS as of May 12,
2010. Accessed on June 26, 2010 at: http://www.aphis.usda.aov/brs/not reo.html
USDA ERS 2010b. U.S. Department of Agriculture, Economic Research Service. Field grains
database: custom query results. Accessed on August 2, 2010 at:
http://www.ers. usda.qov/Data/FeedGrains/CustomQuerv/Default.aspx#ResultsPanel .
USDA ERS 2010c. U.S. Department of Agriculture, Economic Research Service. Field grains
data: yearbook tables. Table 11: Hay: average prices received by farmers. Accessed
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USDA ERS, 2009a. U.S. Department of Agriculture, Economic Research Service. Adoption of
Genetically Engineered Crops in the U.S. updated on July 1, 2009. Accessed on June
22, 2010 at: http:/Awww.ers.usda.qov/data/biotechcrops/ .
Events J101 and J163
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Human Health and Ecological Risk Assessment: Final Report.” Technical report, USDA,
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USDA NASS 2010b. U.S. Department of Agriculture, National Agricultural Statistics Service.
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/VAC1-47F474ABB0A2 .
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Acreage, Accessed on June 26, 2010 at:
http ://usda.mannlib.cornell.edu/MannUsda/viewDocumentlnfo.do?documentlD=1 000
USDA NASS, 2009b. U.S. Department of Agriculture, National Agricultural Statistics Service.
Agricultural statistics 2008. Accessed on June 28, 2010 at:
http://www.nass.usda.oov/Publications/Aa Statistics/2008/index.asp
USDA NASS, 2009c. Alfalfa Hay (Dry) harvested Acres by County for Selected States.
Accessed on July 20, 2010 at:
http://www.nass.usda.oov/Charts and Maps/Crops Countv/pdf/AL-HA09-RGBChor.Pdf
USDA NASS, 2010c. U.S. Department of Agriculture, National Agricultural Statistics Service.
Acreage. Accessed on July 5, 2010 at:
http://usda.mannlib.cornell.edu/MannUsda/viewDocumentlnfo.do?documentlD=1000
USDA NASS. 2007. Agricultural Statistics 2006, Chapter VI - Statistics of Hay, Seeds, and
Minor Field Crops. United States Department of Agriculture, National Agriculture
Statistics Service, Washington, D.C.
USDC, 2007. USDA APHIS Roundup Readyn Alfalfa Documents. Accessed on July 19, 2010
at: http://www.aphis.usda.oov/biotechnoloav/alfalfa documents. shtml
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at:
http://www.aphis.usda.aov/biotechnoloav/downloads/alfalfa/aealfalfa Feb07 courtdecisi
on. pdf
USDC, 2007b. US District Court for the Northern District of California. Accessed July 21, 2010
at: http://www.aphis.usda.aov/brs/pdf/Alfalfa Injunction 20070312.pdf
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at: http://www.aphis.usda.aov/brs/pdf/Alfalfa Ruling 20070503.pdf
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at: http://www.aphis.usda.gov/brs/pdf/Alfalfa Amended Order 20070723.pdf
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Van Deynze, A., D.V., Putnam, S.D.H., Orloff, S., Lanini, M. T., and Canevari, R. Vargas, K.
Hembree, S. Mueller, and L. Teuber.M., 2004. "Roundup Ready Alfalfa: An Emerging
Technology.” Publication 8153, Agricultural Biotechnology In California Series. Technical
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http://anrcatalog.ucdavis.edu/pdf/8153.pdf.
Van Deynze, A.E., S. Fitzpatrick, B, Hammon, M.H. McCaslin, D.H. Putnam, L.R. Teuber and
D.J. Undersander. 2008. Gene Flow in Alfalfa: Biology, Mitigation, and Potential Impact
on Production. Special Publication 28. Council for Agricultural Science and Technology
(CAST), Ames, Iowa. 30 pp.
Waggener, R. 2007. Yellow-flowering Alfalfa Can Improve Native Rangelands, University of
Wyoming, http://uwadmnweb.uwvo.edu/UWaq/news/Yellow-Alfalfa.asp .
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Agricultural Resources and Environmental Indicators 2006 Edition.” Technical report,
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Regulatory Toxicology and Pharmacology, Vol. 31 .
Woodward, W.T.W,, Putnam, D.H. and Reisen, P. 2006. A solution for Roundup Ready Alfalfa
in sensitive export markets (Poster) Proceedings of the Washington State Hay Growers
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2004. FAO Plant Production and Protection Paper 178. World Health Organization and
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(October-December) 1998. p. 789. Accessed August 4, 2010 at:
http://www,wssa.net/Weeds/Resistance/definitions,htm
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Accessed on June 16, 2010 at: http://www.wssa.net/
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146
References
8/5/2010
1004
RECEIVED
By APHIS BRS Dttr orient ContrtflOHn^t tit i iy lir* iJjj/Cfi
Appendix
A
Monsanto Technology and Stewardship Agreement
(MT/SA)
and Accompanying Technology Use Guide (TUG)
1005
TECHNOLOGY USE GUIDE
THE SOURCE FOR MONSANTO’S PORTFOLIO
OF TECHNOLOGY PRODUCTS. STEWARDSHIP
REQUIREMENTS AND GUIDELINES FOR USE.
1007
[ M A Increased
44Bii
ion
I
■ ^ \ .
\
il “9 ^ Saved
475 Million
gallons of diesel fuel through
reduced tillage or plowing
13.3
Crown by
llion
farmers wtK’Idwide
retieblvdoetimanted
human or animal
safety Issues
h A A
Jo
becreased
359,000
metric tons*
ofpestidde applications
A f\ EltmiRsted
10 Million
metric tons
of greenhouse gas emissions
through fuel savings :
Oecreasetf
environmental impact quotient by
172 %™
Have been Ingredients tn an estlmatad
# 1,000,000,000,000
meals consumed
Source: www.biotech-gmo.com
‘t=6sHci(Sss registered by the U.S. EPA v/il! not cause onrcasortabie adverse effects to man or the environmenf when used in accordance with label ctireciions.
1008
YOUR ABILITY TO ENHANCE,
YOUR CROPS TODAY!
It’s time to ReNEW your license
If you haven’t renewed your Monsanto
Technology/Stewardship Agreement (MTSA)
in the past nine months, fake care of it today!
Signing the MTSA ensures you'll have access
to current and next-wave technologies. These
innovations will enhance plant drought tolerance,
cold tolerance, nitrogen use efficiency, yield and
much more!
1-800-768-6387, Option 3
You'll then have the option to complete the process
online or through conventional mail.
Paper MTBA’s will continue to be accepted.
Introduction
This 2010 Technology Use Guide (TUG) provides,
a concise source of technical information about
Monsanto's current portfolio of technology products
and sets forth requirements and guidelines for
the use of these products. As a user of Monsanto
Technology, it is important that you are familiar
with and follow certain management practices.
Please read all of the information pertaining to the
technology you will be using, including stewardship
and related information. Growers must read the
Insect Resistance Management (lRM)/Grower
Guide prior to planting for important information
on planting and iRM.
This technical guide is not a pesticide product label.
It is intended to provide additional information and
to highlight approved uses from the product
labeling. Read and follow all precautions and use
instructions in the label booklet and separately
published supplemental labeling for the Roundup®
agricultural herbicide product you are using.
Included In this guide is Information on the following:
Stewardship Overview
4
Introducing Genuity’”
6
Insect Resistance Management
8
Weed Management
10
Coexistence and Identity Preserved Production
12
Corn Technologies.
YieldGard® and Genuity" Corn Technologies Product Descriptions
Roundup Ready* Technology in Corn
15
Cotton Technologies
Genuity'" Bollgard i.i* and Bollgard®Colton
Roundup Ready Technologies In Cotton
21
Genuity'" Roundup Ready 2 Yield® and Roundup Ready Soybeans
.31
Genuity'" Roundup Ready* Alfalfa
. 35
Genuity'" Roundup Ready'* Spring Canola'
38:
Genuity'* Roundup Ready'® Winter Canola
39
Genuity" Roundup Ready* Sugarbeets ‘ •/
: 40
If you have any questions, contact your Authorized Retailer or Monsantd at 1-800768-6387., ,
2010 TECHNOLOGY USE GUIDE
1010
A Message About Stewardship - seed and traits
Monsanto Company is committed to enhancing farmer productivity
and profitability through the introduction of new agricultural
biotechnology traits. These new technologies bring enhanced value
and benefits to farmers, and farmers assume new responsibilities
for proper management of these traits. Farmers planting seed with
biotech traits agree to implement good stewardship practices,
including, but not limited to:
Reading, signing and complying with the Monsanto
Technoiogy/Stewardship Agreement (MTSA) and
reading all annual license terms updates before
purchase or use of any seed containing a trait.
Reading and following the directions for use on all
product labels.
Following applicable Stewardship practices as
outlined in this TUG.
Reading and following the IRM/Crower Guide prior
to planting.
Observing regional planting restrictions mandated
by the U.S. Environmental Protection Agency (EPA).
Complying with any additional stewardship
requirements, such as grain or feed use agreements
or geographical planting restrictions, that Monsanto
deems appropriate or necessary to implement for
proper stewardship or regulatory compliance.
Following the Weed Resistance Management
Guidelines to minimize the risk of resistance
development
Complying with the applicable IRM practices for
specific biotech traits as mandafed by the EPA and
set forth in this TUG.
Utilizing all seed with biotech traits only for planting
a single crop.
Selling crops or materia! containing biotech traits;
only to grain handlers that confirm their acceptance,
or using those products on farm.
Not moving material containing biotech traits across
boundaries into nations where import is not permitted,
Not selling, promoting and/or distributing within
a state where the product is not yet registered.
MONSANTO
1011
WHY IS STEWARDSHIP IMPORTANT?
Each component of stewardship offers benefits to farmers;
• Signing the MTSA provides farmers access to Monsanto’s biotech
trait seed technology.
• Following IRM guidelines guards against insect resistance to
Bacillus thuringisnsis (B.t) technology and therefore enables
the long-term viability of this technology, and meets EPA
requirements.
• Proper weed management maintains the long-term effectiveness
of glyphosate-based weed control solutions.
• Utilizing biotech seed only for planting a single-commercial
crop helps preserve the effectiveness of biotech traits,
while allowing investment for future biotech Innovations
which further improves farming technology and productivity.
Practicing these stewardship activities will enable biotechnology's
positive agricultural contributions to continue.
Farmers' attitudes and adoption of sound stewardship principles,
coupled with biotechnology benefits, provide for the sustainability
of our land resources, biotechnology and farming as a preferred
way of life.
SEED PATENT INFRINGEMENT
if Monsanto reasonably believes that a farmer has planted
saved seed containing a Monsanto biotech trait, Monsanto
will request invoices and records to confirm that fields in
question have been planted with newly purchased seed. If this
information is not provided within 30 days, Monsanto may
inspect and test all of the farmer's fields to determine if saved
seed has been planted. Any inspections will be coordinated
with the farmer and performed at a reasonable time to best
accommodate the farmer's schedule.
For more information on Monsanto’s practices related to seed
patent infringement, please visit:
www.mon 5 anto.com/seedpatentprotection.
Provide Anonymous or Confidential reports as follows;,
"Anonymous" reporting results when a person reports informa-
tion to Monsanto in such a way that the identity of the person
reporting the information cannot be identified. This kind of
reporting includes telephone calls requesting anonymity and
unsigned letters.
"Confidential" reporting results when a person, reports informa-
tion to Monsanto in such a way that the reporting person's
identity is known to Monsanto. Every effort will be made to
protect a person's identity, but it is important to understand that
a court may order Monsanto to reveai the identity of people who
are "known" to have supplied relevant information.
bmntfP
il'HfMih
'tbu'i9 Buying owe man
jusi seed. Vtu're gatang value tc^
end imavsHon (or tononaw.
eOiSfl’UilH HMWnOV. °E(>fn«UM£.
The Beyond the Seed Program
was launched by the. American
Seed Trade Association (ASTA)
to raise awareness and
understanding of the value
that goes beyond the seed.
The future success of U.S. agriculture depends upon quality
seed delivered by an industry commitment to Bring .innovation
and performance through continued investment, For more
information about seed technology, visit ASIA’S Beyond the
Seed Program at www.beyondtheseed.org.
If you have questions about seed stewardship or become aware of
individuals utilizing biotech traits in a manner other than.as noted
above, please cal! 1-800-768-6387. Letters reporting unacceptable
or unauthorized use of biotech traits may be sent to:
Monsanto Trait Stewardship
800 N. Lindbergh Boulevard NC3C
St. Louis, MO 63167
2010 TECHNOLOGY USE GUIDE |
1012
Genuity" Unites the Best Traits'
As a purchaser of Monsanto biotech trait products, your investment
helps fuel the research and development engine that leads to the
discovery and delivery of new technologies for agriculture. Current
and future Genuity™ traits are designed to deliver high yield potential,
maximize return on seed investments and consistently deliver future
trait innovations.
SOYBEAN
CORN
Higher yields come from quality grain. Genuity” VT Triple PRO“
was the next generation of corn technology available for the
2009 growing season. Genuity’" VT Triple PRO~ provides dual
modes of action against above-ground pests such as corn
earworm. European and southwestern corn borers, sugarcane
borer, southern cornstalk borer and fall armyworm. Reduced
kernel damage from corn earworm means the potential for
reduced Afiatoxin contamination, Genuity” VT Triple PRO” dual
modes-oPaction also allows for a reduction in refuge acres
required in southern cotton-growing regions while providing
long-term effectiveness and consistency.
« GENUITY'" SMARTSTAX”
Scheduled for launch in 2010, Genuity”
SmartSlax” is the most-advanced,
all-in-one corn trait system that
controls the broadest spectrum of
above- and below-ground insects and
weeds. Genuity’" SmarlSlax' provides
control of corn earworm, European
corn borer, southwestern corn borer, sugarcane borer, fall
armyworm. western bean cutworm, black cutworm, western corn
rootworm, northern corn roolworm and Mexican corn rootworm^
Genuity'” SmartStax” contains Roundup Ready* 2 Technology
and LibertyLink* herbicide tolerance. Genuity” SmartStax” also
allows for a reduction in refuge acres in the corn bell from 20%
down to 5% for above- and below-ground refuge. Genuity”
SmartStax’" is also approved for a 20% refuge in the cotton belt.
Genuity"" Roundup Ready 2 Yield* soybeans are taking yield
to a higher level. They were developed to provide farmers with
the same simple, dependable and flexible weed control and crop
safety they've come to rely on with the first:generation Roundup
Ready* soybean system, but with higher yieid potential. This is
possible because of advanced insertion and selection technologies.
COTTON
Genuity” Roundup Ready* Flex and Genuity'" Bollgard ii* offer
the ultimate combination of peace of mind and flexibility.
They contain unrivaled built-in worm control to stop the most
leaf- and boll-feeding worm species, including bollworms,
budworms. armyworms, loopers, saltmarsh caterpillars and
cotton leaf perforators. Protecting just one. additional boil
per plant can result in significantly higher lint yield. The .
convenience and savings from fewer or no sprays for worms
can make a big difference whan it comes to the bottom line,
SPECIALTY
Genuity” Roundup Ready® alfalfa: Bred from an innovative
germpiasm pool, it offers outstanding weed control, excellent
crop safety and preservation of forage quality potential.
Genuity" Roundup Ready® canola: Offers exceitent control
of broadfeaf weeds and grasses, even in tough weather
conditions. Also features excellent crop safety and broad
application flexibility.
Genuity" Roundup Ready* sugarbeets: Excellent in-plant
tolerance to over-the-top applications of labeled Roundup
agricultural herbicides. Offers outstanding weed control,
excellent crop safety and preservation of yieid potential.
-See pages 16 and U for aiWitinridl Itafts.
NOTfi: farmers must read Ihe IR.M/Crower Guide prior to piantirg for irrfwwiationdo EtenCmg and insecl Re^larrce Managertwot
MONSANTO
Monsanto’s New Generation of Technologies
As Monsanto continues to develop new generations of technologies,
several of our newer technologies are migrating to the Genuity™ brand.
These products and their new logos are presented below.
, . StaOTma -
VmUBarii^ i $1^
Triple PRO
I tesm
5*1 ■ -
CORN
1 SOYBEANS
SPECIALTY
crawtttfKi
2010 TECHNOLOGY USE GUIDE
1014
INSECT RESISTANCE MANAGEMENT (IRM)
An EFFECTIVE IRM program is a vital part of
responsible product stewardship for insect-
Plaatlng Bihiges, Presenting Tashnokgy protected biotech products. Monsanto is committed
to implementing an effective IRM program for all of its insect-
protected B.t. technologies in all countries where they are
commercialized, including promoting farmer awareness of these
IRM programs. Monsanto works to develop and implement IRM
programs that strike a balance between available knowledge and
practicality, with farmer acceptance and implementation of the plan
as critical components.
The U,S. EPA requires that Monsanto implement, and farmers
who purchase insect-protected products follow, an IRM plan.*
IRM programs for B.t traits are based upon ari assessment of the
biology of the major target pests, farmer needs and practices,
and appropriate pest management practices. These mandatory
regulatory programs have been developed and updated through,
broad cooperation with farmer and consultant organizations,
including the National Corn Growers Association and the National
Cotton Council, extension specialists, academic scientists, and
regulatory agencies.
a natural retuqe option is available tor Dollyard ll.SetSIbe c«re<< IRM/Croiwr Guide for rfetaBs.
MONSANTO
1015
The IRM programs for planting seeds containing B.t. traits contain
several important elements. One key component of an IRM
plan is a refuge. A refuge is simply a portion of the relevant
crop (corn or cotton) that does not contain a B.L technology
for the control of the insect pests which are controlled by the
planted technology(ies). The lack of exposure to the B.t protans
means that there will be susceptible insects nearby to mate
with any rare resistant insects that may emerge from Rt.
products. Susceptibility to 8.f. products is then passed on
to offspring, preserving the long-term effectiveness of
the technology.
Farmers who purchase seeds containing S.f. traits must plant an
appropriately designed refuge. Refuge size, configuration, and
management is described in detail in the sections on those
products in the 2010 IRM/Grower Guide.
Failure to follow IRM requirements and to plant a proper
refuge may result in the loss of a farmer's access to Monsanto
technologies. Monsanto is committed to the preservation of
B.t. technologies. Please do your part to preserve B.t technologies
by implementing the correct IRM plan on your farm.
MONITORING PROGRAM
The U.S. EPA requires Monsanto to take corrective measures in
response to a finding of IRM non-compliance. Monsanto or an
approved agent of Monsanto must monitor refuge management
practices. The MTSA signed by a farmer requires that upon
request by Monsanto or its approved agent, a farmer must
provide the location of all fields planted with Monsanto
technologies and the locations of all associated refuge areas
as required, to cooperate fully with any field inspections, and
allow Mo.nsanto to inspect all fields and refuge areas to ensure
an approved Insect resistance program has been followed. All
inspections will be performed at a reasonable time and arranged
in advance with the farmer so that the farmer can be present
if desired.
IRM GUIDEIINES
read the current iRM/Grower Guide prior fo piahting for Information on
planting and iRM. if you do not have a copy of the current IRM/Grower Culde. you may
■ downloaded It at www.mon8anto.eom, or you may call 1*800-768:6387 to request a copy
h
r
2010 TECHNOLOGY USE GUIDE
Monsanto considers product stewardship to be a fundamental
component of customer service and responsible business practices.
As leaders in the development and stewardship of Roundup*
agricultural herbicides and other products, Monsanto invests
significantly in research to continuously improve the proper uses
and stewardship of our proprietary herbicide brands.
This research, done in conjunction with academic scientists,
extension specialists and crop consultants, includes an evaluation
of the factors that can contribute to the development of weed
resistance and how to properly manage weeds to delay the
selection for weed resistance. Visit www.weedtool.com for
practical, best practices-based information on reducing the risk
for development of giyphosate-resistant weeds. Developed
in cooperation with academic experts, the website provides
options for managing the risk on a field-by-fietd basis.
Glyphosate is a Group 9 herbicide based on the mode of action
classification system of the Weed Science Society of America.
Any weed population may contain plants naturally resistant to
Group 9 herbicides. The following general recommendations
help manage the risk of weed resistance occurring.
WEED RESISTANCE MANAGEMENT PRACTICES:
• Scout your fields before and after herbicide application
• Start with a clean field, using either a burndown herbicide
application or tillage
• Control weeds early when they are small
• Add other herbicides (e.g. a selective in-crop and/or a residual
herbicide) and cultural practices <e.g. tillage or crop rotation) as
part of your Roundup Ready* cropping system where aptH-opriate
• Rotation to other Roundup Ready crops will add opportunities for
introduction of other modes of action
• Use the right herbicide product at the right rale and Ihe right time
• Control weed escapes and prevent weeds from setting seeds
• Clean equipment before moving from field to field to minimize
spread of weed seed
• Use new commercial seed that is as free from weed seed
as possible
Monsanto is committed to the proper use and long-term
effectiveness of its proprietary herbicide'brands through a
four-part stewardship program; developing appropriate weed
control recommendations, continuing research to refine and update
recommendations, education on the importance of good weed
management practices and responding to repeated weed control
inquiries through a product performance evaluation program.
GLYPHOSATE-RESISTANT WEEDS
Monsanto actively investigates and studies weed.controi
complaints and claims of weed resistance. When giyphosate-
resistant weed biotypes have been confirmed, Monsanto alerts
farmers and develops and provides farrriers wlth recommended
control measures, which may include additional herbicides,
tank-mixes or cultural practices. Monsanto actively communicates
all of this information to farmers through multiple channels,
including the herbicide label, www.weedscience.org, supplemental
labeling, this TUG, media and written communications,
Monsanto's website, www.weedresistancemanagement.com,
and farmer meetings.
farmers must be aware of. and proactively manage for,
giyphosate-resistant weeds in planning their weed control
program. When a weed is known to be resistant to glyphosate,
then a resistant population of that weed is by definition no
longer controlled with labeled rates of glyphosate. Roundup®
agricultural herbicide warranties will not cover the failure to
control giyphosate-resistant weed populations.
Report any incidence of repeated non-performance on a
particular weed to your local Monsanto representative, retailer
or county extension agent.
Always and follow all pesticldt label rsQulremeiUs.
MONSANTO
1017
ROUNDUP BRAND AGRICULTURAL OVER-THE-TOP HERBICIDE PRODUCTS
Rcdcf fo!!d->y aii prcddct l3t>?iinq before fi'si!ig:RQunaiip agrfcuitural herbkWes over the too of oroaLjcts wltb Roin'cl
ffeody Technology.
■ ^. ■ ; ,, '■ I
You iTsay use rinoHier glyohosate herbicide^ butonty if It has flderaliy approved label inst'uctKjns fo* use oyerthr.t
specific Sour.dup Ready crop, arso tne product and the use fatpiforthat Roundup Ready cop has oeyn aupfcvea
by your saecific state, Contact the procl,jct Rianufactyrers, thl locafretailers or the tocaf axtenslon agents (o'-
confirmatfon that tne products carry FPA arid state ^provediabelkg toHbk use, MONSANTO DOES NOT MAKE
ANY REPRESENTATIONS, WARRANTIES OR RECOMMEMdItIONS CONCERNING THE USE OrOLYPHOSATE
PRODUCTS SUPPLIED BY OTHER COMPANIES WHICH ARitASELED FOR USE OVER ROUNDUP READY
CROPS. MONSANTO SPECIFICALLY DENIES ALL RESPONfBILITY AND DISCLAIMS ANY LIABILITY
FOR ANY DAMAGE FROM THE USE CF THESS PRODUCTS (N ROUNDUP READY CROPS. ALL OOESTIONS
AND OOMPIAINTS'CAUSEP BY THE USE OF OLYPHOSATE|pr0DUCTS SUPPLIED BY OTHER COMPANIES
should BE DIRECTED TO THE SUPPLIER OF THE PRODU'tT IN QUESTION,
&
MONSANTO BRANDS OF SELECTIVE OVER-THE-TOP
HERBICIDE PRODUCTS
Herbicide products sold by Monsanto for use over the top of
Roundup Ready crops for the 2010 crop season are as follows:
Roundup WeatherMAX® Roundup PowerMAX*
Read and follow all product labeling before using Roundup
agricultural herbicides over the top of Roundup Ready traits.
To ieam rhore about applicable supplemental labels or fact
sheets, cain-800-768-6387,
Tank-mixtures of Roundup agricultural herbicides with insecti-
cides, fungicides, micronutrients or foliar fertilizers are not
recommended as they may result in reduced weed control,
crop injury, reduced pest control or antagonism. Refer to the
Roundup agricultural herbicide product label, supplemental
labeling or fact sheets published separately by Monsanto for
tank-mix recommendations.
Do not add additional surfactants and/or products containing
surfactants to these Roundup agricultural herbicides unless
otherwise directed by the label. Other glyphosate products
labeled for use in Roundup Ready technologies may require
the addition of surfactants, or other additives to optimize
performance, that may increase the potential for crop injury.
Monsanto will label and promote only fully tested brands that
do not require surfactants and other additives for over-the-top
applications to Roundup Ready Crops.
GLYPHOSATE ENDANGERED SPECIES INITIATIVE
Before making applications of glyphosate-based herbicide
products, licensed farmers of crops containing Roundup Ready ..
technology must access the website www.pre-serve.org to
determine whether any mitigation requirements apply to the
planned application to those crops, and must follow all applicable
requirements. The mitigation measures described on the website
are appropriate for all applications of glyphosate-based
herbicides to all crop lands.
Farmers making only ground applications to crop land with
a use rate of less than 3.5 lbs of giyphosate a.e./A are not
required to access the website. If a farmer does not have web
access, the seed dealer can access the website on behalf of
the farmer to determine the applicable requirements, or the
farmer can call 1-800-332-3111 for assistance.
1018
COEXISTENCE AND IDENTITY PRESERVED PRODUCTION
1
1 I.
. -r . .r ^ 1
Coexistence in agricultural production systems and supply
chains is not new. Different agricultural systems have coexist^j
successfully for many years around the world. Standards
and best practices were established decades ago and have
continually evolved to deliver high purity seed and grain to
support production, distribution and trade of products from
different agricultural systems. For example, produch’on of simifar
commodities such as field corn, sweet corn and popcorn has
occurred successfully and in close proximity for many years.
Another example is the successful coexistence of oilseed rape
varieties with low erucic acid content for food use and high
erucic acid content for industrial uses.
The responsibility for implementing practices to satisfy specific
marketing standards or certification lies with that farmer who
is growing a crop to satisfy a particular market. Only that farmer
is instructed to employ the practices appropriate to assure the
integrity of his/her crop. This is true whether the goal is high-oil
corn* white/sweet corn or organically produced yellow corn for
animal feed, (n each case, the farmer is seeking to produce a
crop that is supported by a market price and consequently that
farmer assumes responsibility for satisfying reasonable market
specifications. That said, the farmer needs to be aware of the
planting intentions of his/her neighbor in order to gauge the
need for management practices.
The introduction of biotech crops generated renewed discussion .. .
of coexistence focused on biotech production systems with
conventionar cropping systems and organic production. These :.
discussions have primarily focused on the potenttai economic
impact of the introduction of biotech products on other systems.
The health and safety of biotech products are not an issue
because their food, feed and environmental safety must be
demonstrated before they enter the agricultural production
system and supply chain.
The coexistence of conventional, organic and biotech crops has
been the subject of several studies and reports. These reports
conclude that coexistence among biotech and non-biotech
crops is not only possible but is occurring. They recommend
that coexistence strategies be developed on a case-by-case basis
considering the diversity of products currently in the market and
under development, the agronomic and biological differences in
the crops themselves and variations in regional farming practices
and infrastructures. Furthermore, coexistence strategies are
driven by market needs and should be developed using current
science-based industry standards and management practices.
The strategies must be.flexibfe, facilitating options and choice for
the farmer and the food/feed supply chain, and must be capable
of'being modified as changes In markets and products warrant.
Successful coexistence of all agricultural systems is achievable
and depends on cooperation, flexibility and mutual respect for
each system. Agriculture has a history of innovation and change,
and farmers have alv/ays adapted to new approaches or chai-
fenges by utilizing appropriate strategies, farm management
practices and new technologies.
IDENTITY PRESERVED PRODUCTION
Sonfie farmers may choose to preserve the identity of tneir crops
to meet specific markets. Examples of identity Preserved (l,P.)
corn crops include production of seed corn, white, waxy or sweet
corn, specialty oil or protein crops, food grade crops and any
other crop that meets specialty needs, including organic and
non-genetlcally enhanced specifications. Farmers of these crops
assume the responsibility and receive the benefit for ensuring
that their crop meets mutually agreed contract specifications.
Based on historical experience with a broad range of I.P. crops,
the industry has developed generally accepted I.P.- agricultural
practices. These practices are intended to manage I.P. production
to meet quality specifications, and are established for a broad
range of I.P. needs. The accepted practice with I.P. crops Is that
each I.P. farmer has the responsibility to impfement any neces-
sary processes. These processes may include sourcing seed
appropriate for I.P. specifications, field management practices
such as adequate isolation distances, buffers between crops,
border rows, planned differences. in maturity between. adjacent .
fields that might cross-pollinate and harvest and handling
practices designed to prevent mixing and. to maintain product
quality. These extra steps .associated with t.P. crop production
are generally accompanied by incremental increases In cost
of production and consequently of the goods sold.
MONSANTO
1019
General Instructions for Management
of Pollen Flow and Mechanical Mixing
For ali crop hybrids or varieties that they wish to identity
preserve, or otherwise keep separated, farmers should take steps
to prevent mechanical mixing. Farmers should make sure ail seed
storage areas, transportation vehicles and planter boxes are
cleaned thoroughly both prior to and subsequent to the storage,,
transportation or planting of the crop. Farmers should also make
sure all combines, harvesters and transportation vehicles used at
harvest are cleaned thoroughly both prior to and subsequent to
their use in connection with the harvest of the grain produced
from the crop. Farmers should also make sure ali harvested grain
is stored in clean storage areas where the identity of the grain
can be preserved.
Seif-poliinated crops, such as soybeans, do not present a risk
of mixing by cross-pollination, if the intent is to use or market
the product of a self-poliinated crop separately from general
commodity use, farmers should plant fields a sufficient distance
away from other crops to prevent mechanical mixture.
Farmers planting cross-pollinated crops, such as corn or alfalfa,
who desire to preserve the identity of these crops, or to minimize
the potential for these crops to outcross with adjacent fields
of the same crop kind, should use the same generally accepted
practices to manage mixing that are used in any of the currently
grown l.P. crops of similar crop kind.
It is generally recognized in the industry that a certain amount
of incidental, trace level pollen movement occurs, and it is not
possible to achieve 100% purity of seed or grain in any corn
production system. A number of factors can influence the
occurrence and extent of pollen movement. As stewards of
technology, farmers are expected to consider these factors and
talk with their neighbors about their cropping intentions.
Farmers should take into account the following factws that can
affect the, occurrence and extent of cross-pollination to or from
other fields, information that is more specific to the crop and
region may be available from state extension offices.
* Cross-pollination Is limited. Some plants, such as potatoes, are
incapable of cross-pollinating, while others, like alfalfa, require
cross-poilination to produce seed. Importantly, cross-poilination
only occurs within the same crop kind, like corn to corn.
The amount of pollen produced within the field can vary. The
pollen produced by the crop within a given field, known as pollen
load, is.typicaily high enough to pollinate all of the plants in the
field. Therefore, most of the pollen that may enter from other
fields falls on plants that have already been pollinated with pollen
that originated from plants within the field. In crops such as alfalfa,
the hay cutting management schedule significantly limits or
eliminates bloom, and thereby restricts the potential for pollen
and/or viable seed formation.
The exist«>ce and/or degree of overlap in the pollination period
of.crops in adjacent fields varies. This will vary depending on the
maturity of crops, planting dates and the weather, For corn, the
typical pollen shed period lasts from 5 to 10 days for a particular
field. Therefore, viable pollen from neighboring fields must be
present when silks are receptive in the recipient field during this
brief period to produce any grain with traits introduced by the
out-of-field pollen.
Distance between fields of different varieties or hybrids of the
same crop: The greater the distance between fields the less likely
their pollen will remain viable and have an opportunity to mix
and produce an outcross. For wind-poliinsted crops, most cross-
pollination occurs within the outermost few rows of the field.
In fact, many white and waxy corn production contracts ask the
farmer to remove the outer 12 rows (30 ft.) of the field in order
to remove most of the impurities that could result from cross-
pollination with nearby yellow dent corn. Furthermore, research
has also shown that as fields become further separated, the
incidence of wind-modulated cross-polilnation drops rapidly.
Essentially, the in-field pollen has an advantage over the pollen
coming from other fields for receptive silks because of its volume
and proximity to silks.
The distance pollen moves. How far pollen can travel depends oh
many environmental factors, including weather during pollination,
especially wind direction and velocity, temperature and humidity,.
For bee-pollinated crops, the farmer's choice, of pollinator species
and apiary management practice. may reduce field-toTield
pollination potential. All these factors will vary from season to
season, and some factors frotti day to day and from location
to location.
For wind-pollinated crops, the orientation and width of the ..
adjacent field In relation to the dominant wind direction. Fields,
oriented upwind during pollination will show dramattcally lower
cross-pollination for wind-poliinated crops, like corn, compared
to fields located downwind.
2010 TECHNOLOGY USE GUIDE I
1020
1021
Advanced breeding and biotechnology have had a major impact on
farming production. From 1971 to 1995, average corn yields were
increasing at a rate of 1.5 bushels per acre, per year. Since the advent
of biotech in 1996, corn yields have increased at a rate of 2.6 bushels
per acre, per year, for a total increase of 32 bushels per acre.*
Excellence Through Stewardship
Monsanto Company is a member of Excellence Through
Stewardship® (ETS). Monsanto products are commercialized
in accordance with ETS Product Launch Stewardship Guidance,
and in compliance with Monsanto's Policy for Commercialization
of Bigtechnology-Derived Plant Products in Commodity Crops.
This product has been approved for import into key export
markets with functioning regulatory systems. Any crop or
material produced from this product can only be exported to,
or used, processed or sold In countries where ail necessary
regulatory approvals have been granted, it is a violation of
national and international law to move material containing
biotech traits across boundaries into nations where import
is not permitted. Growers should talk to their grain handler
or product purchaser to confirm thetr buying position for this
product. Excellence Through Stewardship® is a registered
trademark of Biotechnology Industry Organization.
\nM
For specific refuge regulrements for •
B.t com and cotton, see the current
IRM/Grower Guide, sent with this TUG.
If you have not received a copy of V -
this Guide; it can be downloaded at '
www.monsanto;eom..Qr call 1*800*768*6387
to reguesta copy be mailed to you.
Before opening a bag of seed, be sure to read and understand the stewardship requirements, ittduding
applicable refuge requirements for insect resistance management, hir the biotechnology traits expressed in
the seed as set forth in die Monsanto Technology Agreement that you sign. By opening and using a bag of seed,
you are reaffirming your obligation to comply with those stewardship requirements.
*USDA Yields were crilculaled using 3 vsar rodinQ averages(32 Yield is 3.6 bu/ac *12 2008 Viefd is tram Ooaneftq Services forecasl in April a 2008 Ouarterly Crop Outlook.
2010 TECHNOLOGY USE GUIDE ;
1022
Genuity" Trait Products and YieldGard® Corn Technologies Product Descriptions
GENUITY" SMARTSTAX"
Scheduled to launch in 2010, Genuity SmartStax" is the most
advanced, ati-in-one corn trait system that controls the broadest
spectrum of above- and belowground insects and weeds, ^nuity”
SmartStax“ hybrids will contain B.t. proteins that represent three
separate modes of action for control of lepidopteron. above-
ground insect pests, as well as combined modes of action for
control of coleopteran, beiow-ground insect pests. Providing
multiple at. proteins for control will dramatically decrease the
probability that insects will become resistant to the traits,
resulting in enhanced durability of transgenic insect control via
B.t genes. Based on this multiple gene approach. Genuity'*
SmartStax”* is approved for reduced refuge in the corn belt from
20% down to 5% for both above- and below-ground pests. The
cotton belt refuge for Genuity SmartStax" Is also reduced, from
50% down to 20%.
GENUITV'-VT TRIPLE PRO'“
{Formerly YieldGard VT Triple PRO'") -Genuity“‘VT Triple PR0~
is available in. selected southern corn- and cotton-growing areas.
It includes broad-spectrum insect control against corn earworm,
European and southwestern corn borers, sugarcane borer,
southern cornstalk borer, fall armyworm, western com rootworm,,
northern corn rootworm and Mexican corn rootworm. Its
advanced control of ear pests can result in higher grain quality
and higher-yielding crop potential. The dual mode-of-action of
Genuity" VT Triple PRO" allows for lower corn borer refuge acres
in southern cotton-growing areas compared to other registered
af.-tratted products, it includes the same Roundup Ready* 2
Technology as Monsanto's previous product, YieldGard VT Triple.
Seed containing Genuity'” VT Triple PRO" technology is treated
with seed-applied insecticide.*
VieUEard^
Triple
YIELDGARD VT TRIPLE*
YieldGard VT Triple technology combines YieldGard Corn Borer
and YieldGard VT Rootworm/RR2* technology into a single plant
YieldGard VT Triple corn hybrids control European and south-
western corn borer, sugarcane borer, southern cornstalk borer,
western corn rootworm. northern corn rootworm and Mexican
corn rootworm. YieldGard VT Triple technology suppresses corn
earworm, fall armyworm and stalk borer. By providing in-plant
protection against the above Insect pests, the genetic yield
potential of YieldGard VT Triple corn hybrids is preserved.
YieldGard VT Triple corn hybrids also include Roundup Ready 2
Technology. This trait allows a farmer to experience the benefits
of utilizing Roundup agricultural herbicides in a weed control
system that provides the broadest weed control spectrum
available, better application flexibility, and superior crop safety.-
Seed containing YieldGard VT Triple technology is treated with
seed-appfied Insecticide.*
GENUITY" VT DOUBLE PRO”
Genuity” VT Double PRO” is a new corn technology scheduled
for launch in 20K). It includes broad-spectrum insect control
against corn earworm. European and southwestern corn borers,
sugarcane borer, southern cornstalk borer and fail armyworm.
The dual mode-of-actlon of Genuity” VT Double PRO” eiiows tor
lower corn borer refuge acres compared to other registered
af.-traited products. Seed containing Genuity” VT Double PRO”
technology is treated with seed-applied insecticide.*
*Ase«FappH(>tlinsecllQde can protect seed, roots and seedlings from insects such as blacN
cutworm, wireworm. while grubs, seed corn reaggols, chinch hug and early flea beetles.
MONSANTO
1023
VieUEanl^^
YiELOGARD VT RQOTWORM/RR2®
YieldGard VT Rootworm/RR2 technology is the ci^rent TieldGard stacked-trait product for control of western corn rootworm,
northern corn rootworm and Mexican corn rootworm. Protecting the root of. the corn plant from feeding by corn rootworm larvae
decreases lodging and protects the genetic yield potential of YieldGard VT Rootworm/RR2 corn hybrids. The Roundup Ready 2
Technology allows a farmer to experience the benefits of utilizing Roundup agricultural herbicides in a weed control system that
provides the broadest weed control spectrum, better application fiexibility and superior crop safety. Seed containing YieldGard VT
Rootworm/RR2 technology is treated with seed-applied insecticide.*
YIELDGARD* CORN BORER
YieldGard Corn Borer corn hybrids contain an insecticidal
protein from B.t that protects corn plants from European
corn borer, southwestern corn borer, sugarcane borer and
southern cornstalk borer resulting in full yield potential.
insect Proteetloa
YIELDGARD PLUS
YieldGard Plus corn technology corribineS YfeidGard
Corn Borer and YieldGard Rootworm technology
Into a single plan.
YIELDGARD ROOTWORM
YieldGard Rootworm corn hybrids contain an insecticidal
protein from B.t that protects corn roots from larva!
feeding by western, northern and Mexican corn rootworm.
03 .
YIELDGARD® CORN BORER WITH
ROUNDUP READY* CORN 2
YieldGard Corn Borer with Roundup Ready Corn 2 offers
farmers all the benefits of both traits combined in one crop,
These hybrids exhibit the same insect protection qualities as
YieldGard Corn Borer and, like Roundup Ready Corn 2, are tolerant
to over-the-top applications of Roundup* agricultural herbicides.
I iDMCteraiKeDa
YIELOGARD PLUS WITH ROUNDUP READY CORN 2
YieldGard Plus with Roundup Ready Corn 2 offers farmers al( the
benefits of all three traits combined in one crop. These hybrids ..
exhibit the same insect protection qualities of YieldGard Corn .
Borer and YieldGard Rootworm and. like Roundup Ready Corn 2,
are tolerant to over-the-top applications of Roundup* agricultural, '
herbicides. Seed containing YieldGard Plus technology Is treated .
with seed-applied insecticide.*
i ilMOy.
t<r-iT2
YIELDGARD ROOTWORM WITH
ROUNDUP READY CORN 2
YieldGard Rootworm with Roundup Ready Corn 2 offers farmers
all the same insect protection qualities as YieldGard Rootworm
and, like Roundup Ready Corn 2, is tolerant to over-the-top '
applications of Roundup agricultural herbicides.
2010 -TECHNOLOGY USE GUIDE |
1024
ROUNDUP READY® Technology in Corn
WEED CONTROL RECOMMENDATIONS
Roundup Ready* Corn 2 (RR2) and corn with Roundup Ready*
2 Technology are equivalent in their tolerance to Roundup
agricultural herbicides. Products with Roundup Ready Technology
contain in-piant tolerance to Roundup agricultural herbicides.
The Roundup Ready® Technoiogy system's flexibility, broad-
spectrum weed control and proven crop safety offer farmers
weed control programs that allow them to use the system in the
way that provides the greatest benefit. Farmers can selectthe
program that best fits the way they farm. Options include. the use
of a residual herbicide with
a Roundup* agricultural
herbicide, tank-mixing other
herbicides with Roundup
agricultural herbicides where
appropriate and a total
postemergence program.
AGRONOMIC PRINCIPLES
Corn yield is very sensitive to earlyseason weed competition.
Weed control systems must provide farmers the opportunity to
control weeds before they become competitive. The Roundup
Ready Technology system provides a mechanism to control
weeds at planting and once they emerge. Farmers are provided
excellent crop safety and full yieid potential, with applications
made from planting through 48" of corn height. Drop nozzles
must be used between 30" and 48" of corn height. Failure to
control weeds with the right rate, at the right time and with
the right product, can lead to increased weed competition,
weed escapes and the potential for decreased yields. Use
other approved herbicide products with Roundup agricultural
herbicides if appropriate for the weed spectrum.
HiW
UsethepfogerRoundupReadyRATr’dlBullet*.
Degree*?, Degree Xtra*. Harness* Harness Mra, Harness
Xtra 5.a. Micro-Tecti". or Lariat® (no post) as defined in
the table below and the individual {^oduct labels, »tl)er |
pre or postemergence to the crop.** , |
, Fonowwith Roundup WeathsrMAX at )6 to 22 d;/a
post seguentially after preemergence application or li-js'
ianl^rnixed in*crop with the readual. /^plications
.^puld be made before weeds exceed 4" in height, \;M;y
: Rpunddp.ReadvRATEs'** | ji
mm.
HeSMu^.HerUcI^::
Plus Roundup
WeatherMAX*
Harness Xtn
MJcfo-Iech .
f .s^pIdBertjl Mti fM list Sradcl to astermine >1 winj Saundus PoweiMXS®,
: (oRouwliei Rtaer Corn i. Tallow oH label >
1025
WEED RESISTANCE MANAGEMENT FOR CORN
WITH ROUNDUP READY TECHNOLOGY
Follow aii pesticide label requirements and the guidelines Below
to minimize the risk of developing glyphosate-resistant weed
populations in a Roundup Ready Technology system,
• Start clean with a burndown herbicide or tillage. Eariy-season
weed control is critical to yield.
• Apply pre-emergence residual herbicides such as Harness Xtra,
Degree Xtra or other residual herbicides at the recommended rate.
Or apply a pre-emergence residuai herbicide at the recommended
rate tank-mixed with Roundup WeatherMAX® at a minimum of
22 oz/A in-crop before weeds exceed 4" in height.
Follow with a postemergence in-crop application of Roundup
WeatherMAX at a minimum of 22 oz/A for additional weed
flushes before they exceed 4“ in height.
Roundup WeatherMAX may be tank-mixed with other herbicides
for postemergence weed control.
Report repeated non-performance to Monsanto or your
local retailer.
WEEDS
mSTRUCTfONS AND USE RATES'
2010 TECHNOLOGY USE GUIDE
RECOMMENDATIONS FOR MANAGING GLYPHOSATE-RESISTANT WEEDS IN PRODUCTS
WITH ROUNDUP READY TECHNOLOGY
1026
1027
Genuity'" Bollgard 11® and Bollgard* Cotton Descriptions
genuity
I
B^n
GENUITY'“ BOLLGARD II* COTTON
Genuity" Boilgard 11* cotton contains two distinct insecticidal
proteins from Bacillus ffiuring/ens/s (B.t) that increase the efficacy
and spectrum of control and reduce the chance that resistance
will develop to the B.t. insecticidal proteins, relative to Boilgard*
cotton. Genuity'" Boilgard II® cotton normally provides excellent,
season-long control of tobacco budworm, pink boilworm and
cotton boiiworm. Genuity” Bollgard IP cotton provides good
protection against fait armyworm. beet armyworm. cabbage
and soybean ioopers and other secondary leaf- or fruit-feeding
caterpillar pests of cotton. Applications of insecticides to
control these insects are substantially reduced with Genuity”
Bollgard IP cotton.
Boll3afd
BOLLGARD* COTTON
Bollgard cotton contains a single insecticidal protein from
fi.f. that provides good control against three major lepidopteran
insect pests of cotton. Specifically, Bollgard cotton provides
excellent, season-long control of tobacco budworm and pink
boilworm, and suppression of cotton boilworm. When the
above-mentioned insect larvae feed on Bollgard cotton plants,
the B.f. protein protects the plants from damage by reducing
larval survival. Under high infestation, application of insecticides
may be necessary to protect Bollgard cotton.
BOLLGARD PHASE OUT
The U.S. Environmental Protection Agency has mandated
the following terms and conditions:*
• Dollqiird* cotton may be sold tlirough SeptemtwS^^TOS^After that
(Into, nil sales ol [iotlqard cotton ore
• AH Bollgard cotton seed most bo planted by
(the expiration dale of the Bollgard cotton
2010, planting of Bollgard cotton seed is proNbit^^"'''^*'
seed not planted on or before July 1, 2010,
the retailer or to Monsanto. No rehinds are tel
cotton seeds bought For planting (n 20T0 and
• An adequate amount of refuge seed must bfi
' an appropriate refuge for 8c>ligard cotton.
with the Bollgard cotton seed is mandatory.
: purchased by growers in advance of their
seed. Any seed purchased for uie as a refuge Is norH-efvfWfabla,
unless the proportional amotmlof abi!g8rd cotlon'i«d thafthe
refuge seed would have supported is returned at thasame timet -
Any order for repiac«nent:or edditional BoHgafd cottortseedTor
the 2010 planting season, that does not conform to the r^qulremerits' -.^
stated above must be filled with Genuity* Bollgard It* cotton sehd
(or other products with current registrations).
On-farm IRM assessments will be conducted during ttie planting season.
In 2010, Bcrftgard cotton may only be planted in. Alabama. Arkansai <
Florida (North of norida Route 60), Goo'gia Kentucky. Louisiana^
Maiytend,.Miss(KiriMfss|^i^i,t^rth.CarDKn% South Carolina.
TeraiesieR Texas (exdodlngttie ten ph««&ited Teitas paohamSe counties
Ob Oafiarn. Sherman. ttenslOfd. 6chiltiee,,Upscomii Hafttev>.Wcore>'s:t«
Hutchinswi Roberts. .^Carsor; .tnu v.rgtncr
•it is a violation of federal law to sell or distribute an unregistered pesticide.
NOTE: Sale or commercial planting of Bol!gard®cotton is prohibited in,
certain states,' including: Arizona, California, Colorado. Kansas, New Mexico
and Oklahoma.
Sale or planting of Bollgard is prohibited in the Texas cowftfes of: Cars*i,
Dallam, Hansford, Hartley, Hutchison, Lipscomb, Moore, Ochiltree, Roberts,
ana Sherman.
The at. efeffa endotor/n protetn expressed in this cotton targets certain cotton
insect pests. Routine applicatiorts of insecticides to control certain Insects are
usually unnecessary when cotton containing the at. delta endotoxin protein is
planted. However, if insecticide applications are necessary to control certain
cotton insect pests, follow all label requirements.
Sateor commercial planting of both Genuity' Bollgard ligand Boflgard
is prohibited in Hawaii, Puerto Rico, the U.S. Virgin Islands, and irv.nwkla ,
south of Route 60 (near Tampa).
2010 TECHNOLOGY USE GU
1028
Genuity”' Bollgard If and Bollgard* Cotton
INSECT RESISTANCE MANAGEMENT (IRM)
Lepitiopteran cotton pests have demonstrated the ability
to develop resistance to many chemical insecticides. As a pre- '
emptive measure, Genuity"" Bollgard 11“ and Bollgard* cotton must
be managed in ways that will retard insect resistance, dev^opment.
These practices are designed to ensure that some iepfdofrferan
populations are not exposed to the at. proteins so they can
maintain susceptibility in select populations. In order to achieve
this, refuge cotton that does not contain at. proleir^s must
be planted.
GENUITY^” BOLLGARD 11 « DUAL EFFECTIVE DOSE
Resistance management is critical to the long-term viability
of our technology and the benefits realized by our farmer
customers. 2010. is a transition year for Monsanto af. cotton
.products as we shift all U.S. cotton acres toward the two-gene
Insect control product, Genuity™ Bollgard IP cotton. The move
to.muttipie-gene products, including Genuity"" Bollgard IP. offers
dual effective modes of action against target insect pests.
Increasing the longevity of the technology.
INTEGRATED PEST MANAGEMENT tIPM)
Integrated Pest Management (IPM) Is an effective and environ-
mentally 5€nsiliye.approach to pest management that relies
on acom.binatipn of common-sense, practices. IPM programs use
current, comprehensive information on the life cycles of pests
and their interaction with the environment. This information
is used to manage pests in a manner that is least harmful
to people, property and the environment.
Prevention
Using the best agronomic management practices in conjunction
with the appropriate cotton varieties wlli yield the greatest benefits.
Use varieties, seeding rates and planting technoiogies
appropriate for each specific geographical area. As much
as possible, manage the crop to avoid plant stress^
• Employ appropriate scouting techniques and treatmentdecisions
to preserve beneficial insects that can provide addiflonal insect,
pest control.
• Manage for appropriate maturity and harvest schedules, destroy
^ks immediately after harvest to avoid regrowth and minimize
selection for resistance in late-ssason infestations.
• Use soil management practices that encourage destruction
of over-wintering pupae.
Monitor and Identify
Ffelds should !» carefully monitored for all pests, including cotton
boilworms, to determine the need for remedial insecticide treat-
ments. For target pests, scouting techniques arid supplemental ,
treatment decisions should take, into account the fact that larvae
must hatch and feed before they can be affected by the B.t.
proteinfs) in either Genuity"" Bollgard il* or Bollgard cotton. Fields
should be scouted regularly, foilowing periods of heavy or sustained
egg lay, especially during bloom, to determine if significant larval
survival has occurred. Scouting should incfudea modified whole-
plant inspection, including terminals, squares, blooms, bloom tags
and small bolls. Larvae larger than 1/4 inch (3- to 4-days old) are
generally recognized as survivors that may not be controlled
by Genuity * Bollgard ii* or Bollgard cotton.
I Read the IRM/Grower Guide prior to planting for infor-
I matron on planting and iniect Resistance Management.
; if you do not have a copy of this Guide, you may download
if at www.monsant<Kcom, o'- call 1*800-766*63B7 to
I request a copy by man.
Control
Monsanto recommends the use of appropriate remedial
insecticide treatments to. ensure desired levels of control
if any cotton insect pest reaches locally estabiished thresholds
in Genuity'" Bollgard il* or Bollgard cotton.
Although Genuity" Bollgard il" and Bollgard cotton wiltsdstain
less damage from some of the most troublesome lepidopteran
pests, they will not provide protection against non-lepidopteraa
species. These insects should be monitored and treated with
insecticides when necessary, using recommended thresholds.
Whenever possible, select insecticides that are least harmful
to beneficial insects.
NOTCttn'2010. Mlcor commertial piantintj of eotlgard' cotton is proWbitet) in the Jo'iowing
stales: Arizona, CaBfOfoia.CoterMo., Kansas, New Mexico snflOkiahoma,
m ZOK). sale or planting <rf Bottgard " is prohibited in the Texas counties of: Carson, Oalism,
Hansford, Harttejt Hutchison. Lipscomb. Moore. Ochtllree. Roberts, aM Sherman.,
In ZtnO, sale or conwnorcia! frfanKng of both Genuity ' BoHganl il* anO Boligarfi' is prohibited in
HawSi Pu«to Bkoi and the U.S. Virgin islands, or in Florida south o! Route 60 (near Tiimpa).
MONSANTO
1029
Roundup Ready* Cotton, Genuity" Bollqard II* with Roundup Ready*
Cotton and Bollgard with Roundup Ready Cotton
Roundup Roody-
Coftori
ROUNDUP READY COTTON GENUITY"' BOLLGARD 11 WITH ROUNDUP READY
Roundup Ready® cotton varieties contain in-piant tolerance COTTON AND BOLLGARD WITH ROUNDUP READY
to Roundup® agricultural herbicides, enabling farmers to . COTTON
make in-crop applications of Roundup WeatherMAX* or Genuity" Bollgard 11* with Roundup Ready® cotton and Bollgard
Roundup PowerMAX® according to label requirements. with Roundup Ready varieties offer farmers the benefits of both
insect protection and glyphosate tolerance combined in one
crop. These varieties- exhibit the same insect protection qualities
as Genuity'" Bollgard II* and Bollgard cotton and enable farmers
to make in-crop applications of Roundup WeatherMAX or
Roundup PowerMAX according to label requirements.
MARKET OPTIONS
Gin by-products of cotton containing Monsanto’s biotech traits,
including cottonseed for feed uses, are fully approved for export
to Canada, Japan. Mexico and South Korea. Cottonseed containing
Monsanto traits may not be exported for the purpose of
planting wjthouta license from Monsanto,
it is a ylolatien of national and international law to move
material containing biotech traits across boundaries Into
nations where Import Is not permitted,
recommended management PRACTICES
Managing Roundup Ready cotton, Bollgard with Roundup Ready
cotton and Genully'Soligard 11" with Roundup Ready* cotton
requires that a farmer follow the recommended management
practices associated with cotton containing each individual trail
farmers of Bollgard with Roundup Ready cotton and Genuity*
Bollgard It* with Roundup Ready* cotton varieties must follow
the same guidelines for estabiishing required refuge options,
practicing IRM and managing target and non-target pests as
described for Bollgard and Genuity* Bollgard H® cotton in the.
IRM/Grower Guide.
APPLICATION OF ROUNDUP WEATHERMAX*
AND ROUNDUP POWERMAX*
Roundup Ready cotton is genetically
improved; to provide tolerance to
glyphosate, the active ingredient in
Roundup agricultural herbicides.
Roundup Ready cotton can receive
over-the-top applications of Roundup
agricultural herbicides only through the
four-leaf stage. With the introduction
of Genuity* Roundup Ready* Flex cotton, there is the potential
for both Roundup Ready cotton and Genuity” Roundup Ready"
Flex cotton to be used on a farmer's farm. This creates concern
for the crop safety of Roundup Ready cotton. Monsanto
recommends that farmers:
• Maintain acairate records of which technologies have been planted,
and where they have been planted,
• Communicate the field plan with other rnembers of their.work
force to ensure proper applications lor each technology,
• Clearly mark fields to indicate which technology has been planted.
WEED RESISTANCE MANAGEMENT GUIDELINES
Follow all pesticide label requirements and these guidelines
to minimize the risk of developing glyphosate-resistant weed-
populations in a Roundup Ready cotton system:
- Scout fields before and after each burndown and in-crop application. •
• Start clean with a burndown herbicide program or tliiage.
• Use the right herbicide product at the right rate and rjqht time,
• Add soil residual herbicidefs) and cultural practices as part
of a Roundup Ready weed control program,.
• In-crop, apply Roundup WeatherMAX at a minimum of 22 oz/A
when weeds are less than 6" in height.
• Tank-mix other approved herbicides with Roundup WeatherMAX
if necessary for postemergence weed control.
• Clean equipment t^fore moving from field to field to minimize
the.spread of. weed seed {as well as nematodes, insects and other
cotton pests).
Should repeated non-performance occur, report to Monsanto
W your local retailer.
2010 TECHNOLOGY USE GUIDE ,
1030
WEED CONTROL RECOMMENDATIONS
Weed control in cotton is essential to help maximize both fibei* , , stands aiid/or reduced yield potentiaf. The Roundup Ready‘^
yield and quality potential. Cotton is very sensitive toaariy- 0ttoo, system provides farmers with the right tools to control
season weed competition, which can result in unacceptable weeds before they become competitive.
Preplantftirndovw Always start clean by planting intoa weethfiee^
" ' either tillage dr a bonrtownappltcafl^^^^^
' % in no-titl and reduced-till sySems.^S})r6pWtltefB^
V application ofRoun(lupW8alter!ittiP***M22to.44.(aM mas
tank-mix ii^th,dicamba,ora,4-B. -
See thedicainba and product lafltldriates aidtftse
intervals required betvreen applKatopawt atfbmplairtmg.
Stale re^rictions may apply. ■
residual herbic!de(s)3S
ntrot program. Usethe |
timingof the rWidual :herbkide#|rfi« td;jRai#i8t-
product labels for list:oIre^aaih«r^i(te^^R^. W.MS(^^'i
tfcmiih
FMKthLM
I canTeSuitio unacceptabie,
stands jm,d^r{!0«'ced.yi^, potential. , ' . y
TWstanfcmi* is.recrmmend^ tor-control and management ,
- {rfglvi^^-easM'marestai)..(Dini<?asp.)drofber^
vlough-to^ntrbl-Weeds. . ' isi: ■
' 8»nWi»n ^Icaflon sit* ie tfii:
; madv^cedfptantingidcpiitrdf^tingii^e^ -, • •. ^
Tfa residual hsrbiadets) may beaked as either^ 1
weemergerco (inct jdmg preolant incorporated),
• #t«neRj<^::andfer layby applicatiof' as allowed
d|the l^;Qf;tl)'e5pei ificproducUemg usc-d
I ApplyRoundupWeatherMAXovefthelpptromdope(nefgeTi^;-|
K tbns^Klhe fourth Irue^!wf(nod0sli|ie{uhtittheflfthtru6|5 1
iV-lsafreachesthestzedfSqiiarter). ' -I:!-
^ ^ ' Kj IJ
:<t'Twapplicatiohscanb6in9dedurlrig^is{»rlod ||amaxjm^i|
r^ateot22oz/A perappltca8on. | | ii:
Refer to the 'Annual Weeds Rate T^^^heRoi^up 1
WeaiberMAX label tor rate recomhffi^Sns for ^cific | ^
annual weeds. 1^!-!
-Ifiirdp'oyeHhe^'tQp'appiicahcns tnvst be at Igast^O days apart
4itiweotidn^musthayc at least »o nodes of Incremental
P 'fetwe^applicaticms Car^jrould be taken tO'record''''''''-’^
li^Situalmns where tne pote-ibai ff^weed infestations is high
(iduding perennia* weeds) irakefte first applitalfofi eddy I
^gh to Slow P second appiicat%' befi^' cotton exceeds the
fSirtb tnieHeai siage Over-f>e-lot^Hcat5(«s after the fourth
leaf stage car result m boll '(^ delayed matuhty, aod/or .
#dtoss.
uzles in a low hoi:tei»itat 9 ttif.on ttpermit spifay
to overiap in me ^iwudslecimtact of spray
ton leaves shculdfe^i(oitfodto theiA%timum extent
Ejcesslve taia^i^faiican result in Wi lostdelafed
.anitforyieKinst ,
mu^ be two nbcesisNlfe^h and at least 10 days b^ween
must-liefr^-^-ledst 7 dal's pnor to harvest
agr cuUdr^beH^fdesarenot effoct.ve for
cQhia negroHt^igrRat^tdup Ready cotfon.
-ndup agr culiural hr* ides pre-'a^vest
^n fotseed'vliils'cofftract a* an authoriaed cotton
Roundup Ready cotton has excellent vegetative tolerance to Rmindup WeatherHAX lowing eariy-season over-the-top applications. Incomplete
reproductive tolerance requires that applications after the A-leaf (node) stage be fwoperiy post-directed.
Tate of 22
Ililstreali^B«fftclive»
ATTENTIOH: Use of Roundup agricultural herbicides in accordance with label rKtions is expected to result in normal growth of Roundup Ready cotton,
however, various environmental conditions, agronomic ivacticcs, aiKl rthcr factdre.make it impossible to eliminate ail risks associated with the product,
even when applications are made in conformance with the labd spedftc^ions. in some cases, these factors can result in boil loss, delayed maturity,
and/or yield loss.
■follow all peslicids label r«|UireiTicnts.
‘■If using anotbar RauraSup agricultural Iwfbicfde, you must refer loOic !abe) bmslet or Rmmdupftesdyo^tOT supplemental UM for that brand to aetermlneanpropriale use rates. II using
Rouiiflun PowerMAX* application rales are ttie same as lot Roundup WeaBier MAX
: MONSANTO
1031
RECOMMENDATIONS FOR MANAGING GLYPHOSATt-RESfSTANT WEEDS
wrv;o<5:
INSTRUCTIONS AND USE RATE:
Slyphi^te^Resirtani
{flarestail
Start clean with atwriKtown h€itW(te }TO^in or lill^
-Tank-mix Roundup agricui^^^^ei with dica'ihha hr Z.Vo (consult label tor plant, back limihgl, , ,
tfyouhavedense of m^t^tiiseapitplfflt residua! tierbleiaeattherecommended rate and , - :
timing, such as diu ton (Bire!(*) w Bumiroazfn
Use RoundupWeathH-MAX iti-cto(),asneeded..at a mintmom ozh to control other v.certs.,
iri-crop. if applying post-directed to gtyphosate-resistant marestall, Roundup WeatnerMAX can be tank-mtxed '
with other herbicttfes, su^as dhron or MSMA
klarestailshouM be 6" in height al the time of in'crop appiica^sn
Start clean witha burr^mherbicide program or^liage
Apply a preemergeircet^o^ herbicide such afp^Mfimethafi) ^rQwt*TptdsfluomtbmoFl^m^sa^
(Renex*) or f li«m«(a 2 i,ii#alor) for cimtrol of A/>fft9Mfiu$$pPties.
in-cron tank-mix Roum^ WeatherMAX at22 ozl^^ m^olachfor or other labeled cnioracetamide herbicide
: before Ar7»ra^^ emerges.
Use. Roundup Weatherl^in-crop. as needed, at p;i;^!num of 22 ozM to cortrc! othe' weeds
.A postilirected appiica^ of Roundup Weal herl||^i^i(-m1xed with MSMA and a residual SuCfi as dlufOR
(Dlrex) or fiumioxaztn (\S)br) should be made lo 4maranffAis Hiecies 3" or smaller m h«ght and
prevent addittonaHlusl^ ' '
Start clean with a burnd^n herNcide program
herbicide such
Plu&forthecontrolof
2010 technology use guide
1032
COTTON TECHNOLOGIES
Genuity" Roundup Ready* Flex Cotton and
Genuity" Bollgard If with Roundup Ready* Flex Cotton
GENUITY" ROUNDUP READY" FLEX COTTON
Genuity"* Roundup Ready® Flex cotton varieties possess improved
reproductive tolerance to Roundup* agricultural herbicides. This
technology gives farmers the opportunity to make over-the-lop
broadcast applications of labeled Roundup agricultural herbicides
from crop emergence up to seven (7) days prior to harvest.
GENUITY" BOLLGARD fl* WITH ROUNDUP READY*
FLEX COTTON
Genuity" Bollgard II® with Roundup Ready* Fiex varieties offer
farmers the benefits of both insect protection and glyphosate
tolerance combined in one crop. These varieties exhibit the
same insect protection qualities as Genuity"* Bollgard il** and are
tolerant to over-the-top applications of Roundup WeatherMAX*
and Roundup PowerMAX".
MARKET OPTIONS
Genuity*' Roundup Ready* Flex cotton and Genuity" Bollgard ll®
with Roundup Ready Fiex cotton have regulatory clearance
in the Uhiled States, but do not have import approval in ali
export markets. Processed fractions from these products,
including finters. oil, meal, cottonseed and gin trash, must not
be exported, without al| necessary approvals in the Importing
country. It is a violation of national and international law to
move material containing biotech traits across boundaries
into nations where Import Is not permitted.
RECOMMENDED MANAGEMENT PRACTICES
Managing Genuity-Roundup Ready® Flex cotton and Genuity"
Bollgard 11“ with Roundup Ready® Flex cotton- requires a farmer
to follow the recommended management practices associated
with cotton containing each individual trait. Farmers of Genuity"
Bollgard 11* with Roundup Ready* Flex cotton must follow
the same guidelines for establishing required refuge options,
practicing IRM'and managing target and non-target pests as
described for Genuity'-' Bollgard ll"* cotton in the IRM/Grower Guide.
WEED RESISTANCE MANAGEMENT GUIDELINES
Follow a|l label requirements and the guidelines beiow to
minimize the risk of developing weed resistance in a Genuity*'
Roundup Ready® Flex cotton system:
• Scout fields before and after each burndown and
in-crop application.
• Start clean with a burndown herbicide program or tillage,
• Use the right herbicide product at the right rate and right time..
‘ Add soil residual herbicideCs) and cultural practices as part.of
a Genuity" Roundup Ready® Fiex cotton weed.contrai program,
• In-crc^, apply Roundup WeatherMAX at a minimum of 22 Oz/A
when weeds are 3* to 6" in height.
• Tank-mix oth«- approved herbicides with Roundup WeatherMAX
if necessary for postemergence weed control.
• Should repeated non-performanco occur, report, to Monsanto or
your local retailer.
• Clean equipment before moving from field to field to minimize the
spread of weed seed {as well as nematodes, insects.and other
cotton pests).
APPLICATION OF ROUNDUP WEATHERMAX* AND
ROUNDUP POWERMAX*
.? May be applied over-the-top and/or in-crop, from crop emergence
up to 7 days prior to harvest.
• A maximum rate of 32 oz/A per application may be applied uSthg '
ground application equipment while the maximum is .22 oz/A per
application by air.
• There are no growth or timing restrictions for sequential
applications,
• Four (4) quarts/A is the total in-crop volume allowed from
emergence to 60% open bolls.
• A maximum total volume of 44 oz/A may be applied between
layby and 60% open boils.
• Post-directed equipment may be used to achieve more thorough
.spray coverage of vyeeds or if herbicides, not labeled for over-
the-top application wili be tank-mixed with Roundup WeatherMAX
or Roundup PowerMAX.
MONSANTO
PREHARVEST APPLICATIONS
■ Up to 44 oz/A may be applied after cotton reaches 60% open tK)lfs
and before harvest, If needed.
• Applications must be made at least 7 days prior to harvest.
J Over-The-Top (erampiB)
: Preharvest
! 22-32 oz/A in ary single application
( 128 oz/A total in -crop application (emergence to |»^arvest)
1 44 02/A
1
CROP SAFETY OF OVER-THE-TOP GLYPHOSATE
APPLICATIONS
MonsarttO has determined that a combination of components in
glyphosate formulations. have the potential to cause leaf injury
when applied during later stages of crop growth. Roundup
VVeatherMAX and Roundup PpwerMAX are the only Roundup
agricultural herbicides labeled and approved for new labeled
uses over the top of Genuity" Roundup Ready* F!ex cotton.
Leaf injury may occur if the products are. not used. according
to the product label, used at higher than recommended rates
or if overlap of spray occurs in the field; Farmers must confirm
that any glyphosate formulation to be used on Genuity"*
Roundup Ready* Flex cotton has been jabeled for use on
GenuitY” Roundup Ready* Flex cotton and Should corjflrm
that it has been tested to demonstrate crop safety.
2010 TECHNOLOGY USE GUIDE
1034
WEED CONTROL RECOMMENDATIONS
Weed control in cotton is essential to maximize both fibK'yleW
and quality potential- Cotton is very sensitive to earty-season
weed competition, which can result in unacceptable stands- and/
or reduced yield potential. The Genuity'” Roundup Ready* Flex
cotton system. With improved reproductive tolerance to
Roundup® agrtcultiifai herbicides, provides farmers with the
right tools to control weeds.
Always start clean by planting mtoatteed-freerfeld.
M'.ithi ‘'.itii- ;
I-' nc hi‘ and ro^'wced tilt systems apply a prcpliint
■* ttionofRowidupW^r^ttJI^
at ll to M. otM <n a tank mix with dicamba or 2 4 a '
See e dicamoa and 2.4-D product label h}r rates ..
a'^d t -ne nt^rvcls required between application
a-d cc‘tcn plarting. State restrictions may apply
;3t^reduced yield poi n ; i ,ii .
;5ilS't,anh-4nixisrec0ffirBi’:’(;:ii :i'i ■i'.hmii;';,.-'-':-
•-(rfgiyphotete-r’esistailtiii.ii ill 1 : 1 ’, vai o;
W'cwiirolweeds. ^^'.
Sumdownapplicdtion siioutd be <iadei^ enough
in advaryx: of planting to coirtr'^ exlsHng wed&
Appi, aopro^cO residua! herbtcideW as part o! a
Cel'll Roj''duDRcady®Hex cotton weeoconti
prog>am Lts« the recommended label rate and br
of the residual herbicide applied Refer to Individi
prod ict labels for list of residual herbicides that i
' be utel;
Before hai
open both!
:..R6undii||
This treati
perenial
'follow ail oesticida label reaulrements.
^•The masimijmvolumao! Roundup WealhefMAX and Soon*® PowCfHAX*lhalnwbe used in a single season (5 5.3 Quarts per acre^
MONSANTO
1035
genuity
RECOMMENDATIONS FOR MANAGING GLYPHOSATE-RESISTANT WEEDS
jantfitizofnelotiRsongra:
1036
1037
Genuity” Roundup Ready 2 Yield® and Roundup Ready® soybean
varieties contain in'plant tolerance to Roundup® agricultural
herbicides. This means you can spray Roundup agricultural
herbicides in-crop from emergence through flowering.
Spray labeled Roundup agricultural herbicides over the top from WEED CONTROL RECOMMENDATIONS
emergence (cracking) through flowering (R2 stage soybeans) Starting dean with a weed-free field, and making timely post-
for unsurpassed weed control, proven crop safely and maximum emergence In-crop applications, Is critical to obtaining excellent
yield potential. R2 stage soybeans end when a pod 5 millimeters control and maximum yield potential. The Roundup Ready
(3/16") long at one of the four uppermost nodes appears on the soybean system provides the flexibility to use the herbicide tools
main stem along with a fully developed leaf (R3 stage). necessary to control weeds at planting and in-crop. Failure to
control weeds with the right rate, at the right time and with the
right product can lead to increased weed competition and the
potential for decreased yield.
;i.; : To .Start .clemlrt.no'titl systems, ^iply a bumdoKffi'^katjon Always start with 3.weed-!fee.|leW.Jnfloipi;aniredaced:ti!t ,
of Roundup WeatherMAHE*** at 22 to 44 02 /A before filing. ^ systems, apply a Roundijp WeatherMWTlHiCTdbwn-appiicatio'R
Se=;helatelfcrappro|!Weratets»isaspesg|»™^^^ i tomt,olp*tlpgv,ertsbeli»?(ilanlin,
1 - - ' -- fgtyjrtios^e-resistafttmafestaKffp/iyzasA) I Add(r^2,4 Ointheburndowncafisigpific^tlyTedwe
or ol^er difftcuit-to-control w^spresent at burr^n. apply j broadleat weed presscre at oost-ejnergence timing.
2o,/Ao(SopnPpp*fe«»«»|U»»tank-* I iiea4ttPi4-Oprata:M9talforh«e«te«re»,W
; 2,4-a ■a«papp.,cA^^te»(te!,pbetorepl3Pl.nJ,a^dbetore ; 6et„e„appp4opandsP,teabpteblta,. ^
marestadreaGhestf’inheight. i i k 9
ijiipfeapllli
stpplomeritnl Ish?
NOLOGY y
1038
GENUITY ■ ROUNDUP READY 2 YIELD*
AND ROUNDUP READY* SOYBEANS
TanWx Rounaup'WeatherMAX* with $to12 o?/Aof
Select Max"afi(l apply to 4" to 36" giyphosalHolefanl
volunteer Cora „
■In-Crap: , . , ,
•44oz/ftp0f singleappliCatipn .
;*'44W/AdlffHYi
* 64 02 /A emergence ttirougl) flowering (R2 stage soybeans
PoBtarvesfc ' ■,
•22 02/A,dMli. i i -
Weed species and skeMe'diri the ‘Annua! WeeaiRate Table"
'•ofthe Roundup WeatherHAX label.
■foMSpason: ■"■';■ ^ ■'■
5%m Tfi^ombidtotal^ofin-cfopandprsharvest :
,3Ppi'feations:cahnot8xcee86Ao#: , ' ^ s-
reauiremj
Herbicide products sold by Monsanto for use over the top of soybefflw with Gwulty" Roundup Ready 2 Yield* Technology for the 2010 crop
season are as follows:
■ Roundup WeatherMAX
• Roundup PowerMAX
KEY WEEDS
WEED CONTROL RECOMMENDATIONS
Plant soybeans in nan
Use a pre-plant residU'
•ftjllow all pesticide label fcaulfsfwris.
*lf using another Roundup agricuitura! herbiddc.YOuimHlrsler to the l*«bi}okteLof Roundup Readv.-So^an-orCeouity-ftounitup Ready 2 Yield* Sovt»ansupplemt
todetormine apiYopriatR uie rates, it using Roundup PovwrMAX, ap^callofl rates are the sante.asfv Roundup WeatherMAX.
WEED RESISTANCE MANAGEMENT GUIDELINES
Follow all pesticide label requirements and the guidelines below
to minimize the risk of developing glyphosate-resistant weed
populations in a Roundup Ready Soybean System;
• Crop rotation is strongly encourageel.
• Scout fields before and after each burndown and in-crop applicat
MONSANTO
1039
• Start clean with a burndown herbicide or tillage.
- Tank-mix with 2,4-D to control glyphosats-resistant mdi^tail or
other tough-to-contfo! broadfeaf weeds.
• Use the recommended label rate of a soil-applied residual heiisicWe
such as INTRRO®, Valor®, Valor XLT* or Gangster®.
• In-crop, apply Roundup WeatherMAX at a minimum erf 22 oz/A
before weeds exceed 8” in height.
■ If an additional flush of weeds occurs, a sequential application of
Roundup WeathertlAX at 22 oz/A may be needed before weeds
exceed 6” si height.
• Refer to ^dividual product labels for a list of recommended
tank-mix partners.
■ Clean equipment before moving from field to field to minimize
the spread of weed seed.
■ Repeal repeated non-performance to Monsanto or your local retailer,
RECOMMENDATIONS FOR MANAGING GLYPHOSATE-RESISTANT WEEDS
iWEEDS
INSTRUCTIONS AND USE KATES'
Gf^bosate-Reslstant
Marestaif (Korsatned)
implant: ;
Apply a tank-iiiixture of?S qz/A Baundup WeatherMAX*- 1 p^A'.
, See the 2,4-D product label tor lime intervals required api
in-crop: ^ i “
it is strongly encouraged ^hat marestail should be omtrolfed prior to pi
In-crop, apply a tank-mixEureof S oz}k flbundup WeatherMAX wth G3 1
treatment cmly for a marastail infestabog that was not controlled prepi
-the first trifoliate leaf and 50%f!ow^in^:stage of soybeans. At the tint'
Replant : i s; . •;
Apply a tank-mtx of Z2 opk Roundup W^therMAX with a oreemeroence i
i
']C the tank-mix to help cpnlrol emerged
'■ reoardino aonticalion tirtiinq relative to;
|herbicide for precmcrgence i
us species and other
I planting.
lofen (Cobra*), lot
nay be added to I
In certatnatHSiUalian^fy^
orcajlh«lQ>n8-S387 fien
iDBsHclde !ab*li
2010 TECHNOLOGY USE GUIDE
1040
1041
nsis^pRead/
ATTENTION: Pursuant to a Court Order issued on May 3, 2007,
5enuity'“ Roundup Ready® alfalfa seed CAN NOT be commercfally
lOld or planted until further administrative regulatory actions are
:ompleted. For more; information, and the latest updates on Genuity "
toundup Ready® alfalfa, go to www.roundupreadyalfalfa.com.
Genuity'” Roundup Ready* alfalfa varieties have in-plant tolerance to Roundup® agricultural
herbicides, enabling farmers to apply labeled Roundup agricultural herbicides up to 5 days
before cutting for unsurpassed weed control, excellent crop safety and preservation of
forage quality potential.
Hay and Forage Management Practices
Genuity’* Roundup Ready* alfalfa must be managed for high
quality hay/forage production, including timely cutting to
promote high forage quality (i.e. before 10% bloom) and to
prevent seed development. In geographies where conventional
alfalfa seed production Is Intermingled with forage production
and the agronomic conditions (cjlmate and water^rrigation
availability)' are such that forage alfalfa is allowed to stand and
flower late: in theseason, Genuity'* Roundup Ready* alfalfa must
be. harvested at or before 10% bloom to minimize potential
pollen flow from hay to common or conventional alfalfa seed
production. Faimers who are unwilling to or who can not make
this commitment to stewardship should not continue to grow
Genuity’” Roundup Ready® alfalfa,
Genuity" Roundup Ready® alfalfa varieties have excellent
tolerance to over^the-top applications of labeled Roundup
agricultural herbicides. An in-crop weed control program using
Roundup WeatherMAX* or Roundup PowerMAX* will provide
excellent weed control Iri most situations, A residual herbicide
labeled for use in alfalfa may ;aiso be applied postemergence in
alfalfa. Contact a Monsanto Representative, local crop advisor or
extension specialist to determine the best option for your situation.
stand Takeout and Volunteer Management
Crop rotations can be divided info two main groups, alfalfa
rotated to; 1) grass crops (e.g. corn and cereal crops); and
2) broadieaf crops. More herbicide alternatives exist for manage.-^
ment of volunteer alfalfa in grass crops. The recommended steps
for controlling volunteer Genuity'* Roundup Ready.® alfalfa are;
• Diligent Stand Takeout • Plan for Success
• Start Clean • Timely Execution
DILIGENT STAND TAKEOUT
Use appropriate, commercialiy available herbicide treatments
alone for reduced tillage systems or In combination vyith tillage
to terminate the Genuity" Roundup Ready® alfalfa stand. Refer to
your regional technical bulletin for specific stand takeout recom-
mendations. NOTE: Roundup* agricultural h8rb!ddeS;are not
effective for terminating Genuity" Roundup Ready" alfalfa: stand's.
PLAN FOR SUCCESS
Rotate the crops with known and availabie mechanical or
herbicldai methods for managing volunteer alfaifa, keeping
in mind that Roundup agricultural herbicides wilt not terminate
Genuity’* Roundup Ready* alfaifa stands.,
• Rotations to certain broadieaf crops are not advisable if
the farmerls not willing to implement recommended stand
termination practices.
• in the event that no known mechanical or herbicitiaf methods
are available to manage volunteer alfalfa in the desired rotational
crop, it, is suggested that a crop with established volunteer
alfalfa management practices be introduced into the rotation.
Implement in-crop mechanical or herbicide treatments for
managing alfalfa volunteers in a timely manner; that is, before
the volunteers become too large to control or begin So compete
with the rotational crop.
START CLEAN
If necessary, utilize tillage and/or additional herbicide
application(s) after stand takeout, and before planting of
the subsequent rotational crop to rnanage any newly
emerged or surviving alfaifa.
TIMELY EXECUTION
2010 TECHNOLOGY USE GUIDE
1042
GENUITY -ROUNDUP READY® ALFALFA
Planting Requirements
Genuity'' Roundup Ready* alfalfa is not permitted to be planted
in any wildlife feed plots.
Stewardship
All Genuity" Roundup Ready® alfalfa farmers shall sign the
Monsanto Technology/Stewardship Agreement (MTSA) limited-
use license application which provides the terms and conditions
for the authorized use of the product. Due to special circum-
stances, alfalfa farmers in the Imperial Valley of California will
also sign an Imperial Valley Use Agreement (IVUA) with specific
stewardship commitments. The MTSA or IVUA must be completed
before purchase or use of seed.
Both the MTSA or IVUA explicitly prohibit all forms of commercial
seed harvest on the stand. Every alfalfa farmer producing seed
of Genuity" Roundup Ready* alfalfa must possess an additional,
separate and distinct seed farmer contract to produce Genuity"
Roundup Ready® alfalfa seed. Genuity'* Roundup Ready® alfalfa
seed may not be planted outside of the United States, or for
the production of seed or sprouts.
Any product produced from a Genuity” Roundup Ready* alfalfa
crop or seed, including hay and hay products, must be labeled
and may only be used, exported to. processed or sold in countries
wfwre regulatory approvals have been granted. It is a violation
of national and international laws to move material containing
biotech traits across boundaries into nations where import is
not permitted.
Pursuant to a Court Order Issued on May 3, 2007, Genuity’*
Roundup Ready* alfalfa farmers must adhere to the requirements
set (wt in the December 18, 2007 USDA Administrative Order
(http://www.8phis.usd8.qov/brs/pdf/RRA_A8Jinal.pdf) until
the USDA completes its regulatory process.
These requirements include, but are not limited to:
• Pollinators shall not be added to Genuity* Roundup Ready®
alfalfa fields grown only for hay production.
• Farm equipment used in Genuity" Roundup Ready® alfalfa
production shall be properly cleaned after use.
• Genuity* Roundup Ready* alfalfa shall be handled and clearly
tdentified to minimize commingling after harvest.
For additional information visit the USDA website:
http://www.8phiS4tsd8.gev/blet8Chneiogy/alfslfa_histwy.shttnf
For more information and the latest updates on Genuity” Roundup
Ready® alfalfa, go to http://www.reundupr8adyaifalfa.com
; je maat saiai raporttng rtgulramants, tha stad suppllar Is regalreiiio Mantlfy and list all Canulty" Roundup Ready* alfalfa
: flaPd ioeatiens. Tharafera, ad farmers MUST PROVIDE thair toed t^u^llar with tha GPS ceerdinatas of ell their Genuity**
: Rpunciup Ready* alfalfa Raids.
M MONSANTO
1043
to control flushes of weeds in established alfalfa, make
applications of Roundup WeatharMAX® or Roundup
Pbw«^AX^ herbicide at 22 to 44 oz/A before weeds
exce«i 6" in height, up to 5 days before cutting.
Use other approved herbicide products tank-mixed or in
seguerice with Roundup agricultural herbicide if appropriate
for the weed specfrum present as part of a Genuity’”
Roundup Ready* aifa'fa weed control program.
Report repeated non-performance to Monsanto or your
local retailer.
WEED RESISTANCE MANAGEMENT GUIDELINES
follow ail pesticide label requiremersts and the guidelines below
to minimize the risk of developing glyphosale-resistant vreed
populations in a Genuity'” Roundup Ready® alfalfa system:
• Scout fields before and after each herbicide applicatlcm.
• Use the right herbicide product at the right rate and at
the right time.
WEED CONTROL RECOMMENDATIONS
In established stands, to preserve the quality potential of forage but before alfalfa re-growth interferes with applicatlor:
and hay, applications should be made after weeds have emerged spray coverage of the target weeds.
Ap|^'K:3^st»tvt^eni^hgii^y>ap^ied^:4'iiidgie'%ticatjdh
inmull^leapiikatfoRs'fe.g.'Z'affBlic^tio^ ••
Sequential applications should ce at least 7 days apart
fttaMIshei Stands After the li!^ fwrvest aiwwly eslrtlish^ stand up
^ ia
per cutting may be applied up to S,d8ys brtore each ' ■
subsequent cutting The confined total peryear for
.. atlin'cropspshcationsinesi^llshedsUnifemustoot
exceed132ojMt4tqyWofiteUftdop.»teattierMA)t
> for specifk-application rates and instructions for
- conlfolofvaffeusannu^andperefli^-weeds,relerto
the RourtdupWe^herMAX” herbicklelihel booklet.
. ,v, Some vfteds with multiple germinatiOfltifhes or
' ’ suftjressed bunted) weed's may reqirire a second
•v appltalion of Soundup WeatherMM” herbicide for
^ '-^r rajmpleteccmtrol For some perennial weeds, coated
applications may be required to eliminate crop
competition throughout the growing season.
■*)( using ^nother RottnUuii agrlcullufst kerblciue, v<bj n>ust Ktcr to the label booklet or seoatatolY nublrsbed Oenuily ' Roundwneadye ailslla supplementisl label
foi thai brand to delefmlno apcrdfiriate use rates, if using Roundup PowerHAX. apoKtatlo-nrates-are the same as lor Roundup WeStherMAX.
2010 TECHNOLOGY USE GUIDE
1044
Genuity™ Roundup Ready* spring canola hybrids contain
in-plant tolerance to Roundup agricultural herbicides,
enabling farmers to apply Roundup® agricultural herbicides
over the top of Genuity™ Roundup Ready® spring canola
anytime from emergence through the 6-leaf stage of development.
The introduction of the Roundup Ready^ trait into leading spring
canola hybrids and varieties gives farmers the opportunity for
unsurpassed weed control, proven crop safety arid maximURT
profit potential. With Genuity™ Roundup Ready® spring canola,
farmers have the weed management tool necessary to improve
spring canola profitability, while providing a viable rotational crop
to help break pest and disease cycles in cereal-growing areas.
WEED RESISTANCE MANAGEMENT GUIDELINES
Follow all pesticide label requirements and the guidelines below
to minimize the risk of developing giyphosate-resistant weed
populations in a Genuity" Roundup Ready® spring canola system:
• Scout fields before and after each burndown and in-crop
application.
• Start dean with a burndown herbicide or tillage.
• In-crop, apply Roundup WeatherM AX® herbicide before
weeds exceed 3" in height.
• A sequential application of Roundup WeatherMAX herbicide
may be needed.
• Clean equipment before moving from field to field to minimize
the spread of weed seed.
• Report repeated non-performance to Monsanto or your local
retailer.
WEED CONTROL RECOMMENDATIONS (SPRING-SEEDED)
Tho-Pass Prografn-
For Annuai and
Perennial Weed
For brodd'Spectrum control of annual and perennial Spray when canola is atthe 0- to 6'l?df stage of growth. To Dfraximlze yield
weeds, use an initiai application <rfnoz/A of Roundup . potential, spray Genuitv-" Roundup Reaoy* spring canola at the t- to 3-te3f
Weather MAX”, in 5 to 10 galA water volume. ; j stage to eliminate competing weeds Snort-term yallowmg may occurwth
rio surfactant is required. i i later applicaticms. with little effect on crop growth, maturity, or yield
Make a second application o^«/A of Roundup i ^ WaitaminimQmofiOdas«'t)etweeriappiications.Tweapplicaliws
WeatherMAX” no less than l^ys after initial | ^ of Roundup WeatherMAX will:
appii ation up to the 6 leaf spe (prebolting). |j,jg annual-weedss jch asfoxtiSI, pigvi«ed.
Oorolexfi'Cdirc^ffie'r'awli^Mion.,, andwM
c \ Provide season long^upprRs'ono* Canada thistfe.(}«ac}fgrass. and
' pcrennial'sdvftftistia . . .
(’ovidBbetteryieldsb/’elimlnaOQ^CIimtpetilaifFombothannuais
^ ^ ^ and ha I to control pe*enrta ^
V all pestlciVe late! t«q«irenTenls.
iq another Roundup agritultursl herbicide, you must rcleflo the teWbooWet Of sepafateJ¥p4*liawdGenuily”HowKiiw Heady’
>priate use rates. II using Roundup Power.MAX.df^leatlon rates arethe s^neas (of ftoutrdiS) WeatherMAX.
1045
GENUITY" ROUNDUP READY" WINTER CANOLA
Genuity" Roundup Ready® winter canola varieties have
been developed for seeding in the fall and harvesting the
following spring/summer.
Genuity" Roundup Ready* winter canola varieties contain ini3lant
tolerance to Roundup* agricultural herbicides, enabling farmers
to apply Roundup agricuitura) herbicides over the top of Genuity"
Roundup Ready* winter canola from crop emergence to the
pre-bolting stage. The introduction of the Roundup Ready tfait
into winter canola varieties gives farmers the opportunity of
unsurpassed weed control, crop safety and rnaximum yield
potential. Genuity” Roundup Ready® winter canola offers farmer
an important option as a rotational crop in traditional monoculture
winter wheat production areas, introducing crop rotation is an
important factor in reducing pest cycles, including weed and
disease problems.
WEED RESISTANCE MANAGEMENT GUIDELINES
Follow the same guidelines as stated for spring canola.
WEED CONTROL RECOMMENDATIONS (WINTER-SEEDED)
Spray «fhefi''Gerfoity''fR)undu|p winter cani^ is at tt» H
leaf stage of growth, lartyapplteations eew
mds aM Inpove yield potential
Two appltcattORs of Rolffidop WealfterMSX-.wfll provide controt;#; ■
earlyemerglng a-ruai weeds and winter emerging weeds such as
downy tMume. cheat andlolntedgoatgrass. , ' ' .
Sequential Applications The two-pass program gives the greatest ^xiblrdy In
.controllinglateemeiqirigweedsForbroad-spedmmwee^ j
controLappiylUoZZo^AofROtinduplIfealherMAX** •
herteade to ^te^f or larger Genuity" Roundup Ready* winfeti
canola in the fall; Use 5 to 10 gallons^ water volume. Do not j
- • add surfactants. ! i
Apply asecohdaptli^j^of Roundup WeatherMAX^alltW
22oz/A'ataminfn^^l^alcf60d8ys,afterfhefirst
applicajtonandti^'S^nginthespring. •.
- Oo not izceed 22 c^^ppiication.
For brodd-spectriiA^fiO^I of annual and eas'
perennial weeds, l ^^^ ingie ^iicaticm of
of M^dup.Weat^^^, preferably in the h
R^y^ winter canola
pMlt and actively
to%o!l|ng,Uss the- ,
HaiiflwnOttltitflor ■ acv single <
^es/Jlj^oftothe 6-leaf
raitfife growtn reduct-pn.
Rotintfap'MHMMXt't ‘fta
!oz/A.Nomorel
efife^^cd';
'(blMwai) pesticide iab«) r«i)wi>'en'enU.
‘•SI using anatfier brand twrbtcids. you must rarer (o Uia labw booktat orC«fu<tv”ni>uii:lup a»acty*w4nhir canola succil».-n«ntal label for that brand tooetermine
sppropriaie use rales. If using hounilup PowerMAX, applicalion rates irt the same as I<k RoonOup WeatherMAX.
GRAZING
It is recommended that Genuity” Roundup Ready® winter canola .
not be grazed. While Genuity” Roundup Ready* winter canoia
may provide farmers additional opportunity as a forage for
grazing livestock, at the present time insufficient information
exists to allow safe and proper grazing recommendations.
Preliminary data suggest that excessive grazing can significantly
reduce yield, and that careful nitrate management is criticai
In managing Genuity'" Roundup Ready* winter canoia as a forage
to limit the risk of livestock nitrate poisoning. State universities
are assessing the potential and the instructions for grazing
Genuity” Roundup Ready’ winter canola and they will provide
grazing management guidelines when their research is completed.
2010 TECHMOLOGY USE GUIDE
» Genuity™ Roundup Ready’ sugarbeet varieties have
r q| T in-plant tolerance to Roundup* agricultural herbicides,
enabling farmers to apply labeled Roundup agricultural
herbicides from planting through 30 days prior to
harvest for unsurpassed weed control, excellent crop safety and
preservation of yield potential.
MANAGEMENT PRACTICES
Sugarbeets are extremely sensitive to weed competition for light,
nutrients and soil moisture, Research on sugarbeet weed cor>tfpl
suggests that sugarbeets need to be kept weed-free for the first
eight weeks of growth to protect yield potential. Therefore,
weeds must be controlled when they are smalt and before they
compete with Genuity™ Roundup Ready* sugarbeets (exceed crop
height), that is from less than 2" up to 4" in height, to preserve
sugarbeet yield potential. More than one in-crop herbicide
application wHI be required to control weed infestations to
protect yield potentia! as Roundup agricultural herbicides have
no soil residual activity. Bolting sugarbeets must be rogued
or topped in Genuity" Roundup Ready* sugarbeet fields.
Genuity"" Roundup Ready® sugarbeet varieties have excellent
tolerance to over-the-top applications of labeled Roundup
agricultural herbicides, A postemergence weed control program
using Roundup WeatherMAX® or Roundup PowerMAX" will
provide excellent weed, control in. most situations. A residual
herbicide labeled tor use in sugarbeets may also be applied
preemergence, preplant or poslemergence in Genuity "■ Roundup
Ready^ sugarbeets, Con.tact .a Monsanto Representative, local
crop advisor or extension specialist to determine the best option
for your situation.
WEED RESISTANCE MANAGEMENT FOR GENUITY"*
ROUNDUP READY* SUGARBEETS
Follow a!i pesticide label requirements and the guidelines beiow
to minimize the risk of developing giyphosate-resistant weed
populations in a Genuity™ Roundup Ready* sugarbeet system:
• Start clean with tillage and follow-up with a burndown
herbicide, such as Roundup WeatherMAX, if needed
prior to planting.
• Farly-season weed control is critical to protect sugarbeet
yield potential. Apply the first in-crop application of Roundup
WeatherMAX at a minimum of 22 or/A while weeds are less
than 2" in height.
• Follow with additional postemergence inrcrop application of
Roundup WeatherMAX at a minimum of 22 oz/A for additional
weed flushes before weeds exceed 4“ In height
• Add spray grade ammonium sulfate at a rate of 17 (bs/iOO gallons
of spray solution with Roundup* agricultural herbicides to
maximize product performance.
• Use mechanical weed control/cultfvatlon and/or residua!
herbicides where appropriate in your Genuity*" Roundup Ready*
sugarbeets.
> Use additional herbicide modes of action/residual herbicides
and/or mechanical weed control in.other. Roundup Ready crops you
rotate with Genuity’ Roundup Ready* sugarbeets,
• Report repeated non-performance Of Roundup agriculturai
herbicides to Monsanto or your local retailer.
AGRONOMIC PRINCIPLES IN SUGARBEETS
Sugarbeets are very sensitive to eariyseason weed competition.
It is Important to select the appropriate herbicide product,
application rate end timing to minimize weed competition to
protect yields, The Genuity*" Roundup fteady*.sugarbeet system
provides a mechanism to control weeds at planting and once
Genuity" Roundup Ready* sugarbeets emerge. Failure to control
weeds with the right rate, at the right time and with the right
product, can lead to increased v/eed competition, weed escapes
and the potential for decreased yields. Tank-mixtures of Roundup
agricultural herbicides with fungicides, insecticides, mferonutri-
ents or foliar fertilizers are not recommended as they may resuit
in crop Injury and reduced pest control or antagonism.
PLANTING REQUIREMENTS
Genuity** Roundup Ready* sugarbeets are not permitted to be
planted In any wildlife feed plots.
STEWARDSHIP
Ail Genuity" Roundup Ready® sugarbeet farmers shall sign the
Monsanto Technology/Stewardship Agreement (MTSA) limited-
use license application which provides the terms and conditions
for the authorized use of the product. The MTSA must be signed
and approved prior to purchase or use of seed.
MONSANTO
1047
‘railawaltpnHcUeiabvireguKcmonts. ;
'!< usin^ anoKier Roundup agricultural herbicide, you must refer (o the label booklet w separately published Genuity' Roundup Ready* sugarbeets supplemental label for
that brandto determine aporopriale use rates. !( using Roundup PoweiMAX, aprtJcalfon rates are l»» same as for Roundup WeatherMAX.
sJsth
weed
dt have gefininated after
s(wies and weed sire.
P
herbicides maybema
mRoarlu* siinarhoeU
bbhi
Billf
1
WEED CONTROL RECOMMENDATIONS
2010 TECHNOLOGY USE GUIDE
1048
H This, guide was printed using Utopia II XGCover
and Text which contains 30% p,ost-eo,nsurnef waste.
Savings derived from using 30% post-consumer^
fiber in iieu of 100% virgin fibers:
• Saves the equivalent of 585 mature trees
• Reduces solid waste by 35,308 pounds
• Reduces waste water by 213,390 gallons
• Reduces greenhouse gas emissions by 199,989.75 pounds
Before opening a bag of see<). be sure to reap, undersbnd and the
stewardship (aouirements. includEng applfcMIe retuge reguirenwnts ter
{ntect retistafiee inanagefltent, for the biotechK4«^ traits ex|»'essed k)
ni8 seed as set forth ki the Monssilo Techntriogv AtjresMrA ^ s^ii
By opening aiaj using a bag of seed, you are reHfkmhsg yottf- obigaUan to
comply with the most recent stewardship regtAwnetas.
RTl
[1
Sl.
LIBERTY
LINKCtr
Roundup Ready^ Alfalfa seed Is currently not tm' sale or distribution. The movement and use of Roundup Ready* Alfalfa forage is subject to a USOA administrative Order available at
http://www.aphis, usd8.gov/brs/pdl/HRA_A8_flBal.pdf.
This stewardship statement applies to all products listed herein except Cenulty™ VT Double PRO*", Oenulty"* VT Triple PRO'" and Genuity'" SmartStax'". See restrictions related
to Genuity'" Double PRO'". Genuity'" VT Triple PRO™ and Genuity'" SmartStax"* belovn
Monsanto Company Is a member of Excellence Through Stewerdship* (ETTB). Moh^ntopro&icte are commercialized in accordance withETS Product Launch Stewardship Cuidance,
and in comphancewith Monsanto’s Policy for Commerctatizatlon of Sioiechnrfogy-I^h^ HanH’roducts in Commodity Crops. This product has been approved for import into Key export
markets with functioning regulatory systems. Any crop or maten'rt produced frcm the product can-only be exported to, or used, processed or sold in countries where all necessary regulatory
approvals have been granted. It is a violation ol national and bitarnational lawtomoyomaterU crnitairinq biotech traits across bcKindaries into nations where import is not permitted.
Growers should iaiK to their grain handier or product purchaser to confirm their bu^ngposKiwi for tWs product Excellence Through Stewardship* is a registered trademark ol Biotechnology
Industry Organization.
IMPORTANT: Grain Marketing and Seed Availability: Genuity’" VT Double PRO™ has tec^ved the necessary approvals in the UmtedStates, however, as of October 22, 2D09, approvals
have not been received in certain major corn export markets. Genuity'* VT DouiMe PRO'" win n^ be launched and seed wit not be available until after Import approvals are received in
appropriate major corn export markets, e.t. product*. Including Genuity" VT Double PRO'** may not yet be registered in all slates- Check with your Monsanto representative for the.
registration status in your state.
IMPORTANT: Grain Marketing and Seed Availability: Genuity'" VT Tripia PRO'" has received (he- necessary approvals in the United States however, as of October 22, 2009, approval has
not been received in all major corn export markets, Monsairto anticipates that all such approvals will be-tn place (or the 2010 growing season, if all approvalsare notinplace, Oenulty’.i'VT
Triple PRO'" seed wifi only be available as part of a commerctai demmstrallon program that liKludes grain marketing stewardship reguirements. It Is a violation of national and international
laW: to move material containing biotech traits across boundaries Into nations where import is not permitted. Consult with your seed representative lor current regulatory and stewardship
Information status,
IMPORTANT: Grain Marketing and Seed Availability: Genuity'" SmartStax'" has received the necessary approvals in the United Slates, however, as ol October-22,2009, approvals have
not been received |h certain major corn export markets. Genuity'" SmartStax'" will not be launched and seed wHi not be av^iabie until after Import approvals areircc^ved In appropriate
major com export markets,, 8,t. products, including Genuity'" SmartStax'" may not yet be registered In all stales. Check vdth your Monsanto represontallye lor Irte ragiStralion status :
Ih.your slate.
Cettenaead containing Monsante trait* may net b* axperted for the purpose or pianGng without a llcanse from Monsanto.
Individual retults may. vary, and . performance may vary from locatkm to locaiion and from year to year. This result mey not be an indicator ol results you may obtain. asTbcal growfhg/soil;
and wealher conditions may vary. Growers should evaluate data lr«n muilWe locations and years whenever possible,
Grovrara may uililza the natural refuga.optlon ter varieties containing the Bellgard ll* trait In the following states: AL.AR; ri, CA, KS. K.Yi.LA. MlX.MSi MO, I^C;'0K,.SC, TN. yA.:ah9. .
most of Toxas.texdodlng the Texas, counties of Sfewster, Crane. CrocKetti Cofbetson, £1 Paso, Hudspel^ Jeff Oavts. Loving, Pecos, PresidiOj. Reeves. ref:Pel)f;V8t Verdej Wardarid-Winkler).
The natural refugeoptlondoes not apply to Bdflgard If cotton gri^h in areas where pink boilworm is a pest, including Ca. A2. MM. and the:above:fisted:Texiis count)es, it-alsoTemalns the.case.
that Bollgard* arid Bollgsrd llicottoncannol be planted south of-HlghwayBO in Florida, and that Bollgard cotton cannot be olantGCiin;certaln other counties la the Texas panhandle. Refer to.the
tectmology Use. Guide. and IRM/Grower Guide tor additional inforrnatksn fegardir >9 Bollgard il, Bollgard. natural rctugc and CPA'mandaled geographical restrictions on the planting of B.f. cotton.
ALWAYS READ AND FOLLOW. PESTICIDE LABEL DIRECTIONS. Roundup Ready* crops contain genes that confer tolerance to glyphosate. the active Ingrectibnt !n.Raundup*-brand
agrlculfiirai herbicides. Roundup® brand agricultural heroiciees will klH crops that arc not tolerant to giyphosate. Degree* and HornesS" are not fegfstcrcdln.ail slates, .bogreo*. and HarnbsB.®
may be subject to use restrictions In some states. Bullet®, Degree xtra*. Harness®, INTPftO*, Lariat*, and Micro-Tech ' are restricted use pesticides and are not registered (n ail States, The
distribution, sale; or use of an unregistered pesticide is a violation of feder^ and/or state law and is sirjetly prahS^ited. Check with your local Monsanto dealer: or representative for the product
registration status In your state.
Tank mixtures: The appIlcabiB Ubcling for each product must be in tNi possession oMhe user at the time of application. Follow applicable use Instructions. Including application. rates;
precautions and restrictions of each product used in the-tank mixture. Monsanto has not tested all tank mix product formulatioru for compatlbliily or performance otherthan. specifically
listed by brandname. Always predetermine the compatlb'dityoltarik mixtures by mixing small prc^wrtiorwlQoaritiltes In advance.
SoKqard*, Bollgard- II", Bullet®, Degree®, Degree Xtra*. Genuity Genuity and Oesrgn', Gmc^ty teons* Harness*. INTRRO*. Lariat*. Micro-Tech', Respect the Refuge and Collon Design*,
. Roundup^, Roundup PowerMAX*, Roundup Ready*, Roundup Ready 2 fechnoiogy and Design'. Roundup Ready 2 Yield®. Roundup Ready RATf, Roundup WeathefMAX*,Ra’uridiip
wcalherMAX and Design”, SmartStax-, SmartStax and Design". Start Clean. Stay Clean.'. Transorb and-Oesign*. Vistive®. VIstive and Design*, VT Double PRO", VT TrIpie .PRO YieidGard*,
vieldGard Corn Borer and Design®, YieldGard Plus and Design®. YieldGardRoolvform and Design*. YieldOard VT"i YieldGard VT and Design®, YieldOard VT Rootworm/flR2®, YieloGard VT
Triple*, and Monsanto and Vine Design® are trademarks of Monsanto Teciwicfoov LtC )viRe*and Libert¥Linl(*and the Water Droplet Design® are regislered trademarks of flayer. Hercuiex
Is 3 frademark of Dow AgroSciences LLC. Select Max' and VMor® are registered trademarks Valent U.S.A Corporation. Respect the Roluge* and Respect the Refuge and Corn Design*
are registered trademarks ol National Corn Growers Association, All other trademarks areihefwopertyof their respective owr:ers, ©2009 Monsardn Cnmoany. [l9282r\pgtl)5A-9Y-09-3881
1049
Appendix
B
National and Tier III Production Data and State Maps with
County-Level Detail for the Eleven Tier III States with
Seed Production Greater Than 100,000 lbs
1050
1051
1052
1053
1054
1055
Appendix B
1056
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2 S s o s o 5 :
ci)| CM hsf o CM o he h
CO O CO C5> CO CD CO <
■ col CO CO CO e- CM CO i
I ^ I ill o “
o g i > H 5
O 2 5 Z 03 §
_J i_ UJ
da o z
I ^ Z 2 a.
^ m O ^ jff
^ 5 O S t
X D 5 UJ 5
u X -j a 5
— ui ^ z ^ UJ
5 2 m<fe 2 X re
fK< O Q,<
rt.<Sxiy209SoH^i;^
^ ^ yi •t: X-. iv lit ^ rr. iiT* ^ ^
<0^0<>02XUJOS[ij<2<CD3
QHUJUJ_ia:<<<xx^_jOOQ:z3Uj
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< < < < <
Q Q D Q Q
2 UJ UJ UJ liJ lii
CO z z z z z
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333333533333333335
OOOOOOOOOOOOOOOOOO
1057
1058
1059
1060
Hay %
Operations
Included
35%
Hay %
Operations
Exduded
Alf. Hay -
Tons
175,636 i
18,402 I
5,550 !
^ Subtotals 3,565 32 2,317,740 0 104.918 1,258 519,868
Total 3,565 32 2,317.740 428,812 3,569 1,774,926
52.198 1
126,217 1
100.562 I
66,440 j
: 21.181 j
: 119.239 1
; 122,162 1
i 70.286 i
i 66.019 1
i 72,022 1
1 10.981 1
1 60.524 1
1 47.623 1
i 57.396 1
! 59,366 !
CO
5
cd
(D
CO
to
O)
05
o
CO
M-
cm'
CO
i 58.049
[ 35,926
i 36,251
1 120.449
1 28,164
1 56,085
M-
K
CD
S
s
Aif. Hay -
Operations
eg
JO
CO
159 i
315 i
38 I
358 1
208 1
§
■ 244 1
86 1
209 1
239 !
s
CM
CO
Oi
; 164
05
CM
CM
CO
V
I 153
CM
o
CO
CD
CJ5
o
Alf. Hay -
Acres
34,341 1
1.285 I
17,065 i
38.312 1
28,997 I
23.814 1
10.296 !
46,953 1
42,202 1
23,158 1
17.946 1
22,632 1
i 8.523 .1
1 19.504 I
16,978 1
CM
O
•d
! 16.158 I
^ 27,401 1
1 8.596 !
1 33,758
cn
05
OO'
05
CD
-"J-
CO
05
O
i 46,311 1
i 9,084
1 56,869
1 24,976
1 20,034 I
i
Seed - In
Pounds
o
O
o
o
o
o
o
o
o
o
o
o
O
O
Seed-
Ooerations
eg
o
o
o
o
o
o
o
o
o
O
Seed-
Acres
HvsW.
o
O
o
o
o
o
o
o
o
o
o
o
Alfalfa For Foraae Production
Yes, With Limits and GPS Reporting
’roduction qret
Seed
Production
Reported,
2007
o
Z
County
3
_J
K
<
2
3
WASCO I
WASHINGTON I
: AURORA !
i BEADLE
BON HOMME
! BRULE !
BUFFALO !
1 BUTTE 1
1 CHARLES MIX 1
1 CLARK 1
1 CLAY 1
1 CODINGTON 1
1 CUSTER 1
I DAVISON 1
1 DAY !
1 DEUEL
I DOUGLAS
i EDMUNDS I
1 FALL RIVER i
1 FAULK 1
1 GRANT '
1 HAAKON
1 HAMLIN
^ HAND i
z
o
CO
z
<
X
0
z
Q
X
<
X
LU
Q
>-
X
JERAULD
State
1 OREGON 1
z
o
0
UJ
a:
O
I OREGON I
! SOUTH DAKOTA !
SOUTH DAKOTA 1
3
o
<
o
X
I—
D
O
W
1 SOUTH DAKOTA 1
<
1-
o
g
X
h-
ZJ
O
CO
SOUTH DAKOTA 1
1 SOUTH DAKOTA 1
1 SOUTH DAKOTA 1
! SOUTH DAKOTA 1
<
H
o
<
Q
X
H
Z>
o
CO
1 SOUTH DAKOTA
! SOUTH DAKOTA 1
<
1-
O
iXC
<
o
X
H
ID
o
to
3
O
<
Q
X
l_
:d
o
60
I SOUTH DAKOTA
<
h-
O
<
Q
X
h-
D
O
to
<
1-
O
§
X
h-
Z)
O
CO
1 SOUTH DAKOTA
1 SOUTH DAKOTA 1
1 SOUTH DAKOTA ■
! SOUTH DAKOTA ,
1 SOUTH DAKOTA 1
<
f-
O
<
a
X
h-
3
O
W
1 SOUTH DAKOTA 1
1 SOUTH DAKOTA 1
i SOUTH DAKOTA |
Appendix B
1061
1062
1063
Hay %
Operations
Included
60%
Hay %
Operations
Excluded
40%
Alf. Hay -
Tons
ra
o
CO
CO
q
o
o
o
o
o
m
o
S
3
to
in
c
c
193,480
ro
c>
5
343,717
139,572
§
q
139,095
63,969
Subtotals 1,758 54 1,860,313 0 339,244 4.681 1,370.290
Total 1,758 54 1,860,313 548,570 7,780 2,172,218
o
o
to
q
1.356
3.482
o
«?
to
o
cj
3,186
o
o
o
2,079
o
o
399
o
Str8
Alf. Hay -
Operations
533
636
cn
lO
N
497
996
542
o
3
40
CM
3
C«i
<o
o
CM
o
CO
CM
(0
fO
h-
CO
Aif. Hay -
Acres
49,161
I
1
in
ir
S
ri
'U-
05
36,019
30.197
16.086
«
to
1.561
1,633
1.284
o
1.624
^6S
so
o
1,612
h-
o
o
638
O
1.603
u?
o
o
s
s
1
1
1
1
1
Seed • In
Pounds
1.091,907
311,706
1
1
1
o
o
o
o
^
Seed-
Operations
1
i
1
o
i ill
o
580
09
o
CO
o
o
o
o
o
Jter than 100,000
Alfalfa For Foraae Production
No new RRA forage production
Yes. With Limits and GPS Reporting
Seed
Production
Reported,
2007
Yes
No
Countv
BOX ELDER
CACHE
UJ
2:
to
UJ
X
o
z>
a
<
3
MILLARD
SANPETE
UINTAH
UTAH
WEBER
z
1 —
o
to
<
CHELAN
COWLITZ
DOUGLAS
9
UJ
u.
cc
2
GRAYS HARBOR
ISLAND
Z
o
to
cn
UJ
u.
u.
UJ
O
z
KITSAP
LEWIS
PACIFIC
PEND OREILLE
PIERCE
SAN JUAN
SKAGIT
_aj
ro
55
UTAH
UTAH
X
ID
X
S
D
UTAH
UTAH
UTAH
X
3
UTAH
WASHINGTON
WASHINGTON
WASHINGTON
z
g
CD
z
X
CO
i
WASHINGTON
WASHINGTON
WASHINGTON
WASHINGTON
z
o
I —
0
1
WASHINGTON
WASHINGTON
WASHINGTON
z
o
t—
CD
z
X
<0
s
WASHINGTON
WASHINGTON
NOiONIHSVM
WASHINGTON
WASHINGTON
z
0
0
z
X
CO
1
Appendix B
1064
1065
1066
1067
Arizonia - Alfalfa Hay Counties
With and Without Seed Production
1068
California - Aifalfa Hay Counties
With and Without Seed Production
DEL NORTE
SISKIYOU
SHASTA
TRINITY)
TEHAMA
PLUMAS
GLENN
SIERRA
1ENDOCINO
■YUBAt
f.OLUSA
LAKE'
/ ELDORADO
syot-ojW V ^
'(' ' AMAbOR~>
) SACRAMENTO y z'
SOLANO ] /
, - // \CALA^mRAS
\ii^iN'} -<>1 y
ALHN^
SONOMA
MONO
MARIPOSA
MADERA
X; SANTA CLARA'
SJWTA CRUZ '
SAN BENITO^
KINGS.
SAN LUIS OBISPO:
KERN
SAN BERNARDINO
kANTA BARBARA'
VENTURA.
OMNI
ed Production Reported
’reduction Reported
3d or Hay Production Reported
1069
Idaho - Alfalfa Hay Counties
With and Without Seed Production
1070
1071
Nevada - Alfalfa Hay Counties
With and Without Seed Production
1072
O *;
§
1073
1074
Utah - Alfalfa Hay Counties
With and Without Seed Production
MORGAN
DAWS
PIUTE
WAYNE
GARFIELD
SAN JUAN
WASHINGTON
Alfalfa Hay
'!.] No Seed Production Reported
ili Seed Production Reported
1075
1076
1077
1078
Appendix
C
National Alfalfa & Forage Alliance Best Management
Practices for Roundup Ready® Alfalfa Seed
Production
Best Management Practices
for Roundup Ready® Alfalfa Seed Production
Introduction
The genetic supplier members {hereinafter called the ‘Companies”) of National Alfalfa & Forage Alliance (NAFA)
have agreed to jointly adopt, as a minimum, the following Best Management Practices for Roundup Ready Alfalfa
(RRA) Seed Production in the United States. Compliance is required under a separate and binding agreement of
the Companies to each other in this commitment Forage Genetics International (FGI) is the exclusive licensed
seed producer of RRA and will require ali RRA seed production sub-licensees (herein after called the "RRA Seed
Contractor(s)“) to become a party to this binding agreement. It is not the intent of this document to establish best
management practices for the production of alfalfa seed for GE sensitive markets. Changes to this document v/iil
require a recommendation from the Companies and approval by the NAFA Board of Directors.
Roundup Ready Trait Stewardship in Seed Production
• This document establishes RRA commercial seed production policies that exceed industry standards for Certified
alfalfa seed production.
• Specifically, RRA seed production practices will meet or exceed Association of Official Seed Certifying Agencies
(AOSCA) standards for the seed production of Foundation Class alfalfa seed production.
• All RRA seed growers must complete RRA seed stewardship training and agree to follow the RRA seed production
policies as described herein and as required by RRA seed production contracts.
RRA Seed Contractors’ Responsibilities
Isolation. The RRA Seed Contractor will insure that the isolation distance between the new planting and any
established conventional seed production meets the following pollinator-specific isolation requirements for RRA seed
production, Note the pollinator designated applies to normal pollinating bees introduced or locally cultured for alfalfa
seed production in the area, If more than one pollinator species is introduced or locally cultured, the longer minimum
distance applies.
• Leaf cutter bee - 900 feel
• Alkali bee- 1 mile
• Honey bee - 3 miles
Every year the Companies wilt collectively sample conventional seed lots, test for adventitious presence of
the Roundup Ready trait, and use isolation distance from RRA seed production to monitor the effectiveness of
current isolation standards. The Companies, along with three AOSCA representatives of state crop improvement
associations or their designees, will analyze the data and make recommendations for changes to required isolation
distances, if appropriate.
Reporting. The RRA Seed Contractor shall report GPS coordinates of ail established and planned RRA seed
production fields to local state seed certification officials as early as possible, but no later than two weeks prior to
planting. State officials will confirm minimum isolation and establish a state pinning map for RRA seed production.
The RRA Seed Contractor must authorize state officials to report to any seed grower or seed company, on request,
the isolation distance between a planned new conventional alfalfa seed field and the nearest RRA seed field. GM-trait
sensitive conventional or organic alfalfa seed producers can then use this third party service to assist them in planning
their field locations to meet their company’s isolation or field crop history goals or the certification agent may use the
data to certify a stated isolation distance. The RRA Seed Contractor shall also notify local state seed certification
officials, and officials shall confirm when a RRA seed production field is terminated.
GE-free seed production zones. The RRA Seed Contractor will limit RRA seed production contracts to the following
states: Arizona, California, Colorado, Idaho, Montana. Nevada, Oregon, Texas. Utah, Washington and Wyoming.
The RRA Seed Contractor will also respect any GE-free alfalfa seed production zone designated as such by a
consensus of local seed growers. Recx^nition and designation of such zones will be based on the requirements of
each state, it is envisioned that the local state seed certification agency would play an active role in administering
programs of this nature.
1080
Cooperation. Ail seed companies are enccHjraged to
communicate and work together individually to manage
joint seed quality issues and concerns.
RRA seed grower training. The RRA Seed Contractor
wilt require RRA stewardship training for at! new RRA
seed growers. The RRA seed grower will confirm
having received a copy of the NAFA Best Management
Practices for Roundup Ready Alfalfa Seed Production
(see Appendix 2).
RRA seed grower contracts. The RRAS^d Contractor
shall stipulate which bee species can be intrcKtuced for
pollination and incorporate key grower stewareiship
requirements (as listed below) in RRA seed production
contracts.
License. The RRA Seed Contractor will have an FG!
license for RRA seed production, including reporting
requirements for acreage planted and seed harvested,
by variety.
RRA Seed Growers’
Responsibilities
Monsanto Technology/Stewardship Agreement (MTA).
RRA Seed Grower must sign an MTA and are bound by
the terms outlined in the current Monsanto Technology
Use Guide (TUG). The MTA is a limited-use license for
Monsanto traits, and renews automatically each year.
The TUG is updated annually.
Observe patent rights. All RRA stock seed and
harvested seed contains patent-protected. Roundup
Ready trait, therefore:
• All seed transfer/sale is exclusive between RRA Seed
Grower and the RRA Seed Contractor; no seed may
be sold by RRA Seed Grower to other parties.
• RRA Seed Grower may not save seed for any purpose
as per MTA.
Observe all federal, state and local regulations. It is
the RRA Seed Grower’s responsibility to know and obey
current federal, state and local regulations affecting their
agricultural practices. Some examples are as follows:
Federal Laws and Regulations:
• Pesticide use labels and restrictions;
• U.S. Patent Rights;
• Plant Variety Protection; Federal Seed Act,
• Phytosanitary laws governing import or export of
seeds and pollinators.
State Laws and Regulations:
• Noxious or prohibited weeds, pathogens or insects;
• Pesticide use labels and restrictions
Local Laws and Regulations:
• Pesticide use notifications (field posting);
• County restrictions or prohibitions on the use of
biotechnology, as applicable.
Bees. RRA Seed Grower will man^e polfinatois to minimize
pollen flow to conventional/other variety fidds.
• Only contract-specified bee species can be introduced
for pollination supporting RRA seed production.
• There shali be no bee domicile movement from RRA
to conventional alfalfa seed fields until pollination is
finished for the year.
• Once bees are in RRA seed fields, they may only
be moved among RRA fields. It is the RRA Seed
Grower's responsibility to inform their pollinator
contractors or bee keepers of this requirement.
• RRA Seed Grower will locate domiciles to maximize
domicile distance to other varieties, to the extent
reasonable and appropriate to each field.
• The main pollinator bee species will be stated on each
RRA Seed Grower Contract. Isolation requirements
are specific to the main pollinator species.
• If honeybees are not the contract-stipulated pollinator
species, the RRA Seed Grower will discourage
neighbors from keeping honeybee hives in proximity
to RRA seed production. In cases where this cannot
be avoided, RRA Seed Grower is required to report
the incident to the RRA Seed Contractor.
Isolation. RRA Seed Grower will assist RRA Seed
Contractor with field location planning prior to planting,
isolation zone monitoring after planting and facilitate
crop improvement inspections as requested.
• The pollinator species-specific isolation policy is as
follows (minimum distance to preexisting conventional
seed at planting of RRA):
• Leaf cutter bee - 900 feet
• Alkali bee - 1 mile
• Honey bee - 3 miles
• Once the RRA seed field is planted, State Certification
officials will visit to confirm minimum isolation distances
are in place, RRA Seed Grower must cooperate with
this verification process.
• If the RRA Seed Grower learns that new alfalfa seed
f(eld(s) are planned or planted in close proximity the
RRA seed field. RRA Seed Grower will communicate
thisinformationtoRRASeed Contractor. Management
strategies for maintaining RRA seed quality (varietal/
trait purity) can then be implemented by the RRA
Seed Contractor,
Trait purity, RRA stock seed is guaranteed by the
provider to have 2:90% RR plants; up to 10% non-RR
plants, or "nulls", are normal and expected based on the
breeding and genetics of the trait,
• Growers must apply sufficient Roundup® herbicide to
kill the <10% nulls prior to 9 inches of growth in the
establishment year.
• Apply only registered (labeled) Roundup brand
herbicides to the field.
Weeds and in-crop volunteers. Manage weeds and
volunteers using integrated weed control strategies (e.g,,
conventional practices supplemented with Roundup
agricultural herbicide formulations applied according to
the label for alfalfa seed production). Integrated weed
control strategies:
• Minimize risk of weed shifts or development of tolerant
weeds. Growers are required to use integrated weed
control methods.
• Maintain variety true to type: RRA seed fields need
non-Roundup practices to control in-crop Roundup
Ready alfalfa volunteers sprouting from prior year
)l Alfalfa & Forage Alliance • “Best Management Practices for Roundup Ready^ Alfalfa Seed Production ’
1081
National Alfalfa & Forage Alliance • “Best Management Practices for Roundup Ready’'-’ Alfalfa Seed Production” 3
seed crop in carry-over fields. This is consistent with
conventional alfalfa seed production practices for
certified quality seeds.
Seed box/bin numbers used for harvest;
Stand destruct date and methods used using the RRA
stand take out form, or the equivalent, to report the
information (see Appendix),
Stand take-out.
• The RRA seed field must be destroyed at the
expiration/termination of the seed contract. Take-
out must be completed prior to first flower in the
subsequent year so that seed certification inspectors
can verify stand termination.
• Stand termination and volunteer management
measures must be sufficient to allow seed certification
inspectors to validate stand take-out and to render the
alfalfa stand worthless for any unlicensed purpose
or use (e.g., unlicensed seed, forage, hay or pasture
production purpose).
• RRA stand take-out date and method must be reported
to the RRA Seed Contractor and stand destruction
verified by local crop improvement using the RRA
stand take out form, or the equivalent, to report the
information (see Appendix).
• Plan to use a subsequent crop that allows
management of alfalfa and RRA alfalfa volunteers
should they occur.
RRA Seed Contractors’ Production
Staff Responsibilities
• Working in close partnership with seed growers;
• Complying with binding agreements with local crop
improvement organizations:
• RRA Seed Contractor wilt report each field
location, planting date and stand take-out date to
local crop improvement organizations;
• Coating RRA stock seed purple for easy identification
by seed growers;
• Recommending changes to this document, should
the need arise.
Roundup Ready* and Roundup' are registered
trademarks of Monsanto.
Sanitation requirements. Manage equipment to
minimize seed mixture potential between different
varieties and or variety types. Growers shall use
dedicated equipment for planting and harvesting RRA
seed production, when possible. Zero tolerance for seed
admixture is not feasible under commercial production
conditions; however, grower must take reasonable steps
to assure that equipment is clean prior to and after use in
the Roundup Ready seed field. Examples:
• Planter inspection, clean-down before and after use;
• Combine inspection, clean-down thoroughly before
and after use;
• RRA seed bins may only be used for RRA seed;
maintain physical separation of varieties in storage;
inspect bins before use;
• Handle ail iike-trait varieties together; plan for harvest
sequence of fields to maintain best separation of
varieties by trait type;
• Clean all seed handling equipment to avoid mixing
RRA and conventional seed:
• Return unused, unopened stock seed to the
contracting seed company for credit; maintain in
clean storage areas:
• When a contract harvester is used for RRA seed
harvest, Growers must notify the contract harvester, in
advance, that the field to be harvested is RRA.
Tom Braun, Midwest Forage Association
Reedsvtife, W!
Jim Cane, USDA-ARS, Logan Bee Lab
Logan. UT
<%uck Deatharage. CA Alfalfa Seed Prod. Rstx:h.:BfcS, ,
•San Joaquin,: GA.'v\
Paul Fr?y. CalAAfest Seeds
yvoodland, CA
Chep .Gauntt 'VV&8hlngtpn.^ay Growers Association , ;
KennewtcK,WA ^
Frederick Kirscheitinann l.i I Ctr. fo- Si'vvni ab c-
Agric;vM\eS| lA »
Mark McCastin, Forage Gqnr tics Internati''"''*
;st Paul._.^ V
Dave'Miller..Pib)|serrt-Bredli'’i. vii' i i ^
Arlington. W1 'i;.’
Dan Putnam, Universi^ofCti'i 1 1 la
, Davis.' CA:-"-, -.Li
Dan Undersander. Universily ' v\ scsM' m i
Communication. Immediately communicate questions
or concerns to the RRA Seed Contractor or to FGI.
Totichet.:^
Field records. RRA Seed Grower must record and
communicate the following to RRA Seed Contractor:
• Planting date; actual acres planted; seed rate/acre;
stock seed received/returned;
• Accurate field address with latitude/longitude (decimal
degrees) and local field map;
• Roundup herbicide application date(s), rate{s),
formulation used;
1082
Appendix 1
VERIFICATION OF STAND TAKE-OUT TO TERMINATE THE PRODUCTION OF
ROUNDUP READY* ALFALFA SEED
The AGREEMENT: The Grower planted the RRA Proprietary slock seed described below on the acreage
described below, in accordance with the terms of tee Proprietary Seed Services Agreement for the Production of
Roundup Ready Alfalfa Seed, upon expiration ot termirtafion of the agreement, the grower must take such
actions as are necessary to prevent any fuhire seed harvest ot unlic«Tsed use for hay, forage or grazing. Stand
destruction must occur not later than first Bower in subsequent year. Grower must notify Contracting Seed
Company of each stand take-out date and method used to destroy the stand. The Contracting Seed Company
must perform on-site verification that each field has been kBied and Contracting Seed Company will notify local
crop improvement organization of stand termirraticm.
Use a separate form for each field or field group reported to crop improvement.
Experimental or Variety Name:
#
Field
names
Number of
Acres
Field Location:
Town-Range-
Section
& County
Latitude /
Longitude
(original
GPS
Coordinate)
# ACRES +
DATE(s) +
METHOD(s)
SITE VISIT
VERIFiCATIO
N DATE(s)*
1
2
3
Total no.
acres this
contract
planted:
X, V ''v,''
^ \ ' '
Total no. acres
reported to be
killed:
Seed Company representative verifying information
SignaturB{s) Date(s)
Seed Company representative notifying Crop
Improvement
Signature(s) Dale{s)
GROWER
CONTRACTING SEED COMPANY
Bv:
fstanalure)
Bv;
(sionaiure)
Bv:
(CHinted name)
Bv;
(primed name)
Title;
Title;
Comoanv:
Comoanv;
Address:
Address:
tal Alfalfa & Forage Alliance > “Best Management Practices for Roundup Ready^ Alfalfa Seed Production"
1083
Appendix 2
These signatures confirm that the RRA Seed Grower has received the
NAFA Best Management Practices for Roundup Ready^ Alfaifa Seed Production
Contracting Seed Company has communicated NAFA Best Management Practices for
Roundup Ready Alfalfa Seed Production to the Grower prior to initial RRA seed field
planting and will update Grower annually, thereafter.
RRA Seed Contractor Representative Conducting Initial Grower Training:
Seed Company Representative:
Date:
RRA Seed Grower Acknowledgement of Training and/or Receipt of NAFA Best
Management Practices for Roundup Ready Aifaifa Seed Production:
PRINT NAME AND ADDRE S S
Grower:
SIGNATURE AND DATE
Telephone number:
Signature page original to be retained by RRA Seed Contractor.
Signature page copy to be retained by RRA Seed Grower.
1084
Appendix
D
Orloff, S., D.H. Putnam, M. Canevari and W.T.
Lanini, Avoiding Weed Shifts and Weed Resistance
in Roundup Ready Alfalfa Systems, University of
California Division of Agriculture and Natural
Resources Publication 8362 (2009)
1085
University of California
Division of Agriculture and Natural Resources
http://anrcatalog.ucdavis.edu
UCil
..PEERSfJI
REVIEWED
Ifoiding Weed Sliifts aid
Weed iesislaiice in
iomclup Ready Alfalfa Systems
STEVE B. ORLOFF, University of California Cooperative Extension Farm Advisor, Siskiyou
County; DANIEL H. PUTNAM, Extension Agronomist, Department of Plant Sciences,
University of California, Davis; MICK CANEVARi, University of California Cooperative
Extension Farm Advisor. San joaquin County, and W. THOMAS LANiNi, UC Cooperative
Extension Weed Ecologist, Department of Plant Sciences, University of California, Davis
OVERVIEW
Weeds present a continual challenge for profitable alfalfa production. The
Roundup Ready (RR) production system, using transgenic alfalfa, has the
potential to simplify weed management by improving
broad-spectrum control of both annual and difficult-
to-control perennial weeds. The use of glyphosate, in
combination with transgenic crops, has proven to be a
reliable weed control strategy.
However, wceti species shifts and the selection for glyphosate-resistant weeds can
result from the increased use of this teduiology if the crop is not managed properly
from the outset. Aspects ofthe alfalfa production system both favor and discourage
the occurrence of weed shifts and the evdution of resistant weeds. Alfalfa is a
competitive perennial crop that is cut multiple times per year, making it difficult for
most weeds to become established. On the odier hand, the RR alfalfa .system may
be vulnerable to weed shifts and resistant weeds for several reasons: tillage typically
only tKcurs between crops, alftilfa is produced over a wide geographical area and
in large fields with a great diversity of weeds, and there is potential for long-term
repeated use of a single herbicide because it is a perennial crop. In this publication
we reawnmend an tnlegratetl wad management system designed to prevent the
proliferaticm of tolerant or resistant weeds. Elements include crop rotation, rotations
with herbicides of different modes of action (preferably soil-residual herbicides), tank
mixtures, and irrigfUitMt and harvest timing. Successful adaptation of these concepts
into {^eduction systems would assure the long-term effectiveness and sustainability
of the Roundup Ready .s)eiten\ in alfalfe. A preemptive approach is warranted; these
strati^es should be employed before weed shifts and weed resistance occur.
1086
Avoiding Weed Shifts and Weed Resistance in Roundup Ready Alfalfa Systems
ANR Publication 83S2 2
IMPORTANCE OF
WEED CONTROL IN ALFALFA
Alfalfa, the queen of forages, is the principal forage
crop in the United States and frequently the third
most important crop in value. It is a vital component
of the feed ration for dairy cows and is a principal
feed for horses, beef cattle, sheep, and other livestock.
Because animal performance cfopends ujwn the
paiatability and nutritional value of altalfe, livestock
managers, especially those in the dairy and horse
industry, expect high-quality hay. Althou|^ many
factors influence quality, the presence of grassy
and broadleaf weeds {of low forage quality) plays a
significant role in reducing the feeding value of hay
throughout the United States. Weeds that accumulate
nitrates or are poisonous to livestock are also a major
concern in alfalfa, since poisonous weeds sicken
or kill animals every year (Puschner 2005). Most
livestock producers demand weed-free alfalfa for
optimum quality and maximum animal performance.
Weed-free alfolfa can be difficult to achieve,
whether using nonchemical methods or conventional
herbicides. Typically, no single herbicide controls all
weeds present in a field, and some weeds— especially
perennials— are not adequately controlled with any
of the currently registered conventional herbicides.
Cultural practices such as modifying harvest
schedules, grazing, time of planting, and use of nurse
crops such as oats {Avena sativa I..) help suppress
weeds; however, these practices arc almost never
entirely effective and some of them suppress alfalfa
seedling growth. In addition to being difficult to
achieve, complete weed control in alfalfa
I is costly. Alfalfa growers continually seek
ways to enhance the level of weed control
while minimizing costs.
°,mtt 1 alfalfa TECHNOLOGY
to deal I Glyphosate (Roundup) is generally
‘the most considered the most effective broad-
T specitunt post-emergence herbicide
' ■^1 available. The first commercially
5 available glyphosate-rcsistant crops
were soybean, canola, cotton, and corn,
which were released in 1996, 1997, 1997, and 1998.
respectively, Glyphosate-resistant or Roundup
Ready alfalfa (RR alfalfa) was developed through
biotechnology in late 1997 and became commercially
available in the fall of 2005. This technology imparts
genetic resistance to glyphosate by inserting a single
gene from a soil bacterium into alfalfa. These
biotechnology-derived alfalfa plants have an altered
enzyme that allow.s them to tolerate a glyphosate
application while susceptible weeds are killed.
Glyphosate resistance is the first commercially
available, genetically engineered (GE) trait in alfalfa.
This technology was a major development
In alfalfa weed control, providing growers with a
useful weed management too! and a means to deal
with some of the most difficult-to-control weed
species. Researchers have evaluated its effectiveness
as a weed control strategy (Canevari et al. 2007;
Sheaffer et al. 2007; Steckel et al. 2007, Van Deynze
et al. 2004). The advantages and disadvantages of
this technology have been reviewed (Van Deynze
et al. 2004). Glyphosate was found to be especially
effective for weed control in seeding alfalfa
(Canevari et al. 2007). Glyphosate typically causes
no perceptible crop injury, is much more flexible and
less restrictive in application, and provides superior
weed control across a range of weed species when
compared with other currently used herbicides. One
of the greatest advantages of this technology is that it
provides a tool for suppressing perennial weeds such
as dandelion (Taraxacum officinale), yellow nutsedge
(Cyperus esculentus L.), bermudagrass (Cynodon
dactylon (L.) Pers.), and quackgrass (Blytrigia repens
(L.) Nevski) that have not been adequately controlled
with conventional practices.
After deregulation of this trait in 2005, over
300,(K)0 acres of RR alfalfa were planted in the
United States, about 1.4 percent of US. acreage.
(For equivalents between US. and metric systems of
measurement, a conversion table is provided at the end
of this publication.) However, in the spring of 2007,
further plantings were suspended pending the outcome
of a legal challenge and further environntcntal analysis
by the US. Department of Agriculture’s Animal and
Plant Health inspection Service (USDA-APHIS). There
were two key issues in this proce,ss: the possibility of
contamination of organic and conventional alfalfa
through the adventitious presence of the gene, and
the possibility of a greater level of weed resistance due
to the adoption of the Roundup Ready technology in
alfalfr (USDA 2008),
Grower experience In commercial fields
following deregulation confirmed many of the
benefits that early research had suggested in terms of
the efficacy and safety of the RR system (Van Deynze
ct al. 2004). Growers have generally found that this
technology is easy to use and provides superior weed
1087
Ai/oiding Weed Shifts and Weed Resistance in Roundup Ready Alfalfa Systems
ANR Publication 8362 3
control and improved forage quality in many cases
compared with conventional herbicides. However,
no new technology is a panacea, and, like other weed
control strategies, RR alfalfa has its limitations. An
important limitation of this new weed-man^ement
system is the potential for weed shifte and weed
resistance. This publication discusses techniques that
are available to manage the po^bility of weed shifts
and weed resistance occurring in Roundup Ready
alfalfa weed coiUrol systems.
WEED SHIFTS AND WEED RESISTANCE
Change in weed populations as a result of repeated
use of a single herbicide is not a new phenomenon.
vSuch changes result from shifts in the weeds present
from susceptible to tolerant species, or conversion of
a population within a species to resistant individuals,
as a consequence of selection pressure (Holt and
LeBaron 1990; Prather et al. 2000).
Weed Shift
A weed shift refers to a change in the relative abundance
or type of weeds as a result of a management practice
(fig. 1), The management practice could be herbicide
use or any other practice sucit as tillage, manure
application, or harvest schedule that brings about a
change in weed species composition.
In the case of chemical weed control, no single
herbicide controls al! weeds, as weeds differ in their
susceptibility to an herbicide. Susceptible weeds are
largely eliminated over time with continued use of
the same herbicide. This allows inherently tolerant
weed species to remain, which often thrive and
proliferate with the reduced competition. As a result,
there is a gradual shift to tolerant weed species
when practices are continuously used that are not
effective against those species. A weed shift does not
necessarily have to be a shift to a different species.
For example, with a foliar herbicide without residua!
activity like glyphosatc, there could also be a shift
within a weed species to a late-emerging biotype that
emerges after application. In the case of weed shifts,
the total population of weeds does not necessarily
change as a result of an herbicide or an agronomic
practice; these practices simply favor one species (or
biotype) over another.
Weed Resistance
In contrast to a weed shift, weed resistance is
a change in the population of weeds that were
previously susceptible to an herbicide, turning
them into a population of the same species that is
no longer controlled by that herbicide (fig 2).
Figure 1. Weed shifts due to herbicide application. A weed species shift occurs when both susceptible and tolerant weed species are
present in a field. After continued use of a single herbicide, the susceptible weed species is nearly eiiminated. The tolerant weed species
survives and proliferates, eventually becoming the prevailing species. In this example, a shift to a broadleaf weed is favored by use of a
grass herbicide. ^ ^ ^
Figure 2. Evolution of herbicide resistance due to selection pressure. An herbicide controls susceptible weeds, preventing them
from reproducing and leaving only those individuals carrying the genes for resistance. Typically an extremely small percentage of the
weed population initially possesses the genes for resistance. These altered genes are thought to exist in weed populations at very
low frequencies. As repeated use of an herbicide controls the susceptible individuals, the resistant weeds continue to multiply and
ultimately become predominant.
4- '-f 'If $'-ih /
t % %/
%/
/Va H
H,
A- ^"1 /
population after years of selection pressure
1088
Avoiding Weed Shifts and 'Weed .Resistance in Roundup Ready A^affa Systems
ANR Publication 8362 4
While weed shifts can occur with any s^onomic
practice (crop rotation, tillage, frequent harwsts, or
use of particular herbicides), the evolution of weed
resistance is only the result of continued herbicide
application. The use of a single class of herbicides
continually over time creates selection pressure so
that resistant individuals of a species survive and
reproduce, while susceptible ones are killed.
Which Is More Important Weed Shifts or
Weed Resistance?
A weed species shift is far more common than weed
resistance, and ordinarily takes less time to develop.
If an herbicide does not control all the weeds, the
tendency is to quickly jump to the condusion that
resistance has occurred. Howver, a weed shift is a far
more likely explanation for weed escapes following
an application of glyphosate. See table 1 for a list
of weeds sometimes found in alfalla fields that are
tolerant to or difficult to control with glyphosate.
Are Weed
Shifts or Weed
Resistance
Linked Only
to Ceneticaliy
Engineered
Crops?
A common
misconception is that
weed resistance is
intrinsically linked to
genetically engineered
(GE) crops. However,
this is not correct.
The occurrence of
weed shifts and weed
resistance is not
unique to genetically
engineered crops.
Weed shifts and
resistance are caused
by the practices that
may accompany a GE
crop (for example,
repeated use of a
single herbicide),
not tlie GE crop
itself. Similarly,
some people believe
that herbicide
Table 1 . Annua! weeds encountered in alfalfa
fields that are potential candidates for weed
shifts in continuous glyphosate systems
1 Latin name
; Common name I
Brassica nigra*
black mustard
Chenopodlum album*
iambsquarters
Bchinochloa cohna’
junglerice
Epilobium
Wiltowherb, panicle
brachycarpum*
willowherb, panicle
Eragrostls* ;
lovegrass
Erodlum spp.* ..
fiiaree
Lamium amplexicaule ' .
henbit
Loltum mu/f/florum**
ryegrass
Malvaporvlflbra*. ..
malva (cheeseweed)
Polygonum
convolvulus'
wild buckwheat
Polygonum spp.'
knotweeds
Portulaca oleracea'
purslane
Sonchus oleraceus'
annua! sowthistle
Trifolium spp.*
clover
Urtka urens*
burning nettle
Note-.lhs table Includes weeds that are listed as susc^stsUe
on the label but are difficult to control ar,d weeds which are
not controlled by glyphosate.
’Glyphosate-toierant weeds — not listed as controfied on
product label.
’Oifftcult to control weeds.
‘Giyohosate-resistani biotype has been confirmed.
resistance is transferred from the GE crop to weed
species. However, unless a crop is genetically very
closely related to a naturally-occurring weed, weed
resistance cannot be transferred from crop to weed.
In the case of alfalfa, there are no known wild plants
that cross with alfalfa, so direct transfer of herbicide
resistance through gene flow to weedy species will
not occur. However, the glyphosate-toierant genes
from RR alfalfa can be transferred to feral (wild)
alfalfa plants if cross pollination occurs.
Link to Management Practices
The development of weed shifts or the evolution
of weed re.sistancc in cropping systems is primarily
a result of management practices, not the crop
itself. Continued use of the same management
practice, in this case the use of a single herbicide,
increases the probability of a weed shift or the
evolution of resistant weeds as a result of constant
selection pressure. For example, if the herbicide
diuron (Karmex) is used alone for several years in
established alfalfa, susceptible weeds are controlled.
However, there is likely to be an increase in
tolerant weeds such as common groundsel {Senecio
vulgaris), Persian speedwell {Veronica persica), and
others. Similarly, if imazethapyr (Pursuit) is used
repeatedly for several years without rotating with
other herbicides, there is likely to be an increase
in the population of prickly lettuce {Lactuca
serriola), annual sowthistle {Sonchus oleraceus),
and many grassy weeds that are not controlled by
this herbicide. Rigid ryegrass {Lolium rigidum)
and horseweed (Conyza canadensis) resistance to
glyphosate was the outcome of repeated glyphosate
applications in California orchards and noncrop
settings, respectively. Weed shifts and weed
resistance are not new; evolved resistance was first
reported in the 1970s and now occurs with a range
of hert)icide classes (Holt and LeBaron 199Q; Heap
1999; Heap 2008).
RR Crops Present a Challenge
Transgenic herbicide-resistant crops do,
nonetheless, have greater potential to foster
weed shifts and resistant weeds since a grower is
more likely to use a single herbicide repeatedly
in herbicide-resistant crops such as RR alfalfa.
Additionally, the accumulation of acreage of
different RR crops (corn, .soybean, and cotton)
could increase the potential for weed shifts or weed
resistance in cropping systems utilizing RR crops.
This is because the probability of repeated use of the
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Ai,’oiding Weed Shifts and Weed Resistance in Roundup Ready Alfalfa Systems
ANR Publication 8362 5
annual sowthistle were not adequately controlled
with any of the glyphosate rates (fig. 3). During
the 3 years of this field trial, when glyphosate w'as
used repeatedly, there was a gradual weed species
shift away from annual bluegrass and shepherds
purse to higher populations of burning nettle and
annual sowthistle (figs. 4A and 4B). A tank mix of
glyphosate and Veipar, or a rotation to Velpar and
Gramoxone, was needed to adequately control all
weed species at this location.
To our knowledge there have been no
documented cases of weed resistance in alfalfa
during the first 3 years of RR alfalfa production
(2005 to 2008) in the United States.
Figure 3. Weed control 69 days after treatment in an established stand of
Roundup Ready alfalfa, San Joaquin County, California, 2004.
Roundup Roundup Roundup Roundup+ Gramoxone +
UM0.5ai/A UMl.Oai/A UM2.0ai/A Velpar Velpar
0.375+0.5 0375+0.5
G annual blue grass Oannual sow thistle B shepeid's purse
n burning nettle ^chtekweed
WEED SHIFTS AND
RESISTANCE WITH RR ALFALFA
The possibility of weed shifts and weed resistance is
a concern with RR alfalfa. This Ls due to its perennial
growth habit, its long stand life, and the potential
for repeated use of a single herbicide over several
years without crop rotation. Although some stands
last 3 to 4 years, it is common in many areas of the
United States to keep an alfalfa stand in production
for 5 to 7 years or longer. If the rotation crop (e.g. a
grain crop) is not treated with an herbicide, an even
longer period of time without herbicide diversity
could occur. In this instance, weed populations
could slowly return to preglyphosate composition,
but the new species or resistant biotypes would
not disappear. In areas where alfalfa is rotated with
transgenic RR corn, cotton, or soybean varieties, this
same herbicide is higher and the potential applied
acreage (and therefore the size and genetic diversity
of the weed population) is greater. Fortunately, there
are simple methods available to pre\^ni weed shifts
and weed resistance from occurring.
In studies conducted in San Joaquin County,
California, weeds shifts were found to occur during
the first few years of use when glyphosate-tolcrant
weeds were present (Van Deynze et al. 2004). Annual
bluegrass and shepherd’s purse were adequately
controlled with glyphosate, whereas chickweed
control was about 80 percent and burning nettle and
Figure 4. (A): Increase in burning r^ettie population in Roundup Ready alfalfa with repeated annual applications of glyphosate alone, San
Joaquin County, California, 2006. (B}: Plot overtaken with burning nettle after 3 years of continual glyphosate use. Pftofos; Mick Canevari:
insert. J.M. DiTomaso, from DiTomaso and Healy 2007, p. 1565.
Oct. 2002 Oct. 2003
Evaluation date
1090
Avoiding Weed Shifts and Weed Resistance in Roundup Ready Aijaifa Systems
AMR Publication 8362 6
again could result in a prolonged time period where a
single herbicide is used repeatedly.
There arc aspects of the alfalfa production
system that both favor and discour^ the development
ot weed shifts and the evolution of r^istant weds.
Attributes of Alfalfa That
Favor Weed Shifts and Resistance
hirst, crop rotation opportunities widt a perennial
crop like alfalfa are significantly reduced oMnpared
with annual cropping systems. Mechanical weed
control, such as cultivation, is impractical in a solid-
seeded perennial crop like alfalfa, and hand weeding
IS not economical. Aifalfo is grown over extensive
acreage in the United States and fields can be large
in size; therefore, the overall weed flora available
for selection of resistant traits or for weed shifts is
plentiful. Perennials like alfalfa, if sprayed repeatedly
witli the same herbicide, are likely candidates for
weed shifts and weed resistance.
Attributes of Alfalfa That
Discourage Weed Shifts and Resistance
On the other hand, many weeds do not flourish In
an alfalfa field due to its perennial nature and the
competitiveness of the crop after establishment.
Alfalfa is an aggressive competitor with most weeds,
which fail to establish in alfalfa fields due to the crop’s
vigorous growth and shading ability. In addition,
many weed species do not tolerate the frequent
cutting that occurs in alfalfa fields, The lack of soil
disturbance once the alfalfa stand is established also
reduces opportunities for germination of some weed
species. Furthermore, the interval between alfalfa
cutting.^ is short enough that seed production for
many weeds is reduced compared with annual crops
that allow completion of the weeds’ life cycles.
Risk of Resistance Generally Lower with
GiyphosaCe Than with Other Herbicides
Weed shifts or resistant weeds are unavoidable
and will occur eventually with any herbicide used
repeatedly, and the same is true with the use of
glyphosate (Heap 1999). Fortunately, resistance to
glyphosate is not as common as resistance to many
other herbicides, such as acetolactate synthase (ALS)
and acetyl-CoA carboxylase (ACCase) herbicides that
have a single binding site and single target enzyme
mechanisms of action (Heap 2008). The relatively
low rate of resistance in weeds to glyphosate relative
to the widespread use of this chemical has not been
fully explained, but may be due to the number or
frequency of mutations that may be required to confer
r^istance to glyphosate. Two resistance mechanisms,
a weak target site mutation, and a reduced glyphosate
translocation mechanism have been documented
in weed species that have evolved resistance to this
herbicide (Powles and Preston 2006).
Regardless of the mechanism, weed resistance
to glyphosate is not as common as resistance to
other herbicides. However, cases of weed resistance
to glyphosate have been documented and are
increasing. There is a range of species across the
worid with documented resistance to glyphosate
(table 2). Fortunately, most of these species are
not common in alfalfa fields. Two weed species in
particular have evolved resistant populations in
California: LoUum spp. (ryegrass) and Conyza sp.
(marestail). The latter is not important in alfalfa,
but ryegrass is frequently found in alfalfa fields.
Glyphosatc-resistant ryegrass is increasing in the
Sacramento Valley and northern San Joaquin Valley
of California and may become problematic during
fail stand establishment of RR alfalfa.
Weed shifts and/or weed resistance have
occurred with the other transgenic RR crops
released before RR alfalfa (Duke and Powles 2008).
Weed resistance is of greater concern than weed
shifts and has occurred in RR soybean, cotton, and
corn in less than a decade
after their initial release (see
table 2). Alfalfa growers can
learn from experience with
these crops and in noncrop
areas as a preemptive
measure to avoid, or at least
minimize, the problems
with weed shifts and weed
resistance. These problems
are sure to occur in alfalfa
if proper weed management
practices arc not followed,
WEED MANAGEMENT PRINCIPLES
TO REDUCE WEED SHIFTS AND
RESISTANCE IN ALFALFA
Glyphosate-resistant crops have provided growers
with an easy-to-use, iow-cost, and effective weed
management tool However, the effectiveness of
weed control systems using RR crops can make
grower-s complacent in their weed control practices.
Even though this technology is highly effective,
growers must follow sound weed management
1091
Abiding Weed Shifts and Weed Resistance in Roundup Ready Alfalfa Systems
ANR Publication 8362 7
principles to prevent short- or long-term weed shifts
or weed resistance from occurring. This includes
weed identification, crop rotation, attention to
application rate, proper timing of application,
herbicide rotation, and lank mixtures.
Weed Identification
Effective weed management practices begin with
proper identification to assess the competiveness of
the weeds present and to select the proper herbicide
if one is needed. A weed management strategy to
prevent weed shifts and weed resistance requires
knowledge of the composition of weeds present.
Identification of young seedlings is particularly
important because seedling weeds are easier to
control. Resources for weed identification can be
found at the UC IPM Web site (http://www.ipm.
ucdavis.edu/PMG/weeds_common.html) and at
the UC Weed Research and information Center
Web site (hltp://wric.ucdavis.edu/information/
information.html).
Table 2. Giyphosate-resistantweed populations
1 ' : , . Location of | Year first .
|:l,Resi5tantweed Common niM« v resistant poplhitions s ^ituationtsi reported "
1 UNITEDSTATE$ . s I 1 ! ilntlKU.S.)
Amaranthus palmsri
Palmer amaranth
Arkansas, Georgia, North Caroiina,
Mississippi, Tennessee
corn, cotton, soybean
2005
Amaranthus rudis
common waterhemp
Illinois. Kansas. Minnesota, Missouri
corn, soybean
2005
Ambrosia artemisiifolia
common ragweed
Arkansas, Kansas, Missouri
soybean
2004
Ambrosia trifida
giant ragweed
Arkansas, Indiana, Kansas, Minnesota,
Ohio, Tennessee
cotton, soybean
2004
Conyza bonariensis
hairy flea bane
California
roadsides
2007
Conyza canadensis
horseweed (marestail)
17 states including California
cotton, nurseries, road-
sides (in CA), soybean
2000
Loltum multtflorum
Italian ryegrass
Mississippi , Oregon
cotton, orchards,
soybean
2004
Lolium rigidum
rigid ryegrass
California
orchards ,
1998
Sorghum halepsnse
Johnsongrass
Arkansas
soybean. . ■
2007
1 ■■ a
memt'
, (kttfiiWorid)
Conyro bonariensis
. hairy fleabane
Brazil, Colombia, South Africa, Spain
corn, orchards, soy-
bean, vineyards, wheat
2003
Conyza canadensis
horseweed (marestail)
Brazil. China, Czech Republic, Spain
orchards, soybean,.,
railways
2005 .
Dlgitaria Insularis
sourgrass
Brazil , Paraguay
soybean
2006
Echinochloa colona
junglerice
Australia (New South Wales)
cropland
2007
Eleusine indica
goosegrass
Colombia , Malaysia
cropland, orchards
1997
Euphorbia heterophylla
wild poinsettia
Brazil
soybean
2006
Lolium multifiorum
Italian ryegrass
Argentina. Brazil. Chile, Spain
cropland orchards,
soybean
2001
Lolium rigidum
rigid ryegrass
Australia, France, South Africa, Spain
asparagus, orchards,
railways, sorghum,
vineyards, wheat
1996
Plantago lanceolata
buckhorn plantain
South Africa
orchards, vineyards
2003
Sorghum halepense
Johnsongrass
Argentina
soybean
2005
Urochloa panicoides
liverseedgrass
Australia {New South Wales)
sorghum, wheat
2008
Source: International Survey
] ierhicide Resistant Weeds, adapted from Heap 2008.
Avoiding Weed Shifts and Weed Resislance in Roundup Ready Alfalfa Systems
ANR Publication 8362 8
. Using an effective . : .
herbicide with a different
■ mode of action from the - ..
one to which the weeds . ■
■ are resistant controls.
both the susceptible and- :
resistant biatypes, thus
preventing-reproduction
. , and slowing the spread of
the resistant biotype.: - -
Frequent Monitoring for Escapes
It ts difficult to detect an emerging weed shift or
weed resistance problem if fidds are not frequently
monitored for weeds that escape current weed
management practices. IdentlRcation and frequent
monitoring can detect problem weeds early and
guide management practices, including herbicide
selection, rate, and timing.
Herbicide Rate and Timing
It IS important to use the appropriate rate and
timing for the weeds present. For example, some
weeds that are considered somewhat tolerant to
glyphosate (cheeseweed, filaree, and purslane) can
be controlled effectively in seedling alfalfa with
glyphosate, provided the proper rate is used and
the application is made when the weeds are very
small. Research m Nebraska over a 7-year period
(Wilson 2004) demonstrated a rapid increase in
lambsquarters when a tow rate of glyphosate {0.5
lb ai/acre) was applied, but a higher rate (I.O lb ai/
acre) successfully controlled this weed. Just like with
traditional weed management programs, the grower
must be sure to use the recommended rate for the
weed species present and treat at the appropriate
time when the weeds are still small.
Crop Rotation
One of the most effective practices for preventing
weed shifts and weed resistance is crop rotation,
which allows growers to modify selection pressure
imposed on weeds. Continuous (also called back-
to-back) alfalfa ts not recommended for other
agronomic reasons, but especially would be ill
advised when it comes to management of resistance
and weed shifts. Crops differ in their ability to
compete with weeds; some weeds arc
I a problem in some crops, while they
I arc less problematic in others. Rotation
I therefore would not favor any particular
i weed spectrum. Crop rotation also
allows the use of different weed control
I practices, such as cultivation and
: application of herbicides with different
: sites of action. As a result, no single
weed specie.s or biotype should become
] dominant. The effectiveness of crop
- rotation to manage weed shifts and
resistance is substantially reduced if
another RR crop (such as corn or cotton) is planted
in rotation with RR alfalfa, since the same herbicide
and selection pressure would likely occur.
Agronomic Practices
In addition to crop rotation, several management
practices may have an impact on the selection
of problem weed populations. If problem
weeds germinate at a specific time of year, crop
seeding date can be shifted to avoid these weed
populations, allowing a vigorous alfalfa crop to
develop that is capable of outcompeting weeds.
Delaying irrigation after alfalfa cutting can reduce
germination of certain summer annual weeds.
However, this practice only works on some soil
types, and water stress in alfalfa can reduce yields.
Harvest management can, in some cases, assist
in eliminating or suppressing problem weed
populations, but harvests must occur before weed
seed production to prevent weed proliferation.
Rotation of Herbicides
Weed shifts occur because herbicides are not
equally effective against all weed species and
herbicides differ greatly in the weed .spectrum they
control. A weed species that is not controlled will
survive and increase in density following repeated
use of one herbicide. Therefore, rotating herbicides
is recommended. Rotation of herbicides reduces
weed shifts, provided the rotational herbicide is
highly effective against the weed species that is not
controlled with the primary herbicide. The grower
should rotate to an herbicide with a complimentary
spectrum of weed control, along with a different
mechanism of action and therefore a different
herbicide binding site. Weed susceptibility charts
are useful to help develop an effective herbicide
rotation .scheme (Canevari et al. 2006). In addition,
publications on herbicide chemical families arc
available to assist growers in choosing herbicides
with different mechanisms of action (Retzinger and
Mallory-Smith 1997).
Rotating herbicides is also an effective strategy
for resistance management. Within a weed species
there are different biotypes, each with its own
genetic makeup, enabling some of them to survive
a particular herbicide application. The susceptible
weeds in a population are killed, while the resistant
ones survive, set seed, and increase over time. Using
an effective herbicide with a different mode of
action from the one to which the weeds are resistant,
however, controls both the susceptible and resistant
biotypes. This prevents reproduction and slows the
spread of the resistant biotype.
1093
Avoiding Weed Shifts and Weed Resistance in Roundup Ready Alfalfa Systems
ANR Publication 8362 9
Herbicide Tank Mixtures
t or the same reasons that rotating herbicides
IS effective, tank mixing herbicides is also
recommended. The key is to sdect tank mix partners
that have different target sites and that compliment
each other so that, when combined, they prowde
complete or nearly complete weed control,
RECOMMENDED WEED MANAGEMENT
PROGRAM FOR RR ALFALFA
The cost of RR alfalfa seed, including the technology
fee, is generally twice or more than that of
conventional alfalfa seed. Naturally, growers will want
to recoup their investment as quickly as possible.
Therefore, considerable economic incentiw exists for
the producer to rely solely on repeated glyphosate
applications alone as a weed control program. Some
producers may even be inclined to shave the rates to
the minimum amount that would provide acceptable
weed control. While relying solely on glyphosate and
shaving rates may provide satisfactory results In the
short term, it is a risky practice in the long run as it
will accelerate weed species shifts and the evolution
of resistant weeds. Sound weed management
practices should be employed to maintain the
effectiveness of the RR technology.
Roundup Ready alfalfa is still a relatively new
technology, so there has been limited field experience
with it to date, The following are some suggestions to
consider based upon proven resistance management
strategies, our understanding of alfalfa production
practices, and our initial experience with RR alfalfa.
Ultimately, growers and pest control advisors hold
the key to avoiding weed shifts and resistance by
reducing selection pressure, which is accomplished by
developing a weed management program that does
not rely solely on the continuous use of glyphosate.
Any management practice that reduces the selection
pressure (in this case, the selection pressure imposed
by continual use of the same herbicide) will help avoid
weed species shifts and resistance.
For Seedling Alfalfa, Use Glyphosate Alone
or in a Tank Mix Combination
Seedling alfalfa is most vulnerable to weed
competition because wecd.s are often more vigorous
and competitive than young alfalfa. Additionally,
complete weed control in seedling alfalfa is often
difficult to achieve and frequently requires tank
mixes of different herbicides to control the broad
spectrum of weeds found in an individual field.
Yield and stand loss from weed competition, and
injury from conventional herbicides, are usually
far greater in seedling than in established alfalfa.
Numerous field trials throughout the United States
have proven the effectiveness of RR alfalfa for
stand establishment Superior weed control with
no perceptible alfalfa injury has occurred in most
studies. Therefore, it is only logical to use glyphosate
for weed control in RR seedling alfalfa for the cost
savings, improved weed control, reduced crop injury,
superior stand establishment, and the elimination of
the small percentage of alfalfa seedlings (commonly
called nulls) that do not carry the RR gene. Delayed
removal of these nulls may cause weed control
problems in the future by creating open spaces for
weeds to grow.
Ordinarily, 1.0 pound per acre active
ingredient of glyphosate is sufficient for weed
control during the seedling period. However, a
higher rate may be needed if the field contains some
of the more tolerant weeds listed in table I. A tank
mix may be advised if especially-difficult-to-control
weeds are present. For example, a tank mix of
glyphosate with imazamox (Raptor) or imazethapyr
(Pursuit) may be advised if burning nettle is present,
or a tank mix with clethodim (Prism) will be
necessary if the field or surrounding area is known
to have glyphosate-resistant ryegrass.
Rotate or Tank Mix Herbicides at Least
Once During the life of an Alfalfa Stand
Alfalfa stand life varies considerably throughout the
western United States depending on the production
area, grow-er practice, and the existence of profitable
rotation crop options. A stand life of 3 to 5 years
is common in the Central Valley of California
and other warm, long growing-season areas of the
Southwe.st. A stand life of 5 to 7 years is common
in much of the Northwest, and some alfalfa stands
remain in production in excess of 10 years. As
suggested by the principles outlined above, it is
unwise to rely solely on glyphosate applications for
weed control throughout the life of a transgenic
alfalfa field. This practice would encourage weed
shifts and resistance, and over time weed control
would diminish in most cases. Once an herbicide is
rendered ineffective as a result of resistant weeds,
its usefulness as a weed control too! may be greatly
diminished. After a resistant weed population has
gained a foothold, it is practically impossible to
eliminate it due to the presence of a weed seedbank.
1094
Afjoicling Weed Shifts and Weed Resistance in Roundup Ready Alfalfa Sysfems
ANR Publication 8362 10
control weeds that compete durir^g
stand establishment
glyphosate
glyphosate
control late-emerging weeds during
establishment
glyphosate
glyphosate’
winter (late)
spring
summer annual weed control may not
be needed first year
summer
control Winter annual weeds and/or ^
pre-emergence control of
summer weeds
summer annual weed control/dodder ^summer
fall ""
glyphosate
^ glyphosate ^
winter
| l«5l^(iaih«?bldde
Control wtnter a^mtiai weeds and/or
'pie-^mergence'r^ntroi of , ^ %
iut^rrherweWs ^ 3
'icoi MEMRifiiMj^Mi ra^ we^s/.-^|v
glyphosate
glyph®»|'';
spring
summer (mid)
^eeds
winter
glyphosate
glyphosate
glyphosate
lit-;#
jr^fal grassy weeds/
i summer (mid!
(4 years'
1 /Vofe; A combination of soil residuaiheihicidesanddiffefent modes trf action is recommended to prevent weed shifts and herbicide resistance. These are
1 examples only-appropriate strategies should be modified for different regions and weed pressures,
‘Tank mixing with another herbicide is advised if significant populations trfgf^hosate, tolerant weeds such as burning nettle are present,
i 'Soii residual herbicide (depending on location and weed spectrum, use hexaanone,diuror% orosetribuzin) for pre-emergence control of winter annual
! weeds. An application of a dintiroaniline herWcide (petwitmetbaiin or trMuralin) applied at this time wilt control summer annual grassy weeds.
Most aitalfa producers apply an herbicide
to alfalfa during the dormant season to control
winter annual weeds that infest the first cutting. It is
strongly recommended that growers not rely solely
on glyphosate for their winter weed contKd prc^ram
for the duration of the stand. They should rotate to
another herbicide or tank mix at least once in the
middle of the life of a stand, and perhaps twice if the
stand life is over 5 years (table 3).
Use an Herbicide with a
Different Mode of Action
Fortunately, all of the herbicides currently registered
in alfalfa~and there are several to choose from—have
Table 3. Comparison of weed management strategies for giyphosate-resistant alfalfa using continuous glyphosate applications versus a
recommended approach where glyphosate is rotated with other herbicides during a 4-year alfalfa stand
1095
Avoiding Weed Shifts and Weed Resistance in Roundup Ready Alfalfa Systems
ANR Publication 8362 11
a different target site of action than does ^yphosate.
The soil-residuai herbicides applied during the
dormant season to established aJfelfa {such as
hexazinone (Velpar), diuron (Karmex), metribuzin
(Sencor). and pendimethalin (Prowl)] would be
ippropriate herbicides for a rotation or tank-mix
partner. The rotation herbicide or tank-mix partner of
choice depends on the weeds pf<»cnt in the fidd and
their relative susceptibility to the herijicides. Paraqu^
(Granioxone) is another candidate for rotation, but
oaraquat, like glyphosate, lacks residua! activity and
!S applied late in the dormant season. &y rotating
paraquat with glyphosate, growers could potentially
be selecting for early-emerging weeds that may be
too large to control at the typical timing for these
herbicides. In addition, they could be selecting for late
emerging weeds that germinate after the application.
Rotate Herbicides Early in Stand Life So
Glyphosate Remains Effective
Weed control during the last year of an alFalfo stand
IS often challenging because the stand is typically
less dense and competitive and also there are fewer
herbicide options from which to choose. There are
significant plant-back restrictions associated with
many of the soil-residual herbicides used in alfalfa,
so glyphosate is a good choice for controlling weeds
in the final year of RR alfalfa field. The preference
to use glyphosate in the final year of an alfalfa stand
underscores the importance of rotating herbicides
earlier so that glyphosate will remain effective and
continue to control the majority of the weeds.
Consider a SolLResiduai Herbicide for
Summer Annual Weed Control
Summer annual grass weeds such as yellow and green
foxtail (Setaria .spp.), barnyardgrass {Echinochloa
crus-galH), cupgrass (Erhcbloa spp), and jungle
rice (Echinochloa colona), and less frequently,
broadleaf weeds like pigweed (Atnaranthus spp.)
or lambsquarcers (Chenopodium albutn), can be
problematic in established alfalfa. These weeds
emerge over an extended time period whenever soil
temperatures and moisture are adequate, typically
from late winter or early spring (as early as February
in the Central Valley) throughout the summer. Weeds
may emerge between alfalfa cuttings, so several
applications may be necessary in Califomias Central
Valley for a foliar herbicide without residual activity
like glyphosate to provide season-long control.
Multiple applications of a single herbicide during
a season is cited as promoting weed resistance.
■ntereforc, growers should not rely solely on
glyphosate for summer grass control for multiple
seasons. It remains to be seen how many applications
of glyphosate will be required for season-long
summer grass control. In some of the long growing-
season areas of California, as many as two to three
appIicalion.s per .season may be needed in older,
thinner stands. Rather than making multiple
applications of glyphosate, a better approach may be
to apply a pre-emergence soil-residual dinitroaniline
herbicide like trifluralin (Trellan) or pendimethalin
(Prowl), or possibly EPTC (Eptam), and follow up
with glyphosate later in the season as needed for
escapes. Not only is this approach more in line with
management practices to avoid weed shifts and
resistance, but it may be more economical as well,
compared with multiple applications of glyphosate.
The practice of rotating herbicides or applying
tank mixtures is recommended for both dormant
applications aimed at winter annual weeds and for
spring/summer applications intended to control
summer annual weeds. For example, rotating to
hexazinone (Velpar) for winter annual weed control
for a year does nothing to prevent weed species shifts
or the evolution of resistance in the summer annual
weed spectrum. Herbicides for summer annual weed
control should be rotated as well.
Frequency of Rotation Depends on Weed
Species and Escapes
There is no definitive rule on how often herbicides
should be rotated. Our suggestion to rotate
or tank mix at least once in the middle years
of the life of a stand (or more often for long-
lived alfalfa stands) may need to be modified
depending upon actual observations of evolving
weed problems. The key point, which cannot be
overemphasized, is the importance of diligent
monitoring for weed escapes. Producers should
stay alert to the appearance of weed species shifts
and evolution of resistant weeds, If the relative
frequency of occurrence of a weed species increases
dramatically, chances are that it is tolerant to
glyphosate and immediate rotation of herbicides
or a tank mix is advised. If a few weeds survive
among a weed species that is normally controlkcl
easily with glyphosate, it could be an indication
of weed resistance, assuming misapplication and
other faclons can be eliminated as possible causes.
Weed resistance should be confirmed by controlled
studies conducted by a weed scientist. However,
1096
Avoiding Weed Shifts and Weed Resistance in Roundup Ready Aifalfa Systems
ANR Pubiication 8362 12
in these situations, it is imperative to prevent
reproduction of a potentially resistant biotype. Treat
weed escapes with an alternative herbicide or other
effective control measure.
CONCLUSIONS
The Roundup Ready alfalfa production system
has the potential to simplify weed management,
while also improving the spectrum of weed control.
However, growers should learn from the experience
gained in other crops and stay alert to the occurrence
of weed shifts and evolution of resistant weeds. The
key is for growers to reduce .selection pressure, not
to rely on repeated applications of glyphosate year
after year, application after application. Well-known
management principles are available to manage weed
shifts and weed resistance in RR alfalfa. Rotate crops,
rotate herbicides, and utilize tank mixes a.s needed,
depending on the weed species and weed escapes
present. A grower should not wait for a problem to
occur before he or she employs these practices: a
preemptive approach is strongly encouraged.
METRIC CONVERSIONS
pound (lb)
0.454
2.205
kilogram (kg)
acrefac) .
0,4047
2.47
hectare (ha)
pound per acre . .
1.12 ..
0.89
kilogram per
(Ib/ac) .
hectare (kg/ha)
1
REFERENCES
Canevari, W. M., S. B. Orloff, W. T. Laniui, R. G. Wilson,
and R, N. Vargas. 2006. UC 1PM pest management
guidelines: Aifalfa. Oakland; University of California
Agriculture and Natural Res<Hirces, Publication 3430.
UC IPM Program Web site. htlp://www.ipm.itcdavis.
cdu/PMG/sdectncwpest.alfalfa hay.html.
(Janevari, M„ R. Vargas, and .S. Orloff. 2007. Weed
management in alfalfa. In C. Summers and D. Putnam,
eds- Irrigated aifalfa management for Mediterranean
and desert /.ones. Oakland: University of California
Agriculture and Natural Resources, Publication
8294, UC' Alfalfa and Porages Workp'oup Web
site, http://a!falfa.ucdavi,s,cdu/irrigatcdalfalfa/pdfs/
UCAlfa!fa8294Weeds-pdf.
DiTomaso, J. M., and R. A. Healy. 2007. Weeds of
California and other western states. Vol. 2. Oakland:
University of California Division of Agriculture and
Natural Resources. Publication 3488.
Duke, S. O, and S. B. Powics, cds. 2008. Cilyphosate-
resistant weeds and crops. Pe.st Management Science
64(4): 317-496,
Gunsolu-s, ). L. 1999. Herbicide resistanl weeds. St. Paul:
University of Minnesota, North Central Regional
F,xten.slon Publication 468,
Heap, I. 1999. The occurrence of herbicide-resistant weeds
worldwide. Pesticide Science 51(3): 235-243.
2008. Internationa! survey ofherbicide resistani
weeds. WeedScience.org Web site, hup://www.
wcedscicnce.com.
Holt. J. S., and H, M. LeBaron. 1990. Significance and
distribution ofherbicide resistance. Weed Technology
4(1): 141-149
Powles, S. B., and C. Preston. 2006, Evolved glyphosate
resistance in plants; Biochemical and genetic basis of
resistance. Weed Technology 20:282-289.
Prather, T. S.. J. M. Ditomaso, and I. S. Holt. 2000.
Herbicide resistance: Definition and management
strategics. Oakland: University of California
Agriculture and Natural Resources. Publication 8012.
UC ANR CS Web site. http://anrcatalog.ucdavis,edu/
Wced.s/8012.aspx.
Puschner, B. 2005. Problem weeds in hay and forages
for livestock. In Proceedings, California Alfalfa
Symposium, 12-14 December, 2005, Visalia . UC
Alfalfa and Forages Workgroup Web site. http;//alfaU'a.
ucdavis.cdu/’*-symposium/proceedings/20()5/05-71.pdf,
Retzinger, E J., Jr., and C. Mallory-.Smith. 1997.
Classification of herbicides by site of action for weed
resistaitce management .strategies. Weed Technology
11:384-393.
Sheaffer, C., i!). Undersander, and R. Becker. 2007.
Comparing Roundup Ready and conventional systems
of alfalfa establishment. Plant Management Network
Web site, htcp;//www, plantmanagementnelwork.org/
suh/fg/rcsearch/2()()7/aifalfa/,
Stcckel, L„ R. Hayes. R. Montgomery, and T. Mueller.
2007. Evaluating glyphosate treatments on Roundup
Ready alfalfa for crop injury and feed quality.
Plant Management Network Web site, http://www.
planimanagementnetwork.org/pub/fg/research/2Ct07/
gb’phosatcA
UC IPM (University of California Statewide Integrated
Pest Management Program). Continuoiusly updated.
Pest management guide: Weed identification. UC IPM
Web site, http;//www.ipm.ucdavi,s.edu/PMG/wceds_
common.html,
USDA. 2008. Genetically-engineered alfalfa status, USDA
Animal and Plant Health Inspection Service Web site,
http;//www.aphis.usda.go\7bioiechnology/a!faifa.shtml
Van Deynze, A., D, Putnam, S. Orloff, T. Lanini, M.
Canewi, R. Vargas, K. Hembree. S, Mueller, and I..
Tcuber. 2004. Roundup Ready alfalfa: An emerging
technology. Oakland: University of California Division
of Agriculture and Natural Resources, Publication
1097
Auoiding Weed Shifts afid Weed Resistance in Roundup Ready Aifalfa Systems
ANR Publication 83S2 13
8153. UC ANR Web site, http://anrcataiog.Qcdavis.edu/
Alfa!fa/8 1 53.asp.x.
Vargas. R. 2004. Stewaniship issues for Roundt^ Ready
alfalfa - A CaKfcHrnia pcr^)ective on Roundup Ready
alfalfa. In Proceedings, National Alfalfa Syn^^osiuin,
13-15 December, 2004, San Di^a UC Alfalfa and
i'orages Workgroup Web ate, http://alfaifa.ucdavis.
c<!u/+syinposiuin/proceedings/2004/04-367-pdf.
Wilson, R. 2004. Stewar<Miip issues for Roundup
Ready Alfalfa - A high plains perspective on the
sustainability of Roundup Ready croppli^ systems.
2004. In Proceedings, National Alfalfa Symposium,
13-15 December, 2(KM, San Diego. UC Aifalfa and
Poragc.s Workgroup Wd) site, http://aifaira.ucdavis.
cdu/+symposiuin/proccedings/2(K)4/04-365.pdC
WARNING ON THE USE OF CHEMiCALS
Pesticides are poisonous. Always read and car^lty fellow all
precautions and safely jecomiTKStdaiions givot on die OMitaincf
label. Store all chemicals in iheir originai labeled containers in a
locked cabinet or shed, away from foods or feeds, and out of the
reach of chiidren, unauthorized persons, pets, and llveaock.
Recommendations arc based on the best information cur-
rently available, and treatments based on th«n ^ufd not foave
residues exceeding the tolwance cst^lishcd for any particular
chemical. Confine ckemicais to the area beii^ treated. THE
GROWER IS LEGAI.!.Y RESPONSIBU for resyues cm the
growers crops as well as for probians caused by drift from the
grower's property to other properties or ck^.
Consult your county agricultural commisstoiiet for correct
iiiethtxls of disposing ol kfiover spray maierisds and empty con-
tainers. Never burn pesticide containers.
PIIYTOTOXKJI'Y: (kniain chemicals may cause plant Injury
If vised at the wrong stage of plant devHopment or when iwn-
pcraturcs are too high. Injury may also re.suU from excessive
amounts or the wrong forinulalion or from mixing incompat-
ible materials. Inert ingredtenls, such as welters, spreaders,
emulsifiers, diluents, and soivcnls, can cause plant injury. .5ince
formulations are often dvanged by manufacturers, It is possible
that plant Injury may occur, even though no injury was noted in
prevlou.s sea.sorts.
FOR fTjRTHER INFORMATION
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xm-pr-2/09-lR/WS/AZ
1098
Appendix
E
Effects of Glypfiosate-Resistant Weeds in
Agricultural Systems (Appendix G from Draft EIS)
1099
Appendix G. Effects of Glyphosate-Resisant Weeds in
Agricultural Systems
G-1
1100
Effects of Glyphosate-Resisant Weeds
in Agricultural Systems
Executive Summary
Alfalfa is grown for forage, grazing, seed production (forage and sprouts), human consumption,
and honey production. The most acreage is for dry hay forage. In 2005, 22,439,000 acres of dry
hay alfalfa was harvested and 204,380 (0.9%) of those acres were certified organic. In addition
to mechanical and cultivation techniques, conventional fanning allows the use of 16 different
herbicides to control weeds in alfalfa. Organic farming does not allow synthetic pesticides or the
use of crop varieties produced through genetic engineering. Glyphosate-tolerant (GT) alfalfa
allows for the application of glyphosate directly onto growing plants, which provides increased
options for weed control over conventional and organic systems. GT alfalfa allows for flexibility
in timing of glyphosate application to control weeds. In the two years that GT alfalfa seed was
on the market --200,000 acres were planted in 1 ,552 counties in 48 states.
Alfalfa Growing Regions
The seven growing regions in the United States have varying optimal alfalfa varieties and
farming practices, such as frequency of cutting, companion cropping, and irrigation. California,
South Dakota, Idaho, Nebraska, Montana, and Wisconsin are the top six alfalfa hay producing
states (in 2007). South Dakota, Montana, Wisconsin, and North Dakota, have the largest
acreage of alfalfa hay. California’s acreage is highly productive.
Crop Rotations
Crop rotation options may be different between conventional and GT farming systems. Many of
the non-glyphosate herbicides have follow-up planting restrictions that limit crop rotation
choices in conventional farming. Farmers using GT cropping systems are advised to include
some years of non-GT crops in rotation, so there may be limitations in the use of other GT crops
if GT alfalfa is used in a rotation plan.
Alfalfa Stand Removal
Glyphosate is the primary tool used to remove conventional alfalfa stands. Use of herbicides
other than glyphosate for removal of GT alfalfa is a major difference between GT alfalfa and
conventional alfalfa. Non-glyphosate herbicides and tillage are recommended for effective GT
alfalfa stand removal.
Volunteer Alfalfa
Farmers are not able to use glyphosate to control volunteer GT alfalfa in other GT crops.
However, 1 1 other herbicides and mixtures of those herbicides are available to control volunteer
GT alfalfa. These are the same herbicides that are used to control non-GT alfalfa with the
exception that glyphosate can be used to control non-GT alfalfa.
G-2
1101
Weeds in Alfalfa
Weeds are controlled in conventional alfalfa with chemicals (herbicides), cultural methods
(rotation, companion crops, monitoring), and mechanical methods (tillage). The cultural and
mechanical methods are permitted for organic farmers. GT systems allow for the use of one
additional herbicide, glyphosate. Weeds are undesirable because they compete with crops,
leading to lower yields, can lower the nutritional value of crops, can be poisonous or unpalatable
to livestock, can cause off flavors in milk, and can cause trouble with bailing. At least 129
different weed species are identified as minor or major problems in alfalfa. Out of 14 new
glyphosate resistant weeds found since 1998, eight are known to be weeds in alfalfa. Out of at
least 21 weeds that have natural resistance to glyphosate, ten are known to be a problem in
alfalfa. These 18 weeds that are both resistant to glyphosate and traditionally listed as problems
in alfalfa include: common ragweed, horseweed, Italian ryegrass, Johnsongrass, Palmer
Amaranth, buckhom plantain, goosegrass, junglerice, bermudagrass, burning nettle, cheeseweed,
common lambsquarters, field bindweed, filaree, large crabgrass, mominggloiy, nutsedge, and
purslane. Although the composition of weed shifts is based on the local seedbank, these 18
weeds are candidates for becoming more prevalent than glyphosate-resistant sensitive weeds in
rotations that include GT alfalfa.
Glyphosate Resistant Weed Distribution
Nineteen states and over two million acres of cropland contain new glyphosate resistant weeds.
The heaviest infestation is in the Southeast and Midwest. Overlap with the major alfalfa
producing states in the Intermountain regions (Washington, Oregon, Idaho, Montana, Wyoming,
Colorado, Utah, Nevada, and parts of California) seems to be minimal at this point. However,
given that there is overlap between glyphosate resistant weed locations and alfalfa hay acreage
there is potential for rapid shifts of glyphosate resistant weeds into GT alfalfa fields if GT alfalfa
were to be widely adopted. California is a concern because glyphosate resistant weeds are
present and alfalfa is a major crop in California.
G-3
1102
1.0 Introduction
The scope of this report covers how glyphosate-tolerant (GT) alfalfa could impact weed
dynamics in agricultural systems. Gene flow from GT alfalfa is covered in another technical
report in this series (Appendix J). In this report, different types of alfalfa crops and cropping
systems are described. Regional differences in alfalfa farming are summarized and discussed
within the context of weed management. Glyphosate resistant weeds and the potential risks from
volunteer GT alfalfa are also discussed. This report is limited to weed dynamics in agricultural
systems. Potential effects of farming with GT alfalfa on ecosystems is discussed in other
technical reports. This report is limited to practices involving weed management and does not
include discussion of control of diseases, insects, nematodes, and vertebrate pests and
management of field fertility and soil conservation.
Weed management is an important aspect of alfalfa production. Some of the negative effects of
weeds include the following (Canevari et al., 2007; Canevari et ah, 2006; Van Deynze et ah,
2004; Loux et ah, 2007; Miller et ah, 2006; Orloff et ah 1997):
• Competition with weeds can reduce yield and cause thinning in the stand.
• Weeds can lower the nutritional quality of alfalfa hay because many weeds are lower in
protein (50 percent less protein than alfalfa) and higher in fiber compared to alfalfa.
• Poisonous weeds containing toxic alkaloids (e.g., common groundsel, fiddleneck, yellow
starthistle, and poison hemlock) can make alfalfa hay unmarketable.
• Under some conditions weeds can accumulate toxic nitrate concentrations (e.g.,
lambsquarters, kochia, and pigweed).
• Some weeds with a spiny texture can cause mouth and throat ulcerations in livestock
(e.g., foxtail, wild barley, cheatgrass, and bristlegrass).
• Weeds that are unpalatable to livestock result in less feeding and, therefore, less
productivity (either beef or milk).
• Some weeds can contribute to off flavors in milk (wild celery, Mexican tea, creeping
swinegrass, and mustards).
• Weeds that contain higher moisture eontent than alfalfa (dandelion) can cause bail
problems such as mold, off-color hay, and high bale temperatures, which are a fire
hazard.
Without weeds, alfalfa can grow at a density of about 1 2 plants per square foot. Heavily infested
stands can have less than one alfalfa plant per square foot (Canevari et ah, 2007). In California,
if weeds are not effectively controlled weeds can represent up to 76 percent of the first cutting
yields (Gianessi et al, 2002). The limiting factor for weed control in alfalfa is that, by the time
alfalfa reaches the stage of growth that is tolerant to herbicides, weeds are also beyond their
susceptible stage (Gianessi et al., 2002). Glyphosate-tolerant alfalfa was developed so that the
broad spectrum herbicide, glyphosate, could be applied directly to alfalfa fields to control weeds.
The glyphosate-tolerant (GT) trait was introduced through genetic engineering. Although
glyphosate-tolerance has arisen naturally in some plants due to decades of glyphosate use, so far,
all crops with glyphosate-tolerance have had the trait introduced through genetic engineering.
G-4
1103
1.1 Methodology
A literature search was designed to identify peer review articles and grey literature (e.g.,
government reports, State Agricultural Extension Office publications) on weeds in alfalfa
(Appendix G-2 of this technical report). Several DIALOG databases were searched. Google,
Google Scholar, Scirus, and Yahoo search engines supplemented the DIALOG search.
Calculations for percentages of harvest were done with Microsoft Excel. Alfalfa harvest
statistics were obtained from USDA’s National Agricultural Statistics Service
(http://vww.nass.usda.gov/index.asp). In addition, USDA’s Economics, Statistics and Market
Information System (ESMIS), which is a collaborative project between Albert R. Mann Library
at Cornell University and USDA, provided information on alfalfa harvesting
(http://usda.mannlib.cornell.edu/MannUsda/homepage.do). USDA’s Agricultural Marketing
Service also provided information on harvests (http://www.ams.usda.gov). The common and
scientific names for weeds (Appendix G-3 of this technical report) were found in the USDA
Plants database (http://plants.usda.gov/Java/invasiveOne).
G-5
1104
2.0 Alfalfa Cropping Systems
This chapter discusses how alfalfa is used, the farming practices for growing alfalfa, and the
alfalfa growing regions in the United States.
2.1 Alfalfa Uses
Alfalfa is grown for seed production, human food, honey, grazing, and forage. Forage comprises
the largest acreage for alfalfa stands. In 2007, 72.5 million tons of dry hay alfalfa was produced
from 21.6 million acres harvested (www.nass.usda.gov).
2. 1. 1 Forage
Alfalfa is considered the “Queen of Forages” because of its high nutritional content when fed to
cattle and horse livestock (Putnam et al., 2001). Due to climate and other differences, farming
practices differ regionally. However, some farming characteristics are shared among growing
regions. Alfalfa stands have two growing phases, establishment of seedlings (first year) and
established (two to eight years). Weed management differs for each phase (Orloff et al., 1997).
During the seedling establishment phase, companion or nursery crops, such as oats, wheat, and
barley can be used to help shelter the alfalfa seedlings, help prevent soil erosion, and suppress
weeds because they germinate and grow faster than alfalfa (Canevari et al, 2007). Well
established alfalfa that is not thinning has fewer issues with weeds because established alfalfa is
a good competitor. Alfalfa can be harvested (mowed) every 30 to 50 days depending on growth
conditions in the region, local weather patterns, and alfalfa variety. In most of the growing
regions, alfalfa is only cut three to four times a year, but in the Southwestern U.S. growers can
cut up tolO or 1 1 times per year (Putnam et al., 2001). To determine when to harvest, farmers
balance yield and nutritional content. Yield increases as plants grow and peaks at 100% bloom,
but nutritional content is highest in young vegetative plants and decreases until full flower.
There is no optimal harvest schedule, because farmers make different decisions based on
changing market demand. Farmers may choose to harvest between late bud stage and full
bloom, however, alfalfa hay production experts recommend cutting alfalfa for hay at 10% bloom,
as this stage provides the most valuable and nutritious forage (e.g., Sheaffer et al. 2000). . The
highest quality hay (bud stage) is generally used for active dairy cows. Whereas hay that is
lower in protein and higher in fiber, is fed to beef cattle, horses, heifers (too young to milk) and
non-lactating dairy cows (Ball et al., no year). Alfalfa for livestock feed can be stored in a
variety of forms:
• Hay - dry bailed at 1 8-20% moisture
• Haylage - round bale silage, baled at 50-60% moisture, wrapped in plastic
• Silage - chopped and blown into a silo or a truck
G-6
1105
2.1.2 Grazing
Grazing is sometimes used as an alternative to harvesting alfalfa. Grazing allows for high
nutritional gains per animal, but the risks include animal losses due to bloating and difficulties in
alfalfa stand maintenance if continuous grazing is present. Farmers may choose grazing for
dormant-season alfalfa stubble, a substitute for early or late season cutting, and rotational grazing
during the growing season. It is strongly recommended that animals not graze before flowering
begins. Alfalfa root carbohydrate reserves may not be sufficient if early grazing is permitted and
the potential for bloat decreases with flowering (Orloff et al., 1997).
2.1.3 Seed Production (Hay and Sprouts)
Alfalfa is also consumed by humans (e.g., sprouts, dietary supplements, and herbal teas).
Sprouts have been the source of several foodbome outbreaks due to bacterial contamination
(FDA 1999). Epidemiological investigations suggest that seeds are the likely source in most, if
not all, sprout-associated illness outbreaks. Seed grown for sprouts have more stringent
restrictions for chemical applications during growing since the chemicals must be evaluated as
food residues. Sources of animal waste in fields, such as grazing areas and irrigation water, must
also be controlled to reduce the likelihood of pathogens from animal waste coming into to
contact with seeds. For these reasons, sprout seed and hay seed are usually grown separately
(FDA 1999).
FDA considers GT alfalfa not materially different from conventional alfalfa; therefore it is
permitted for human consumption (FDA 2004). However, Monsanto does not allow GT alfalfa
to be planted for sprouts (Hubbard 2008). If GT alfalfa was present in human food, it would not
be considered adulterated and would not need to be removed from the market.
2.1.4 Honey
Alfalfa and clover are common nectar sources for honey bee hives. Although alfalfa is not
specifically grown for bees, both managed and wild bee hives are often associated with alfalfa
fields (Hammon et al., 2007).
2.2 Alfalfa Farming Practices
Alfalfa framing practices are broken into three categories, organic, conventional, and glyphosate-
tolerant alfalfa. Only aspects of farming related to weed control are discussed. Practices for
controlling disease, insects, nematodes, and vertebrate pests and management of field fertility
and soil conservation are not discussed.
2.2,1 Organic Farming
For this report, organic production is only those cropping systems that fall under the USDA
National Organic Program (NOP) definition of organic farming and are certified organic
production systems. In organic systems, the use of synthetic pesticides, fertilizers, and
genetically engineered crops is strictly limited. NOP publishes a list of approved substances for
organic farming inputs ( http://www.ams.usda.eov/AMSvl. Of .
G-7
1106
GT alfalfa is not approved for use in organic systems because it is genetically engineered and
because glyphosate application is not permitted in organic systems.
In organic systems, where herbicides are not permitted, alfalfa is tilled and allowed to sit for
seven to ten days. Two or more discing passes may be necessary if weed germination is
observed. The field should also be treated with nutrients, such as compost and boron, and left for
a week to check for further weed germination. Planting can occur once weed growth potential is
minimized (Guerena and Sullivan 2003). Manure fertilizer should be composted to kill weed
seeds (Canevari et al., 2007).
2.2.2 Conventional farming
Conventional farming includes any farming system where synthetic pesticides or fertilizers are
used. The definition of conventional farming usually includes the use of genetically engineered
crops, but genetically engineered GT alfalfa is considered separately for this report (Harker et al.,
2005). Conventional farming covers a broad scope of farming practices, ranging from farmers
who only occasionally use synthetic pesticides to those farmers whose harvest depends on
regular pesticide and fertilizer inputs. The 16 herbicides that may be used in conventional
farming are summarized in table G-1 (based on OMAFRA 2008; Canevari et al., 2007; Rogan
and Fitzpatrick 2004; Loux et al., 2007).
Table G-1. Herbicides Used in Conventional Alfalfa Farming
Herbicide (Brand)
stand Stage
Weed
Notes
2,4-DB (Butyrac,
Butoxone)
1-4 trifoliolate or
established stands
Prickly lettuce Annual
sowthistle Mustards
Curly dock
• No harvesting or grazing
allowed for 60 days following
treatment
Benefin (Balan)
Before seeding
Annual grasses
Broadleaf
» Not for use on soils high in
organic matter
Bromoxynil (Buctril)
2-4 trifoliolate
Coastal fiddieneck
MustardOs Common
groundsel Annual
sowthistle
• Often tank mixed with other
herbicides
Clethodim (Prism,
Select)
2-4 trifoliolate or
established stands
Summer grasses Yellow
foxtail Green foxtail
Barnyardgrass
Bermudagrass
Johnsongrass
Goosegrass Volunteer
cereals
• Well established perennials
require multiple applications *
Allow 15 days between
application and grazing, feeding,
or harvesting of alfalfa
Diuron (Kaimex, Direx)
Established stands
Winter annuals
Broadleaf Some grasses
• Pereists in soil for one year, so
cannot be used in last year of
stand
EPTC (Eptam)
Established stands
Summer grasses
Nutsedge
• Applied before germination •
Controls for 30 to 45 days so
repeated applications may be
necessary
G-8
Hexazinone (Velpar)
6 inches of root growth
in new stands or
established stands
Broadleaf
Grasses
Common groundsel
Chidwveed miners
Lettuce annual
Bluegrass dandelion
Bud<horn plantain
Speedwell
• Many crops cannot be planted
for 18 months without yield
damage
imazamox (Raptor)
2-4 trifoliolate or
established stands
Venter annual Grasses
Broadleaf
• Preharvest interval is 20 days
Imazethapyr (Pursuit)
2-4 trifolioiate or
established stands
Winter annuals Mustards
Shepherd’s purse
Cieeping swinecress
Chickweed
• Follow-up planting restrictions
range from 4 to 40 months
Metribuzin (Sencor)
Established stands
Lamb's-quarters Wild
mustard Redroot
pigweed Common
ragweed Shepherd’s-
pufse Lady’s-thumb
Velvetleaf Jimsonweed
Prostrate pigweed
Russian thistle Yellow
wood-sorrel Prickly
mallow ChicJ(we8d
Cocklebur Carpetweed
Dandelion seedlings
Barnyard grass Crab
grass Foxtail Fail
panicum Wtch grass
Johnson grass Cheat
grass
• No grazing or harvesting
allowed for 28 days following
application
Norfluzaon (Solicam)
Established stands
Broadleaf Grasses
Nutsedge
• Cannot be applied within 28
days of harvest • Does not control
emerged weeds • 24 month
rotation interval
Paraquat (Gramoxone
Inteon)
3, 6. or 9 trifoliolate;
established stands
Broad spectrum
• Rescue treatment when weeds
form a canopy over alfalfa • No
harvest or grazing until 60 days
after application • Often used in
the last year of the stand
Pronamide (Kerb)
First trifoliate leaf stage
Perennial grasses
Quack grass Annual
grasses Volunteer
cereals Common
chickweed
• No grazing or harvesting
allowed for 120 days following
application
Sethoxydim (Poast)
2-4 trifoliolate or
established stands
Summer grasses Yellow
foxtail Green foxtail
Barnyardgrass
Bermudagrass
Johnsongrass
Gooseqrass
• Weil established perennials
require multiple applications
Terbacil (Sinbar)
Established stands
Barnyard grass
Bluegrass Crab grass
Foxtail Chickweed Cheat
grass Perennial rye
grass Wild barley
Mustard Prit^ly lettuce
Stinkweed Annual sow-
thistle Henbit Lamb’s-
quarters Pigweed
• Can not plant any ottier crop for
2 years after Sinbar application
1108
Purslane Ragweed
Partial control ot Quack
grass Hofsenettle Vetch
Yellow nut sedge
Trifluralin (Treflan/TR-
10)
Established stands
Summer grasses
• Applied before germination
• Rainfall or sprinkler Irrigation is
required within 3 days after
irrigation to incorporate the
herbicide
• Controls dodder before
germination
2.2.3 GT Farming
GT alfalfa can be integrated into conventional farming practices. Farming GT alfalfa is mostly
the same as farming conventional alfalfa, with two important exceptions. Weeds can be
controlled by the application of glyphosate directly on top of growing alfalfa and, when alfalfa
stands reach the end of their life cycle (typically after 3-8 years depending on growing region),
glyphosate cannot be used to kill the stand to prepare for another rotation (Miller et ah, 2006). In
GT alfalfa, herbicides other than glyphosate combined with tillage are required to obtain 100
percent removal. Several of the recommended GT alfalfa stand removal herbicides result in
restrictions regarding what crops can be planted next, so careful crop rotation plans are necessary
when using GT alfalfa. Stand removal is discussed in the technical report Effects of Changes in
Farming Practices on Water, Soil and Air Due to Use of Glyphosate-Tolerant Alfalfa (appendix
J).
Another important difference to some farmers is that non-GT crops cannot be used as companion
crops for GT alfalfa. For farmers that plant pure alfalfa stands this difference does not matter.
For farmers that traditionally use companion crops, this difference is important. Companion
crops can increase overall forage yield but decrease hay quality (McCordick et ah, 2008).
2.2.4 Crop Rotation in Aifaifa
For weed, insect, and disease management, it is recommended that aifaifa be used in rotation
with other crops. It is also advised to rotate alfalfa because mature alfalfa produces medicarpin,
which is auto toxic to seedling alfalfa (Guerena and Sullivan 2003). This autotoxicity is the
primary problem for alfalfa seeded after alfalfa (Jennings, no year). Table G-2 presents rotation
recommendations for control of several common alfalfa pests.
G-10
1109
Table G-2. Recommended Rotations for Pest Reduction (Goodell 2006)
Pest
Recommended Rotation
Root knot nematode
1 year rotation with cotton
stem nematode
3-4 year rotation with small grains, beans, cotton, corn, sorghum, lettuce, carrots,
tomatoes, or forage grasses.*
Diseases; Bacterial
wilt Anthracnose
Spring blackstem
Common leafspot
Stagonospora
3-4 year rotation with small grains, beans, corn, sorghum, forage grasses.*
\Afinter weeds
A minimum of 1 year (preferably longer) in crops such as small grains, wheat, oats, winter
forage grasses ^at allow the use of selective herbicides that are not registered in alfalfa.
Summer weeds
A minimum of 1 year (preferably longer) in crops such as small grains, beans, cotton, corn,
sorghum, summer forage grasses that allow the use of selective herbicides that are not
registered in alfalfa.
Dodder
At least 2 years with cotton or other nonhost crops such as small grains, beans, corn,
sorghum, or forage grasses. Avoid rotations with crops such as tomatoes, onions, and
carrote that also serve as a host for this weed.
Nutsedge
Two year rotation with corn or sorghum rotation that includes application of herbicide to
control nutsedge,
• Three to four-year rotations give satisfactory results, A rotation for fevi«r years will provide minimal suppression.
Herbicides that can be used to remove GT alfalfa have rotation restrictions. For example,
following clopyralid (Curtail® or Stinger®), pea, lentil, potato, and dry bean cannot be planted
for 18 months. Picloram (Tordon®) can only be followed by grasses for the year after
application. Sunflower, dry bean, and potato should not be planted for several years following
picloram (Miller et al., 2006). Dicamba (Banvel®) should not be used prior to soybean and is
also limited seasonally in California (Dillehay and Curran 2006). Because of these restrictions,
alfalfa stand removal and rotation schedules should be closely coordinated. Non-glyphosate
herbicides are available to manage alfalfa volunteers in wheat, oats, barley, sugar beet, and corn.
Therefore rotations from GT alfalfa to those crops should be similar to rotations with non-GT
alfalfa (Rogan and Fitzpatrick 2004),
Smother crops planted before alfalfa can suppress weeds. For example, sorghum-sudangrass
hybrid or foxtail millet both suppressed weeds and enhanced subsequent alfalfa establishment
(Forney et al., 1985).
No-till GT corn can be planted directly into alfalfa. In a study comparing no-till GT com planted
into cut or uncut alfalfa and various herbicide applications to control the alfalfa, com yield was
13% higher following herbicide applications to uncut alfalfa. Application of glyphosate and
dicamba at planting resulted in the greatest corn yield. Given that alfalfa is also a valuable crop,
whether the com yield gain is worth the loss of an alfalfa harvest should be weighed (Glenn and
Meyers 2006).
G-11
1110
2.3 Alfalfa Growing Regions
Figure G-1; Alfalfa growing regions (Rogan and Fitzpatrick 2004)
The Association of Official Seed Certifying Agencies, National Alfalfa and Miscellaneous
Legumes Variety Review Board and USDA Plant Variety Protection Office recognizes seven
growing regions in the United States, Moderately Winterhardy Intermountain, Winterhardy
Intermountain, Southeast, Great Plains, North Central, East Central, and Southeast (figure G-1)
(http://www.aosca.orgA^arietyRcviewBoards/Alfalfa.html).In addition, the Pacific Northwest,
which includes Moderately Winterhardy Intermountain and Winterhardy Intermountain, is also
sometimes recognized as a distinct growing region.
Table G-3 and table G-4 summarize the winter survival and fall dormancy ratings for alfalfa
varieties. The National Alfalfa & Forage Alliance (NAFA) publishes a list of varieties and their
winter survival ratings, fall dormancy ratings, and susceptibility to 17 different crop stresses
(e.g., diseases, insects, grazing). The list is updated yearly and the 2007/2008 version lists 242
varieties of alfalfa (NAFA 2008). When selecting a variety, farmers consider yield, stand
persistence, dormancy, pest and disease resistance, herbicide resistance, hay quality, price, seed
certification, and other factors that may be specific to their farming situation (Orloff et al., 1997).
G-1 2
1111
Table G-3. Winter Survival Ratings
Category
Check Variety
Score
Superior
ZG9830
1
Very Good
5262
2
Good
WL325HQ
3
Moderate
G-2852
4
Low
Archer
5
Non V\finterhardy
Cut 101
6
Table G-4. Fall Dormancy Ratings
Check Variety
Rating
Maverick
1
Vernal
2
5246
3
Legend
4
Archer
5
ABI 700
6
Dona Ana
7
Pierce
8
CUF 101
9
UC-1887
10
UC-1465
11
1 is very dormant. 1 1 is extremely non-dormant
Table G-5 presents the U.S. states in order of percentage of alfalfa harvest (in 2005). For each
state, the growing region, the percentage of the total national harvest of all alfalfa are presented
for 2002, 2005, and 2007; and the percentage of the national organic certified harvest are
presented for 2002 and 2005. In 2005, the most recent USDA organic harvest report, 22,439,000
acres of dry hay alfalfa was harvested and 204,380 (0.9 percent) of those acres were certified
organic. The number of acres harvested in a state does not indicate the quantity of the harvest.
For example, as shown in table G-5, because of the growing season length, California ranks top
in production (in 2007, ~1 1 percent of the national harvest and ~7 million pounds) and South
Dakota ranks second (in 2007, ~6.8 percent of the national harvest and ~4 million pounds) even
though South Dakota has ~2 million acres and California has less than 1 million acres of
alfalfa.In addition, even though the Northeastern states rank low in the percentage of acres and
quantity of harvest, alfalfa is the number one crop for several of those states (NAFA 2007).
G-13
1112
Table G-5. Alfalfa Growina Regions and Percentage of Dry Hay Harvest by State
State
Growing Region
Percent of
Percent of
harvest acres
organic harvest
2002
2005
2007
2002
2005
South Dakota
Nortti Central
10.57
10.70
9.86
8.S8
6.82
Montana
Winter Hardy Intermountain
6.76
7.80
9.23
3.66
2.60
North Dakota
North Central
6.13
7.35
7.20
1122
10.09
VMsconsin
North Central
7.32
6.91
7.50
16.34
14.38
Minnesota
North Central
5.59
6.02
4.67
6.40
10.44
Iowa
North Centra!
5.16
5.57
4.10
6.11
4.50
Nebraska
North Central
5.92
5.57
5.36
2.71
4.01
Idaho
PNW-Intermountain
4.57
5.08
5.12
24.69
24.22
California
Moderate Winter Hardy
Intermountain/ Southwest
5.19
4.63
4.88
2.92
6.48
Michigan
East Central
3.56
4,01
3.45
2.07
0.35
Kansas
Great Plains
4.14
3.79
3.92
140
0.32
Colorado
Wnter Hardy Intermountain
3.40
3.57
4.25
3.4S
4.38
Wyoming
V\finter Hardy Intermountain
2.16
2.67
3.33
0.19
0.84
Utah
Moderate Winter Hardy
Intermountain
2.46
2.41
2.71
0.60
0.45
Ohio
East Central
2.71
2.27
2.16
1.89
0.50
Pennsylvania
East Central
2.96
2.27
2,35
0.96
0.60
Missouri
East Central
1.77
2.01
1.46
0.23
0.58
New Yoi1<
East Central
2.90
2.01
2.22
1.34
0,16
Washington
PNW-Intermountain
2.37
2.01
2,22
119
0,56
illinois
East Central
1.84
1.78
1.59
0.80
122
Oregon
PNW-Intermountain
2.15
1.78
2.12
0.42
3.23
Indiana
East Central
1.41
1.52
119
0.D3
0,29
Oklahoma
Great Plains
1.54
1.43
165
O.OD
0.04
Kentucky
East Central
1.37
1.16
133
0.00
0,01
Nevada
Moderate Wmter Hardy
Intermountain
1.34
1.16
135
125
147
Arizona
Moderate Winter Hardy
Intermountam/ Southwest
1.03
1.16
127
0.91
0.24
New Mexico
Moderate Wnter Hardy
Intermountain
0.B3
1.07
117
0.14
0.33
Texas
Great Plains/ Southwest/
Southeast
0.72
0.67
0.76
0.18
0.55
Virginia
East Central
0.62
0.49
0.44
0.31
0.14
Vermont
East Central
0.20
0.20
0.16
0.00
0.00
Maryland
East Central
0.26
0.18
0.20
0.00
0.01
Tennessee
East Central
0.13
0.16
0.10
0.00
0.00
West Virginia
East Central
0.23
0.16
0.14
0.00
0.00
New Jersey
East Central
0.12
0.11
0.10
0.00
0-00
Arkansas
East Central
0.07
0.09
0.06
0.00
0.00
Massachusetts
East Central
0.07
0.06
0.05
0.00
0.00
G-14
1113
State
Growing Region
Percent of
harvest acres
2002 2005 2007
Percent of
organic harvest
2002 2005
Maine
North Cenbel
0.06
0.05
0.05
0.00
0.17
North Carolina
Southeast
0.10
0.05
0.05
0.00
0.00
Connecticut
East Central
0.04
0.04
0.04
0.00
0.05
New Hampshire
East Central
0.04
0.04
0.03
0.00
0.00
Delaware
East Central
ND
0.02
0.02
0,00
0.00
Rhode Island
East Central
0.01
0.01
0.01
0.00
0.00
Florida
Southeast
0.02
0.00
0.03
0.00
0.00
Georgia
Southeast
0.01
0.00
0.01
0.00
0.00
Louisiana
Southeast
0.03
0.00
0.01
0.00
0.00
Mississippi
Southeast
ND
ND
0.02
ND
ND
South Carolina
Soufrieast
0.01
0.00
0.02
0.00
0.00
Alabama
Southeast
0.04
ND
0,04
0.00
ND
Alaska
0.00
ND
0
0.00
ND
Hawaii
ND
0.00
0.00
0,00
0.00
ND = no data provided by USDA
Other differences in alfalfa farming are revealed by examining the number of farms that grow
alfalfa and the number of farms that irrigate. Comparison of California and Wisconsin (table G-
6) shows that in California ~97 percent of the farms irrigate, whereas in Wisconsin only 0,5
percent of the farms irrigate. In addition, the average farm size in California is much larger than
in Wisconsin. It should be noted that the average farm size calculation is a bit misleading
because in California mainly two farm sizes exist, small and very large (4,000 acres). In general,
because farm size does not fit a normal distribution, the average farm size does not give a full
picture of farm sizes. However average farm size does relay the general trend of farm size iti a
state. Like any census, these data may not include all alfalfa farms.
Table G-6. Alfalfa Dry Hay Harvest 2007 U.S. Agricultural Census
state
Number
of
Farms
Acres
Harvested
Quantity
(pounds)
Harvested
Farms
Irrigated
Acres
Irrigated
%of
Acres
%of
Pounds
Avg.
Acres
per
Farm
United States
290,726
20,244,497
65,349,074
56,390
6.556,652
100.0
100.0
70
California
3.587
986,982
7,057,014
3,488
963,086
4.9
10.8
275
South Dakota
12,653
1,996,599
4,414.338
716
75,913
9.9
6.8
158
Idaho
8,817
1,037,520
4,254,543
7,605
861,092
5.1
6.5
118
Nebraska
14.820
1,085.921
3,955.881
4,405
389.516
5.4
6.1
73
Montana
9,711
1,868,756
3,936,445
5.444
703,960
9.2
6.0
192
\Msconsin
30,810
1,517,522
3,673.619
171
8,809
7.5
5.6
49
North Dakota
8,985
1,457,604
3,072,682
240
21,773
7.2
4.7
162
G-15
1114
Iowa
22,040
830,440
3,054,729
62
1,198
4.1
4.7
38
Kansas
9,643
793,140
2,986,134
1,115
207,455
3.9
4.6
82
Colorado
8,648
861,053
2,887,865
7,347
707,234
4.3
4.4
100
Minnesota
20,398
944,775
2.671,173
384
15,603
4.7
4.1
46
Washington
4.294
448,588
2.192,001
2,822
334,005
2,2
3.4
104
Utah
7,780
548,570
2.172,218
7,413
507,798
2.7
3.3
71
Arizona
943
257,407
1,968,043
920
257,263
1,3
3.0
273
Oregon
3,569
428,812
1,777.894
3,043
380,679
2,1
2,7
120
Michigan
16,431
698.595
1,707.036
291
8,080
3.5
2,6
43
Wyoming
4,007
674,284
1,696.438
3.357
471,126
3.3
2.6
168
Pennsylvania
14,402
475,873
1.357,225
109
462
2.4
2.1
33
Ohio
15,354
437.658
1,256.174
17
536
2.2
1,9
29
Nevada
1,128
1,217,586
1,128
274,004
1.4
1.9
243
New Mexico
4,272
1,176,242
1.2
1.8
iQm
lliinois
1,138,512
1.6
1.7
m
Oklahoma
3,781
334.990
1,131,938
294
33,000
1.7
1.7
89
7.70?
450,144
1.119.421
31
901
2,2
1.7
58
Missouri
8,229
295,021
782,847
63
1823
1.2
36
Texas
2,391
153,763
721,303
1.1
64
Indiana
10,775
1.2
1.0
22
Kentucky
10,538
269,610
524,565
109
1,210
1.3
0,8
26
89,213
233,807
76
679
0.4
0.4
29
Maryland
1,429
40,576
120,402
49
712
0,2
0.2
28
Vermont
571
31,769
68,624
2
(D)
0.2
0.1
66
West Virginia
1,185
28,465
62.484
5
(D)
0.1
0.1
24
New Jersey
728
20,310
51,483
39
799
0,1
0,1
28
Tennessee
1,655
20,074
45,819
28
(D)
0,1
0.1
12
Arkansas
278
11,732
28.647
16
932
0.1
0.0
42
Maine
246
10,089
23,876
0
0
0.0
0.0
41
Massachusetts
406
9,921
22,537
1
(D)
0.0
0.0
24
G-16
1115
349
8,343
0
0
0.0
0.0
24
Alabama
340
7,526
16,944
13
91
O.Q
0.0
22
758
10.322
16,755
67
360
0.1
0.0
14
6,951
14,993
13
1,071
0.0
0.0
49
Delaware
177
3.687
13,530
22
421
0.0
0.0
21
New
Hampshire
218
5,373
13,475
5
(D)
0.0
0.0
25
South Carolina
143
4.070
8,860
20
274
0.0
0.0
28
Mississippi
159
3,931
7,113
4
35
0.0
0.0
25
Georgia
134
1,655
4,810
18
243
0.0
0.0
12
Louisiana
52
2,164
4,768
2
(D)
0.0
0.0
42
Rhode Island
63
1,035
1,806
1
(D)
0.0
0.0
16
Hawaii
5
89
267
5
89
O.Q
0.0
18
D data withheld to protect identify of individual farms
2.4 Summary of Findings
Alfalfa is grown for forage, grazing, seed production (forage and sprouts), human consumption,
and honey production. The most acreage is for dry hay forage. Alfalfa is currently grown
through conventional farming practices, organic farming, and in glyphosate-tolerant systems. In
addition to mechanical and cultivation techniques, conventional farming allows the use of 16
different herbicides to control weeds in alfalfa. Organic farming does not allow synthetic
pesticides or the use of crop varieties produced through genetic engineering. QT alfalfa allows
for the application of glyphosate directly onto growing plants, which provides increased options
for weed control over conventional and organic systems. In 2005, 22,439,000 acres of dry hay
alfalfa was harvested and 204,380 of those acres were certified organic.
Crop rotation options may be different between conventional and GT systems. Many of the non-
glyphosate herbicides have follow-up planting restrictions that limit crop rotation choices in
conventional farming. Farmers using GT cropping systems are advised to include some years of
non-GT crops in rotation, so there may be limitations in the use of other GT crops if GT alfalfa is
used in a rotation plan.
The seven growing regions in the United States have varying optimal alfalfa varieties and
fanning practices, such as frequency of cutting, companion cropping, and irrigation. California,
South Dakota, Idaho, Nebraska, Montana, and Wisconsin are the top six alfalfa hay producing
states (in 2007). South Dakota, Montana, Wisconsin, and North Dakota, have the largest
acreage of alfalfa hay. California’s acreage is highly productive.
G-17
1116
3.0 Glyphosate-Tolerant Alfalfa (Roundup Ready®)
Glyphosate-tolerant (GT)“ alfalfa was deregulated in 2005 and by 2006, -80,000 ha (-200,000
acres) were planted in the United States (Beckie and Owen 2007).^'^ USDA APHIS lists all the
counties in the United States where OT alfalfa has been planted (http://www.aosca.org/
VarietyReviewBoards Alfalfa.html). GT alfalfa has been planted in 1,552 counties and 48 states.
Alaska and Hawaii do not have GT alfalfa. In March of 2007 USDA published notice in the
Federal Register that GT alfalfa is a regulated article and GT alfalfa seed sales and plantings
were halted. GT alfalfa planted in the 2005 and 2006 growing seasons is still permitted to be
harvested, but has court ordered stewardship practices to minimize risk of co-mingling GT and
non-GT alfalfa (Hubbard 2008).
3.1 Using GT Alfalfa
Van Deynze et al., (2004) reported that in field trials when Roundup® (glyphosate) was applied
during alfalfa stand establishment at the 3 to 4 trifoliolate stage, weeds were controlled and
usually no second application was needed. Early applieations allowed for late germination of
weeds and later applications allowed weeds to compete with alfalfa. For example in the
intermountain region applications at the unifoliolate to first trifoliolate stage resulted in invasion
by prickly lettuces and henbit and required a second application. In the Southwest annual
bluegrass and canarygrass germinated in early December and required a second application of
glyphosate for control. The effectiveness of the first application during stand establishment is a
function of which weed species are present and their germination period as well as how soon
after application the alfalfa canopy covers the soil surface. In California there is period of time
in the winter when alfalfa stands are dormant and rain causes winter weeds to germinate.
Recommended application of glyphosate to GT alfalfa is 0.75 to 1 .5 pounds acid equivalent per
acre (22 to 44 fluid ounces Roundup Weathermax 4.5S® per acre) at the three to five trifoliolate
stage during stand establishment and up to five days before harvest in established stands
(Dillehay and Curran, 2006). The maximum labeled rate for a single use of glyphosate on GT
alfalfa is 1.55 pounds glyphosate acid equivalent per acre.
Alfalfa is polyploid (tetraploid), so small percentages (three to seven percent) of the seedlings do
not have the GT trait. This is similar for other genetic traits. If glyphosate is sprayed early
enough, plants containing the GT trait will fill in gaps left by dead weeds and non-GT alfalfa that
was killed (Van Deynze et al., 2004). Up to six percent injury was observed after the first
glyphosate application in a new stand, but was gone by the time of first harvest (McCordick et
al., 2008). In GT alfalfa, crop injury from glyphosate application is much less than for other
herbicides (Canevari et al, 2007).
GT alfalfa is an option for weed control; however it may not be appropriate in the following
situations (Dillehay and Curran, 2006);
■Resisiance' and" tolsrance” are usually synonyms and are often used interchangeably. In this report "tolerance" is used to
indicate crop varieties that are intentionally engineered to withstand glyphosate application. "Resistance" is used to indicate weeds
and weed biotypes that can withstand glyphosate application.
2.471 acres = 1 ha * 104 m’
G-18
1117
• Alfalfa-grass mixtures and alfalfa seeded with companion/nursery crops
• Fields that have a history of low weed populations
• Fields that are rotated between alfalfa and other GT crop varieties (e.g. Roundup Ready®
soybean)
McCordick et al. (2008) tested GT alfalfa in 2004 and 2005 growing seasons in field studies in
Michigan. Two seeding regimes were used, clear seeded (only alfalfa seed) and oat companion
crop. In both of these seeding regimes glyphosate, imazamox, and untreated conditions were
tested. For the oat companion crop stands, clethodim was added to the imazamox treatment to
increase control of oat. In the first year (stand establishment), temporary stunting was observed
with glyphosate treatment, but it did not affect yield or stand density. Clear seeded alfalfa
treated with glyphosate yielded the highest alfalfa dry matter in both years, even though
combined forage yield was higher in the oat companion crop. When no herbicide was applied
the oat companion crop had lower weed biomass than clear seeded alfalfa.
3.1.1 Stand Establishment
Forage alfalfa is planted in the spring and in the early fall In the Southwest and western regions.
Currently trifluralin, EPTC, imazethapyr, imazamox, sethoxydim, clethodim, and bromoxynil
herbicides are sometimes used during spring stand establishment and could be replaced with
glyphosate if GT alfalfa is used. Use of GT alfalfa also allows weed control during late-summer
and fall establishment (Rogan and Fitzpatrick 2004).
3.1.2 Stand Removal
One of the major differences between conventional alfalfa and GT alfalfa occurs during stand
removal. Whereas glyphosate is often used to kill old stands of conventional alfalfa for crop
rotations, GT alfalfa has to be removed through other mechanisms. Application of an herbicide
(e.g., 2,4-D, dicamba (Banvel®), and clopyralld (Stinger®)) and tillage is effective. In no-till
systems 2,4-D and dicamba can be applied together. However dicamba cannot be used before
planting soybean (Dillehay and Curran, 2006).
Renz 2007 reported that dicamba and 2,4-D (WeedMaster®) applied at 2 pt/A achieved zero
resprouting of alfalfa in the spring following herbicide application. Lower concentrations of
WeedMaster resulted in 0.3 to 2.5 percent resprouting. The other herbicides applications
(dicamba or 2,4-D only) resulted in 0.5 to 26.5 percent resprouting. In another study, picloram
and 2,4-D was more effective than dicamba and 2,4-D (Miller et al., 2006). Combined with
plowing, clopyralid, clopyralid plus 2,4-D, dicamba plus 2,4-D, picloram, and picloram plus 2,4-
D all controlled alfalfa 100 percent. Plowing alone provided 75 percent control (Miller et al.,
2006).
Potential effects of changes in tillage practices due to the use of GT alfalfa are discussed In the
technical report Effect.^ of Changes in Farming Practices on Water, Soil and Air Due to Use of
Glyphosate-Tolerant Alfalfa (appendix K).
Figure G-2 shows Monsanto’s guidance for GT alfalfa stand removal (Monsanto 2008).
G-19
1118
STAND TAKEOUT AND VOLUNTEER MANAGEMENT
Crop rotations can be divirled into two mairr groups,
alfalfa rotated to: 1 ) grass crops (e.g. corn and cereal
crops): and 2) broadleaf crops. More herbidde
alternatives exist for management of volunteer affalfa
in grass crops. The recommended steps lor controlling
volunteer Roundup Ready Alfalfa are:
Diligent Stand Takeout
Use appropriate commercially available herbicide
treatments alone for reduced tillage systems or In
combination with tillage to terminate the Roundup
Ready Alfalfa stand. Refer to your regional technical
bulletin for specific stand takeout recommendations.
NOTE: Roundup agricultural herbicides are not
effective for terminating Roundup Ready Alfalfa
stands.
Start Clean
If necessary, utilize tillage and/or additional herbicide
applioatlonfs) after stand takeout, and before planting
of the subsequent rotational crop to manage any
newly emerged or surviving alfalfa.
Plan tor Success
Rotate to crops with known and available mechanical
or herbicidal methods tor managing volunteer alfalfa,
keeping in mind that Roundup agricultural herbicides
will not terminate Roundup Ready Alfalfa stands.
• Rotations to certain broadieaf crops are not
advisable If the grower Is not willing to Implement
recommended stand termination practices.
• In the even! that no known mechanical or herbicidal
methods are available to manage volunteer alfalfa in
the desired rotational crop, it Is suggested that a
crop with established volunteer alfalfa management
practices be Introduced Into the rotation.
Timely Execution
implement imcrop mechanical or herbicide treat-
ments tor managing alfalfa volunteers in a timely
manner; that is. before the volunteers become too
large to control or begin to compete with the
rotational crop.
Figure G-2: Monsanto's guidance for GT alfalfa stand removal (Monsanto 2008)
3.2 Volunteer GT Alfalfa
Crop rotation is the practice of alternating crop species in the same field in different years.
Crops are considered volunteer when they grow in a field during a year when they have not been
planted intentionally. Volunteer crops are weeds because they compete with the current crop for
resources and they may harbor insect and disease pests. For example, volunteer GT cotton in GT
soybean can harbor boll weevil. Boll weevil is a serious cotton pest and is monitored
aggressively in cotton for eradication. However boll weevil is not monitored in soybean (York, et
al., 2004).
Volunteer GT crops have to be controlled through the use of other herbicides. For example GT
wheat and canola is best controlled through paraquat and diuron (Rainbolt et al., 2004).
Volunteer GT canola needs to be controlled before replanting canola because cultivars with
different resistance genes can cross and result in multiple herbicide resistance (Rainbolt et al.,
2004).
Herbicides that are used to control alfalfa, including GT alfalfa include (Rogan and Fitzpatrick
2004; Renz 2007; Dillehay and Curran, 2006; Miller et al., 2006):
• 2,4-D
• Clopyralid
• Dicamba
• Dicamba and diflufenzopyr
• Glufosinate
• Primsulfuron-methyl
G-20
1119
• Mixtures of dicamba, 2,4-D, and clopyralid
• Picloram
• Picloram and 2,4-D
• Halsulfuron and dicamba
• Acetochlor
• Acetochlor and atrizine
• Acetochlor and atrizine and dicamba
• Atrizine and dicamba
• Clopyralid and fluraetsulam
Monsanto demonstrated in their Deregulation Petition that the last five herbicides and mixes on
the above list can control volunteer GT alfalfa in com (Rogan and Fitzpatrick 2004). Clopyralid
is effective at controlling volunteer alfalfa in broccoli (Tickes 2002). Clopyralid or 2,4-D provide
control of volunteer alfalfa in 33 different crops. Exceptions include potatoes and popcorn
(Rogan and Fitzpatrick 2004).
Feral alfalfa (alfalfa not in fields) is discussed in more depth in the technical report Effects of
Glyphosate-toleranl Weeds in Non-agricultural Ecosystems (appendix FI).
3.3 Summary of Findings
GT alfalfa allows for flexibility in timing of glyphosate application to control weeds. In the two
years that GT alfalfa seed was on the market -200,000 acres were planted in 1,552 counties in 48
states.
Glyphosate is the primary tool used to remove conventional alfalfa stands. Use of herbicides
other than glyphosate for removal of GT alfalfa is a major difference between GT alfalfa and
conventional alfalfa. Non-glyphosate herbicides and tillage are recommended for effective GT
alfalfa stand removal.
Farmers are not able to use glyphosate to control volunteer GT alfalfa in other GT crops.
However, eleven other herbicides and mixtures of those herbicides are available to control
volunteer GT alfalfa. These are the same herbicides that are used to control non-GT alfalfa with
the exception that glyphosate can be used to control non-GT alfalfa.
G-21
1120
4.0 Weeds in Alfalfa
Although weeds can be a problem in alfalfa, once alfalfa is established, it acts as a suppressor of
weeds and is commonly used in rotations for weed reduction. For example, prior rotation in
alfalfa can reduce weed densities in sunflower to the same level as herbicide treatment and
alfalfa in com rotations also benefited com yield and suppressed weeds (Clay and Aguilar 1998).
Fields with a history of perennial weed infestation are not well suited for alfalfa (Canevari et al,
2007).
Wilson (1981) tested seven herbicides on dormant alfalfa in Nebraska and found good weed
control that resulted in increased protein and total digestible nutrients (except for hexazinone
application) compared to untreated control plots. Weeds that were successfully controlled
included kochia, downy brome, tansymustard, Russian thistle, and prickly lettuce. Out of 48
weeds in alfalfa listed by the University of California Pest Management Guidelines, five weeds
are not controlled by glyphosate; green foxtail, filed bindweed, yellow nutsedge, buckhorn
plantain, and burning nettle. There was no data on pepperweeds. Three weeds stand out (field
bindweed, yellow nutsedge, and buckhom plantain) because they are not controlled well by
glyphosate or any of the other 16 herbicides evaluated (table VII-3 in Rogan and Fitzpatrick
2004).
A list of 129 weeds that are known to infest alfalfa are in Appendix G-3 of this technical report,
including the U.S. region where they are most prevalent as well as their scientific and common
names.
General rules for managing weeds at establishment or in the seedling year include (Loux et al,,
2007);
• Weeds that emerge with the crop are generally more destructive.
• Maintain the forage relatively weed-free for the first 60 days.
• Weeds that emerge beyond 60 days will not influence that year’s forage yield.
• Later-emerging weeds may still influence forage quality.
• Winter annual weed competition in early spring is most damaging to forages.
• Broadleaved weeds are generally more competitive against legumes than grassy weeds.
4.1 Glyphosate Resistance in Weeds
Herbicide resistance can be defined as the inherited ability of a weed population to survive and
reproduce following a herbicide application that is normally lethal to the vast majority of
individuals of that species (lethal to the wild type) (Puricelli and Tuesca, 2005; Stoltenberg and
Jeschke, no year). Farmers are concerned about glyphosatc-tolerant weeds (Johnson and Gibson
2006). Figure G-3 represents the different weed populations in alfalfa. Since 1998, 14 new
glyphosate resistant weeds have been found globally. Nine of these have glyphosate resistant
biotypes in the United States. Eight of the new glyphosate resistant weeds known globally are
also known to be weeds in alfalfa stands (see Appendix G-3 in this technical report for list of
weeds in alfalfa). At least 21 weeds that have natural resistance to glyphosate exist. Ten of
these naturally glyphosate resistant weeds are known to be a problem in alfalfa. Table 0-7 lists
G-22
1121
the weeds known to be glyphosate resistant in general or have glyphosate resistant biotypes.
Figure G-4 summarizes the results of a recent farmer survey regarding their satisfaction with GT
alfalfa and which weeds were controlled.
Table G-7. GIv
ohosate-resistant weeds
Common
Name
Scientific
Name
Resistant
Biotype
Report^ in
U.S.
identified
Problem in
Alfalfa
(Appendix G-3)
Listed on
Roundup®
Label
Source
Recently Evolved or Selected Resistant Biotypes
Common
Ragweed
Ambrosia
artemisHfioIia
Yes
Yes
Yes (with
resistant biotype
note)
Heap et at,
2008
Common
Waterhemp
Amaranthus rudis
and Amaranthus
tuberculatus
Yes
No
Yes (with
resistant biotype
note)
Heap et ai.,
2008;
Nandula et
al.. 2005
Giant
Ragweed
Ambrosia trifida
Yes
No
Yes (with
resistant biotype
note)
Heap et al.,
2008
Hairy Fleabane
Conyza
bonariensis
Yes
No
Yes
Heap et al.,
2008;
Nandula et
ai.. 2005
Horseweed
Conyza
canadensis
Yes
Yes
Yes (with
resistant biotype
note)
Heap et al.,
2008;
Nandula et
al,. 2005
G-23
1122
Italian
Ryegrass
Lolium mulWorum
Yes
Yes
Yes (with
resistant biotype
note)
Heap et al.,
2008;
Nanduia et
al.. 2005
Johnsongrass
Sorghum
haleper^se
Yes
Yes
Yes (mixture also
recommended)
Heapetal..
2008
Palmer
Amaranth
Amaranthus
palmeri
Yes
Yes
Yes (with
resistant biotype
note)
Heapetal.,
2008
Rigid Ryegrass
Lolium rigidum
Yes
No
Yes (with
resistant biotype
note)
Heapetal.,
2008:
Nanduia et
al., 2005
Buckhorn
Plantain*
Plantago
lanceolata
No
Yes
No
Heapetal.,
2008
Goosegrass
Eleusine indica
No
Yes
Yes
Heapetal.,
2008;
Nanduia et
a!.. 2005
Junglerice
Echinochloa
colona
No
Yes
Yes (mixture also
recommended)
Heap et al.,
2008
Sourgrass
Digitaria hsutaris
No
No
No
Heapetal.,
2008
Wild Poinsettia
Euphorbia
heterophylla
No
No
No
Heap et al.,
2008
Historically Naturally Resistant
Asiatic dayflower
Commelma
commur)is
No
No
Nanduia et at,
2005
Birdsfoot trefoil
Lotus corniculatus
No
No
Nanduia et at.,
2005
Bermudagrass
Cynodon daclylon
Yes
Yes (partial
control notes)
Cerdeira and
Duke 2006
Burning nettle
Urtica uren
Yes
No (mixture
recommended)
Van Deynze et
al.. 2004;
Canevari et al..
2004
Cheeseweed
Malva parvifJora
Yes
No (mixture
recommended)
Van Deynze et
ai., 2004
Chinese foldwig
Dicliptera chinensis
No
No
Nanduia et al.,
2005
Common
lambsquarters
Chenopodium album
Yes
Yes (mixture also
recommended)
Nanduia et ai.,
2005
G-24
1123
Field bindweed*
Convolvulus
arvensis
Yes
No (mixture
recommended)
Nandula etal.,
2005
Filaree
Erodium spp.
Yes
Yes (mixture also
recommended)
Van Deynze et
ai.. 2004
Florida peliltory
Parietara debilis
No
No
Cerdeira and
Duke 2006
Hemp sesbania
Sesbania exalta
No
Yes
Cerdeira and
Duke 2006
Large crabgrass
Digitarla sanguinalis
Yes
Yes (mixture also
recommended)
Cerdeira and
Duke 2006
Morning glory
Ipomoea purpurea
Yes
Yes (mixture also
recommended)
Hilgenfeld et al.
(2004; Cerdeira
and Duke 2006
Nutsedge*
Cyperus spp.
Yes
Yes
Cerdeira and
Duke 2006
Oval-leaf false
buttonweed
Spermacoce latifolia
No
No
Cerdeira and
Duke 2006
piilpod sandmat
Chamaesyce hirta
No
No
Cerdeira and
Duke 2006
Purslane
Portulaca oleracea
Yes
Yes (mixture also
recommended)
Van Deynze et
al., 2004
Tropical Mexican
clover
Richardia
brasiliensis
No
No
Cerdeira and
Duke 2006
Tropical
spiderwort
Commelina
benghafensis
No
No
Nandula et al.,
2005
Velvet leaf
Abutilon theophrasti
No
Yes (mixture also
recommended)
Nandula et al.,
2005
Watertiemp
Amarathus rudis and
A. tuberculatus
No
Yes (with
resistant biotype
note)
Cerdeira and
Duke 2006
Cline 2004 reports that fleabane and henbit are also difficult to control wth glyphosate. * These 3 weeds are not ftjlly controlled by
any of the 16 herbicides listed in the University of California Pest Management Guidelines (Rogan and Fitzpatric^Q 2004).
G-25
1124
Sureey of GT Alfalfa Farmers
Canevari (2007) reported survey results from interviews with alfalfa growers and Industry
representatives from California, Idaho, Nevada. Arizona, Washington, and New Mexico (43
respondents). The major weeds in alfalfa that were controlled by using a GT alfalfa system are
listed below. Weeds that were cited as causing probiems in alfalfa but were not mentioned by
farmers as being controlled by glyphosate are highlighted in grey. A more comprehensive list of
weeds in alfalfa is in appendix B.
Of the 24 growers surveyed all were satisfied with GT alfalfa. Advantages included less herbicide
needed, yield increase, control of volunteer crops, excellent weed control, hay quality increase,
better stand and water efficiency. Farmer concerns were that the seed is no longer available, the
need for bale identification due to court order, and reluctance of the horse market. For the pest
consultants, dealers, and researchers, concerns included export concerns, seed costs, weed
resistance, weed shifts, market acceptance.
Bindweed
Dandelion
Knapweed
MStnitillory
Bur clover
Dodder
Khdt^eed
Nuteedqe
Canada thistle
Flddlensck
Kochia
Peopenveed
iSOckMr!
Foxtail
^'neidD)rd.6ket
ftahtalh
Common groundsel
Hoary cress
Loveqrass
Curly dock
Johnson grass
MexicatiTdEi
Quackgrass
Water grass
Figure G-4; Survey of GT alfalfa farmers
The 18 weed species (table G-7) that are both resistant to glyphosate and traditionally present
problems in alfalfa likely pose the greatest threat for weed shifts in a GT cropping system. Eight
weeds with newly identified resistance and ten weeds known to have some natural resistance to
glyphosate are briefly described below.
4. 1. 1 New Glyphosate Resistant Weeds
Glyphosate resistant biotypes have recently been identified for the following eight weeds that are
also common in alfalfa: common ragweed, horseweed, Italian ryegrass, Johnsongrass, Palmer
Amaranth, buckhorn plantain, goosegrass, and junglerice. Each is briefly discussed below.
Common ragweed {Ambrosia artemisiifolia) germinates in May and early June, flowers in
August to September, and sets seed in September. Each plant can release more than 30,000,
three mm-long seeds, which can remain viable for more than 39 years buried. Seeds are
dispersed by water and animals and can be blown across crusted snow in the winter. Common
ragweed can thrive in soil containing high amounts of clay, gravel, or sand. It is found in
cropland, abandoned fields, vacant lots, fence rows, waste areas, and along roadsides and
railroads. Because it can accumulate large quantities of trace metals, it is very competitive and
can cause nutritional deficiencies in crops. Not only does it taste bitter to livestock but it also
causes nausea and mouth sores in livestock. It is very difficult to control as it can tolerate
mowing, trampling, and grazing (Lanini, no year a). Common ragweed has a biotype that has
multiple herbicide resistance to acetolactate synthase (ALS) inhibitors and PPG inhibitors (Heap
et al., 2008).
Horseweed (Conyia canadensis) is a summer or winter annual that grows 1 .5 to 6 feet tall
(Loux et al., 2006). It produces a large number of seeds (200,000 per plant) that are wind-
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1125
dispersed. Seed dispersal in a com field ranged from 12,500 seeds per square yard at 20 feet
from the seed source, to more than 125 seeds per square yard at 400 feet from the seed source
(Loux et al., 2006). Seeds can disperse a quarter mile when winds are only 1 0 miles per hour
(Barnes et al., 2003). Seeds are able to germinate in no-till fields (undisturbed soil, includes non-
crop sites) and tilled fields. Outcrossing among horseweed occurs at 1.2 to 14.5 percent which
facilitates the spread of resistance traits (Stoltenberg and Jeschke, no year; Nandula et al., 2005;
Loux et al., 2006). The known cases of glyphosate-resistant horseweed are characterized by
frequent use of glyphosate, little or no use of alternative herbicides that control horseweed, and
long-term no-tillage crop production practices (Loux et al., 2006). In addition to direct
competition for light, water, and nutrients, horseweed can host the tarnished plant bug, an alfalfa
pest, and the viral disease aster yellows, which is transmitted by aster leafhoppers to a wide
variety of plants (Loux et al., 2006). Horseweed contains volatile oils, tannic acid and gallic acid
that may cause mucosal and skin irritation in livestock (especially horses) and humans (Steckel,
no year a). There are horseweed biotypes that are also resistant to ALS inhibitors. Several
herbicides are effective at the rosette stage, but once horseweed is over six inches tall a three-
way mixture of glyphosate, plus 2,4-D ester, plus chlorimuron or cloransulam, is recommended.
Biotypes that are resistance to glyphosate and/or ALS inhibitors cannot be effectively controlled
(Loux et al.', 2006). In Ohio, a biotype that is resistant to both ALS inhibitors and glyphosate and
a biotype in Michigan that is resistant to photosystem II inhibitors and ureas and amides have
been identified (Heap et al., 2008). Over 500,000 acres in the Midwest are reported to be infested
with glyphosate-resistant horseweed (Cline 2004). Others estimate that over two million acres in
the U.S. are infested (Heap et al., 2008).
Italian Ryegrass {Lolium multiflorum) is an annual grass and is related to perennial ryegrass
{Lolium perenne). Italian ryegrass can be intentionally cultivated with alfalfa as a companion
crop and is good for grazing, hay, and silage (Hall 1992). However in cool, wet environments, it
may outcompete alfalfa and, in very dry situations, it might not provide adequate ground cover
(Schneider and Undersander 2008). Italian ryegrass is a weed in wheat because it stays green
longer than wheat and causes cut wheat to heat and spoil (Peeper 2000). There are biotypes that
exhibit multiple herbicide resistance to acetyl-CoA carboxylase (ACCase) inhibitors, ALS
inhibitors, and Chloroacetamides (Heap et al., 2008). At least 5,000 acres in CA are reported to
be infested with glyphosate resistant ryegrass (Cline 2004).
Johnsongrass (Sorghum halapense) is one of the ten most noxious weeds in the world. It is a
fast-growing competitive perennial grass. Established Johnsongrass can be seven to nine feet tall
and releases chemicals that inhibit surrounding plant growth. A plant produces 1 00 to 400 seeds
that withstand silage and passage through livestock digestive systems. Seeds can germinate from
6 inches deep and are viable for three years. Stresses that interrupt normal growth, such as
freezing, cutting, wilting, trampling, and herbicide exposure, can cause the release of toxic
amounts of hydrocyanic acid which are poisonous to livestock. Johnsongrass is thought to be
introduced from Egypt sometime after the Revolutionary War and was previously grown as
forage in the south. If herbicides are not used it can be controlled by intense grazing and mowing
for two years until the rhizomes are depleted. (CDF A, no year a; Lanini no year b). There are
separate biotypes of Johnsongrass that have resistance to ACCase inhibitors, Dinitroanilines and
ALS inhibitors (Heap et al., 2008).
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1126
Palmer amaranth {Amaranthus palmert) is closely related to waterhemp and is the dominant
pigweed in the Southwest. It is the most competitive and rapidly growing species of the weedy
pigweeds and can reach a height of six feet (Steckel no year b). It is susceptible to herbicides
when it is 4 to 6 inches tall (Scarpitti et al., 2007). Biotypes of Palmer amaranth have been
identified with resistance to Dinitroanilines, photosystem II inhibitors, and ALS inhibitors (Heap
et al., 2008).
Buckhorn Plantain {Plantago lanceotata) competes with crops for soil nutrients, water, and
light and does well in droughts. It reproduces by seed and by tap root. Buckhorn plantain
establishes slowly in alfalfa, but, once established, is difficult to control because of its extensive
crown system (Wall and Whitesides. 2008). Glyphosate resistance is the only identified
herbicide resistance in buckhorn plantain and has only been found in South Africa, so far (Heap
et al., 2008).
Goosegrass (Eleusine Mica) is an annual grass with an extensive root system that can produce
50,000 seeds per plant (Duble, no year). It is one of the five most troublesome weeds world-
wide. It is found in agricultural fields, homeowner lawns, waste areas, roadsides, pastures, and
golf courses. When it emerges with or shortly after a crop it can be a very competitive weed.
Later in the growing season, it can produce enough biomass to hinder harvest (Steckel no year c).
Some goosegrass biotypes exist that are known to be resistant to ACCase inhibitors,
Bipyridiliums, Dinitroanilines, and ALS inhibitors. In Malaysia, a case of multiple resistance to
ACCase inhibitors and glyphosate was found (Heap et al., 2008).
Junglerice (Echinochloa colonum) is a summer annual grass that is invasive in Tennessee,
Hawaii, and Arizona (NPS 2007). It has little or no dormancy in tropical areas and germinates
throughout the year. It can grow two to three feet high (Virginia Tech, no year). In Costa Rica, a
biotype has been identified that has multiple resistance to ACCase inhibitors, ALS inhibitors,
and ureas and amides. A glyphosate resistant biotype has been identified in Australia (Heap et
al., 2008).
4. 1.2 Traditionally Glyphosate Resistant Weeds
Ten weeds that are common in alfalfa and historically have some tolerance for glyphosate
include bermudagrass, burning nettle, cheeseweed, common lambsquarters, field bindweed,
filaree, large crabgrass, morningglory, nutsedge, and purslane. Each is briefly discussed below.
Bermudagrass (Cynodon dactylon) is a perennial grass that propagates through seed, root, or
stem cuttings. If bermudagrass is cultivated, the soil should be dry because, if it is moist, the cut
shoots will form new plants (Cudney and Elmore 2007). Bermudagrass is also grown as a forage
crop (Undersander and Pinkerton 1988).
Burning nettle {Urtica urens) is a summer annual that flowers from June to November and is
wind-pollinated. One plant can produce from 1,000 to 40,000 seeds. When left undisturbed in
soil for six years, germination declined by 61 percent. However, 20 to 100 year-old seeds from
excavations have been known to germinate. Seeds can also survive livestock digestive systems
(Organic Garden 2007). Burning nettle stinging hairs contain histamine, formic acid,
acetylcholine, acetic acid, butyric acid, leukotrienes, 5-hydroxytryptamine, and other irritants.
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1127
Dermal contact with the hairs leads to a mildly painful sting and itching or numbness for a period
lasting from minutes to days (Thorne Research 2007). In Australia, a biotype resistant to
photosystem 11 inhibitors has been identified (Heap et al., 2008).
Cheeseweed (Malva iteglecta) is an annual or biennial dicot that reproduces from seeds. It is
found on cultivated ground, new lawns, farmyards, and waste places (Mitich, no year). It is very
competitive in alfalfa and, once established, is difficult to control. The fatty acids malvalic acid
and sterculic acid may cause the plant to be toxic to horse, cattle, and sheep (Canevari 1997).
Selenium or nitrate concentration has also been cited as the cause of toxicity (Hill 1993; USU, no
year; Barnard, 1996).
Common lambsquarters {Chenopodium album) is a summer annual dicot that is adaptable to
many environments. A plant can produce 100,000 seeds which can survive 30 to 40 years in soil
(Lanini, no year c). Biotypes that are resistant to photosystem II inhibitors and ALS inhibitors
have been identified in the United States (Heap et al., 2008). Glyphosate resistant lambsquarters
has been reported in the Midwest and in a Madera, CA almond orchard (Cline 2004).
Field bindweed (Convolvulus arvensis) is a perennial dicot that reproduces by seed and
vegetatively from deep-creeping roots and rhizomes. Young plants seldom produce seed in the
first year, but one plant can produce 500 seeds. In fields, seeds can survive 20 years or more.
Field binweed can harbor the viruses that cause potato X disease, tomato spotted wilt, and
vaccinium false bottom. In addition, it contains tropane alkaloids and can cause intestinal
problems in grazing horses (CDFA no year b).
Filaree (Erodium cicutarium) is a winter annual dicot that grows two to five inches high. It is
adapted to a broad range of soil types and is found in oak woodlands, semi-desert grassland,
desert shrublands, fields, lawns, and wasteplaces. Redstem filaree can be excellent forage for
livestock and wildlife, but can cause bloating under heavy grazing (Pratt et al., 2002). It is
competitive with crops and can cause yield reductions (Trainor and Bussan 2001).
Large crabgrass (Digitaria sanguinalis) is a summer annual that reproduces by seeds (Stritzke,
no year). It is primarily a turfgrass weed, but can be founding thinning alfalfa stands (Elmore
2002). A biotype with multiple resistance to ACCase inhibitors and ALS inhibitors has been
identified in Australia. Photosystem II inhibitor resistant biotypes have also been identified
(Heap et al., 2008).
Morning glory (Ipomoea purpurea) is a perennial climbing vine that reproduces by seed
(Pittwater Council, no year). It is a problem in crops because of competition. Morning glory
seeds are toxic to humans (Filmer, no year). Morning glory foliage is toxic to livestock due to
nitrates. Symptoms of acute nitrate poisoning are trembling, staggering, rapid breathing, and
death. Chronic poisoning may result in poor growth, poor milk production and abortions. In
cattle, there is evidence that vitamin A storage is affected (Robinson and Alex 1989).
Nutsedge (Cyperus spp.) is a hardy weed due to tubers that grow 8 to 14 inches below the
ground and, when mature, can re-sprout 10 to 12 times after cutting before tuber resources are
depleted. In addition, many herbicides are not translocated to tuber, and, therefore, do not
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1128
effectively control growth (Wilen et al., 2003). Alfalfa should not be planted in a field where
nutsedge is a known problem (Canevari et al., 2003). In a study in California, nutsedge was
reduced 96 to 98 percent using crop rotation and herbicides. The rotation was two years alfalfa
with applications of EPIC herbicide, two years of barley double-cropped with com and
application of thiocarbamate herbicide, and two years of barley followed by fallow glyphosate
applications (Canevari et al., 2007). Biotypes of Cyperus difformis that are resistant to ALS
inhibitors have been found in California and globally (Heap et al., 2008).
Purslane {PoHulaca oleracea) is a summer annual dicot that produces 240,000 seeds per plant
and can survive five to 40 years. It can re-root after cultivation or hoeing, so it is difficult to
control mechanically. It is a minor crop in the United States because it is edible and is used in
ethnic cooking. In other crops, it is a weed because of competition (Cudney et al, 2007).
4. 1.3 Mechanisms of Glyphosate-Tolerance
Glyphosate inhibits 5-enolpyruvyIshikimate-3-phosphate (EPSP) synthase, which is a key
enzyme in the shikimate pathway in plants and is required for plant growth. The effects of
glyphosate can be stopped in several ways (Cerdeira and Duke, 2006; Stoltenberg and Jeschke,
no year; Nandula et al., 2005):
Resistant EPSP synthase - A version of EPSP synthase that is not affected by glyphosate has
been found in bacteria [Agrobacterium) and has been transferred into crop plant genomes. Also,
the maize version of EPSP synthase has been modified by site directed mutagenesis to be
resistant to glyphosate. A version of EPSP synthase with decreased binding to glyphosate has
been found in the weed goosegrass {Eleucine indica).
Degrade glyphosate - A glyphosate-degrading enzyme has been found in bacteria
(Ochrobactrm anathropi) and has been transferred into crop plant genomes.
Inactivate glyphosate - An enzyme found in bacteria {Bacillus licheniformis) has a weak ability
to inactivate glyphosate through N-acetylation. The efficiency of this enzyme was increased by
directed evolution in the lab and, when transferred to plants, confers resistance to glyphosate in
field settings. A fungal gene encoding glyphosate decarboxylase has been discovered and
patented for eventual use in crop plants.
Altered translocation of glyphosate - There is limited evidence that, in some glyphosate resistant
ryegrass, glyphosate accumulates in mature leaf tissue rather than in the growing parts. Although
the mechanism of resistance in horseweed is unknown, translocation experiments suggest that
resistant biotypes do not translocate glyphosate to the growing parts of the plant (e.g., roots,
young leaves, and crown).
Other - Resistant plants exist for which the mechanism of glyphosate resistance is not known. In
addition, it is likely that there are mechanisms of resistance that have yet to evolve.
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1129
4.2 Weed Shifts in GT Aifalfa
Adopting new weed control strategies eventually leads to shifts in the weeds that are of greatest
concern. Weed shifts can occur due to changes in tillage, irrigation, soil fertility, planting date,
crop rotation, and herbicide use (Hilgenfeld et al., 2004). Changes to a no-till system results in a
more diverse seedbank. Within weedy species variations in characteristics help weeds escape or
tolerate weed management. These characteristics include seed dormancy, emergence patterns,
growth plasticity, life cycle, life duration, shade tolerance, late-season competitive ability, seed
dispersal mechanisms, and morphological and physiological variations (Hilgenfeld et al., 2004).
Because weed seedbanks in the soil can contain large reservoirs of dormant weed seed, short-
term studies (a few years) might not detect the full potential shift in weed communities (Marker
et al., 2005). However sometimes weeds shift can be observed within a few years. For example,
in a field trial in an established GT alfalfa stand in the Southwest (San Joaquin Valley) burning
nettle was not controlled and the population of burning nettle increased significantly over the
three-year trail period (Canevari et al., 2004; Van Deynze et al., 2004). Tank mixtures with
Velpar (hexazinone) or paraquat controlled burning nettle. Weeds that are difficult to control
with glyphosate, such as dodder and cheeseweed, may need to be treated early and require a
second application. Van Deynze et al (2004) recommend that the best way to prevent weed shifts
is to avoid using the same herbicide year after year, rotate herbicides and crops, and include non-
herbicide strategies to control weeds.
Puricelli and Tuesca (2005) found that continuous (once before planting, once at 40 days after
planting, once in winter fallow in August) glyphosate application in field studies on three crop
rotation sequences and two tillage systems lead to quantitative and qualitative changes in weed
communities. They found that glyphosate application was a more important factor than crop
sequence to explain weed community changes in summer crops. They also predicted that
continual glyphosate application for longer than the five years in their study might lead to the
development or higher increases in abundance of weeds tolerant to glyphosate. Weed species
diversity in conventional versus no-tillage plots did not differ significantly.
Marker et al., (2005) reported that field studies of spring wheat-canola-spring wheat rotations of
various combinations of GT and non-GT varieties under conventional tillage or low soil
disturbance direct seeding systems indicate that weed community shifts are dependent on
rotation pattern in a site-dependent manner. In the western Canada field locations, within 3
years, crop systems without GT varieties were associated (using canonical discriminant analysis)
with green foxtail, redroot pigweed, sowthistle spp., wild buckwheat, and wild oat. The specific
weeds associated with all GT variety systems included Canada thistle at the Brandon site, henbit
at the Lacombe site, and volunteer wheat, volunteer canola, and round-leaved mallow at the
Lethbridge site. One surprising finding was that high variability in wild buckwheat between the
systems. Glyphosate is not very effective on wild buckwheat, so the authors propose that wild
buckwheat .seed production or viability may be restricted by glyphosate more than the wild
buckwheat biomass. Therefore after glyphosate application the plant may appear visually robust,
but its ability to reproduce has been effected, so in following years less wild buckwheat is
observed (Marker et al., 2005).
G-31
1130
It is plausible that the 1 8 weeds discussed in section 4. 1 are the first candidates for weed shifts in
GT alfalfa. However, as discussed in the studies sinnmarized above, weed shifts are dependent
on the composition of the weed seedbank in the soil and surrounding sources of weeds.
4.2.1 Weed Management Options
Weed management strategies in organic alfalfa systems, conventional alfalfa systems, and
glyphosate-tolerant alfalfa systems differ. Management options for conventional systems
include (Nandula et al., 2005; Guerena and Sullivan 20031
• Chemical (See table G-6)
o Alternating herbicides with different modes of action
o Tank mixing herbicides
o Sequences of herbicides
o Application timing
• Cultural
o Rotation between GT cultivars and non-GT cultivars
o Winter crops in rotation
o Companion crops/co-cultivation/interseeding/nurse crop)
o Cover crops (smother crops) (prior to planting alfalfa)
o Field scouting for early detection
o Monitor for weed species and population shifts
• Mechanical
• Tillage cultivation
Organic alfalfa systems can use the cultural and mechanical strategies (except for use of GT
cultivars). Nurse crops of peas or oats produce good hay for the horse market (Guerena and
Sullivan 2003). GT alfalfa systems can use all of the strategies of conventional systems plus
application of glyphosate directly on growing alfalfa. Options for rotating between GT cultivars
and non-GT cultivars are reduced with GT alfalfa, since GT com and GT soybean are popular
rotation crops for alfalfa.
Cutting intervals affect weed infestation. For example, if alfalfa is cut too frequently (20 to 25
days) there is not enough time for root storage of carbohydrates so growth after cutting is not
vigorous and weeds have a competitive advantage. However sometimes early harvest can rescue
a heavily weed-infested new stand if the weeds are beyond the stage of optimum herbicide
treatment (Canevari et al, 2007). Alternating long and short intervals between cuttings enables
alfalfa to maintain root reserves so plants can recover from defoliation quickly and more
vigorously compete with weeds (Canevari et al, 2007).
4.3 Distribution of Glyphosate Resistant Weeds
Table G-8 shows that currently 19 U.S. states are affected by glyphosate resistant weeds. The
majority of new glyphosate resistant weeds are located in the Southeast and Midwest. The
overlap with the major alfalfa producing states in the Intermountain regions seems to be minimal
at this point (table G-6). However, given that there is overlap between glyphosate resistant weed
locations and alfalfa hay acreage there is potential for rapid shifts of glyphosate resistant weeds
G-32
1131
into GT alfalfa fields if GT alfalfa were to be widely adopted. California is a concern because
glyphosate resistant weeds are present and alfalfa is a major crop in California. More detailed
records of local weed infestations may be kept by state extension offices.
Table G-8. Glyphosate-Resistant Weed Infestations by State (Heap et al., 2008)
State
Weed species
- Number of
Sites in State
Infested
~ Number of
Acres in State
Infested
Situation
Year
Reported
Arkansas
Conyza canadensis
Horseweed
6-10 increasing
1.001-10.000
increasing
Cotton
2003
Ambrosia ariemisiifolia
Common Ragweed
1
11-50
Soybean
2004
Ambrosia trifida Giant
Ragweed
6-10 increasing
101-500
Increasing
Soybean
2005
Amaranthus palmeri
Palmer Amaranth
1 increasing
unknown
Soybean
2006
Sorghum halepense
Johnsongrass
1
unknown
Soybean
2007
California
Loiium rigidum Rigid
Ryegrass
11-50 increasing
1,001-10.000
increasing
Almonds
1998
Conyza canadensis
Horseweed
1
unknown
Roadside
2005
Conyaa bonariensis
Hairy Fieabane
2-5
unknown
Roadside
2007
Delaware
Conyza canadensis
Horeeweed
101-500
10,001-100,000
Soybean
2000
Georgia
Amaranthus patmeri
Palmer Amaranth
101-500
increasing
100.001-
1,000,000
Increasing
Cotton
Soybean
2005
Illinois
Conyza canadensis
Horseweed
1.001-10,000
increasing
10,0001-
1.000.000
increasing
Soybean
2005
Amaranthus rudis
Common Waterhemp***
1 increasing
51-100
Increasing
Corn
Soybean
2006
Indiana
Conyza canadensis
Horseweed
2-5 inaeasing
101-500
increasing
Soybean
2002
Ambrosia trifida Giant
Ragweed
1 increasing
11-50 Increasing
Soybean
2005
Kansas
Conyza canadensis
Horseweed
51-100
increasing
10,001-100.000
increasing
Cotton
Soybean
2005
Ambrosia trifida Giant
Ragweed
2-5 increasing
601-1,000
increasing
Soybean
2006
Amaranthus rudis
Common Waterhemp
2-5 Increasing
101-500
increasing
Soybean
2006
Ambrosia artemisiifolia
Common Ragweed
1 increasing
11-50 increasing
Soybean
2007
Kentucky
Conyza canadensis
Horseweed
2-5 increasing
51-100
increasing
Soybean
2001
Maryland
Conyza canadensis
Horseweed
6-10 increasing
501-1,000
increasing
Soybean
2002
Michigan
Conyza canadensis
Horseweed
1 1ncreasing
5M0Q
increasing
Nursery
2007
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1132
Minnesota
Ambrosia trifida Giant
Ragweed
2-5 increa^ng
101-500
increasing
Soybean
2006
Amaranthus rudis
Common Waterhemp
2-5 incre^ng
51-100
increasing
Soybean
2007
Mississippi
Conyza canadensis
Horseweed
101-500
increasing
1.001-10,000
inaeasing
com,
cotton, rice,
and
. soybean
2003
Lolium muHiflorum
Italian Ryegrass
unknown
1,001-10,000
increasing
Cotton
Soybean
2005
Missouri
Conyza canadensis
Horseweed
101-500
increasing
10,001-100.000
increasing
Cotton
2002
Ambrosia artemisitfoHa
Common Ragweed
1
11-50
Soybean
2004
Amaranthus rudis
Common Waterhemp**
1 increasing
1,001-10,000
increasing
Corn
Soybean
2005
New Jersey
Conyza canadensis
Horseweed
6-10 increasing
101-500
increasing
Soybean
2002
North
Carolina
Conyza canadensis
Horseweed
2-5 increasing
6-10 increasing
Cotton
2003
Ohio
Conyza canadensis
Horseweed
101-500
increasing
1,001-10,000
increasing
Soybean
2002
Conyza canadensis
Horseweed*
2-5 increasing
101-500
increasing
Soybean
2003
Ambrosia trihda Giant
Ragweed
2-5 increasing
101-500
increasing
Soybean
2004
Oregon
Lolium multifiorum
Italian Ryegrass
1 stable
1-5 stable
Orchards
2004
Perrnsylvania
Conyza canadensis
Horseweed
2-5 increasing
101-500
increasing
Soybean
2003
Tennessee
Conyza canadensis
Horseweed
501-1,000
increasing
>2,000,000
Increasing
Cotton
Soybean
2001
Amaranthus paimeri
Palmer Amaranth
2-5 Increasing
101-500
Increasing
Cotton
2006
Ambrosia trifida Giant
Ragweed
101-500
increasing
1.001-10.000
increasing
Cotton
Soybean
2007
* resistant to ch!orimuron*ethyl, cloransulam-methyl, and glyphosate ** resistant to acif)uorfen-Na. cloransulam-methyl, fomesafen,
giyphosate, imazamox, imazethapyr, and iactofen **• resistant to chlorimurorvethyl, glyphosate, and imazethapyr
Monsanto’s guidance for weed resistance management in GT alfalfa is as follows (Monsanto
2008):
• Scout fields before and after each herbicide application.
• Use the right herbicide product at the right rate and at the right time.
• To control flushes of weeds in established alfalfa, make applications of Roundup
WeatherMAX herbicide at 22 to 44 oz/A before weeds exceed 6”, up to 5 days before
cutting.
• Use other herbicide products tank-mixed or in sequence with Roundup agricultural
herbicide if appropriate for the weed control program.
• Report repeated non-performance to Monsanto or your local retailer.
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1133
4.4 Summary of Findings
At least 129 different weed species are identified as minor or major problems in alfalfa. Out of
14 new glyphosate resistant weeds found since 1998, eight are known to be weeds in alfalfa. Out
of at least 21 weeds that have natural resistance to glyphosate, ten are known to be a problem in
alfalfa. These 1 8 weeds that are both resistant to glyphosate and traditionally listed as problems
in alfalfa include; common ragweed, horseweed, Italian ryegrass, Johnsongrass, Palmer
Amaranth, buckhom plantain, goosegrass, junglerice, bermudagrass, burning nettle, cheeseweed,
common lambsquarters, field bindweed, filaree, large crabgrass, momingglory, nutsedge, and
purslane. Although the composition of weed shifts is based on the local seedbank, these 1 8
weeds are candidates for becoming more prevalent than GT sensitive weeds in rotations that
include GT alfalfa.
Mechanisms of glyphosate resistance include resistant EPSP synthase, degradation of
glyphosate, inactivation of glyphosate, and altered translocation of glyphosate.
Nineteen states and over two million acres of cropland are infested with new glyphosate resistant
weeds. The heaviest infestation is in the Southeast and Midwest. Overlap with the major alfalfa
producing states in the Intermountain regions seems to be minimal at this point. However, given
that there is overlap between glyphosate resistant weed locations and alfalfa hay acreage there is
potential for rapid shifts of glyphosate resistant weeds into GT alfalfa fields if GT alfalfa were to
be widely adopted. California is a concern because glyphosate resistant weeds are present and
alfalfa is a major crop in California.
Weeds are controlled in conventional alfalfa with chemicals (herbicides), cultural methods
(rotation, companion crops, monitoring), and mechanical methods (tillage). The cultural and
mechanical methods are permitted for organic farmers. GT systems allow for the use of one
additional herbicide, glyphosate.
G-35
Appendix G-1 . References
All URLs confirmed in June or July 2008.
1134
Ball, D.; Collins, M.; Lacefield, O,; Martin, N.; Mertens, D.; Olson, K.; Putnam, D.;
Undersander, D. & Wolf, M. (No Year), Understanding Forage Quality, Technical
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Results; California and the U.S. Proceedings, National Alfalfa Symposium, 13-15
December 2004, San Diego, CA; UC Cooperative Extension, University of California,
Davis 95616. http://alfalfa,ucdavis.edu
Canevari, W. M., Orloff, S.B., Lanini, W.T., Wilson, R.G., Vargas, R.N., Bell, C.E., Norris,
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Proceedings, 37th California Alfalfa & Forage Symposium, Monterey, CA, 17-19
December, 2007. UC Cooperative Extension, Agronomy Research and Information
Center, Plant Sciences Department, One Shields Ave., University of California, Davis
95616. http://alfalfa.ucdavis.edu
G-36
1135
Cerdeira, A. L. & Duke, S. O. (2006), The Current Status and Environmental Impacts of
Glyphosate-resistant Crops; a Review., J Environ Qual 35(5), 1633—1658.
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CDFA (no year a) California Department of Food and Agriculture, Johnsongrass.
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CDFA (no year b) California Department of Food and Agriculture, Field Binweed.
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Clay, S. A. & Aguilar (1998), Weed Seedbanks and Corn Growth following Continuous Com or
Alfalfa, Agronomy Journal 90, 8 1 3-8 1 ,
Cline, H. 2004. Benefits, challenges of Roundup Ready alfalfa examined. Western Farm Press.
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Cudney, D. W. & Elmore, C. L. (2007), Bermudagrass; Integrated Pest Management for Home
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Cudney, D. W.; Elmore, C. L. & Molinar, R. H. (2007), Common Purslane; Integrated Pest
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Duble, R. L. (no year) Goosegrass, Texas Cooperative Extension
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Elmore, C. (2002), Crabgrass: Integrated Pest Management for Home Gardeners and Landscape
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Filmer, A. K. (No Year), Toxic Plants; Alphabetical by Common Name, Technical report.
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G-37
1136
Forney, D. R.; Foy, C. L. & Wolf, D. D. (1985), Weed Suppression in No-Till Alfalfa {Medicago
saliva) by Prior Cropping of Summer-Annual Forage Grasses, Weed Science 33, 490-497.
Gianessi, L. P.; Silvers, C. S.; Sankula, S. & Carpenter, J. E. (2002), Plant Biotechnology:
Current and Potential Impact For Improving Pest Management In U.S. Agriculture An
Analysis of 40 Case Studies Herbicide Tolerant Alfalfa, National Center for Food and
Agricultural Policy, Technical report. National Center for Food and Agricultural Policy,
1-13. http://www.ncfap.org/40CaseStudies/CaseStudies/AifalfaHT.pdf
Glenn, S. and Meyers, R.D. (2006), Alfalfa Management in No-tillage Com, Weed Technology
20, 86-89.
Goodell, P.B. (2006). Alfalfa Crop Rotation. UC Pest Management Guidelines.
http://www.ipm.ucdavis.edu/PMG/rl 90081 1 .html
Guerena, M. & Sullivan, P. (2003), Organic Alfalfa Production: Agronomic Production Guide,
Technical report. Appropriate Technology Transfer for Rural Areas.
http://attra.ncat.org/attrapub/PDF/alfalfa.pdf
Hall, M. H. (1992), Ryegrass, Technical report, Pennsylvania State University.
http://cropsoil.psu.edu/Extension/Facts/agfactl9.pdf
Hammon, B., Rinderle, C., and Franklin, M. (2007), Pollen Movement from Alfalfa Seed
Production Fields, Technical report, Colorado State University Cooperative Extension.
www.colostate.edu/Depts/CoopExt/TRA/Agronomy/Alfalfa/Hammon.RRpollenflow.pdf
Harker, K. N.; Clayton, G.; Blackshaw, R.; ODonovan, J.; Lupwayi, N.; Johnson, E.; Gan, Y.;
Zentner, R.; Lafond, G. & Irvine, R. (2005), Glyphosate-resistant spring wheat
production system effects on weed communities, Weed Science 53, 451-464.
Heap, 1; Glick, H; Glasgow, L; Beckie, H (2008) International Survey of Herbicide Resistant
Weeds. http://www.weedscience.org/In.asp.
Hilgenfeld, K.; Martin, A.; Mortensen, D. & Mason, S. (2004), Weed Management in a
Glyphosate Resistant Soybean System: Weed Species Shifts, Weed Technology 18, 284-
291.
Hill, S. R. (1993), Jepson Manual Treatment for Malvaceae parviflora. Technical report,
University of California, http://ucjeps.berkeley.edu/cgi-
bin/get_JM_treatment.pl?5042,5084,5087.
Hubbard, K. (2008), A Guide to Genetically Modified Alfalfa, Technical report. Western
Organization of Resource Councils.
http://www.worc.org/issues/art_issues/alfalfa_guide/alfalfa_guide.html
G-38
1137
Jennings, J. (No Year), Understanding Autotoxicity in Alfalfa, Technical report. University of
Arkansas.
http://www.uwex.edu/ces/forage/wfc/proceedings2001/understanding_autotoxicityjn_alf
alfa.
Johnson, W. G. & Gibson, K. D. (2006), Glyphosate-Resistant Weeds and Resistance
Management Strategies: An Indiana Grower Perspective, Weed Technology 20, 768-772.
Lanini, WT. (no year a) Common ragweed {Ambrosia artemisiifoUa). Weed Identification 8.
Pennsylvania State University, College of Agriculture, Cooperative Extension Service.
http://weeds.cas.psu.edu/psuweeds/COMMON%20RAGWEED.pdf.
Lanini, WT. (no year b) Johnsongrass {Sorghum halapense) Weed Identification 6. Pennsylvania
State University, College of Agriculture, Cooperative Extension Service.
http://weeds.cas.psu.edu/psuweeds/JOHNSONGRASS.pdf.
Lanini, WT (no year c) Common lambsquarters {Chenopodium album)
Pennsylvania State University, College of Agriculture, Cooperative Extension Service.
http://weeds.cas.psu.edu/psuweeds/LAMBSQUARTERS.pdf
Loux, M.; Stachler, J.; Johnson, B.; Nice, G.; Davis, V. & Nordby, D. (2006), Biology and
Management of Horseweed, Technical reporf Purdue University.
http://www.ces.purdue.edu/extmedia/gwc/gwc-9-w.pdf
Loux, M. M.; Stachler, J. M.; Johnson, W. G.; Nice, G. R. & Bauman, T. T. (2007), Weed
Control Guide for Ohio Field Crops, Ohio State University.
http://ohioline.osu.edu/b789/index.html.
McCordick, S. A.; Hillger, D. E.; Leep, R. H. & Kells, J. J. (2008), Establishment Systems for
Glyphosate-Resistant Alfalfa, Weed Technology 22, 22-29.
Miller, S. D.; Wilson, R. G.; Kniss, A. R. & Alford, C. M. (2006), Roundup Ready Alfalfa: A
New Technology for High Plains Hay Producers, Technical report. University of
Wyoming Cooperative Extension Service. http://ces.uwyo.edu/PUBS/Bl 173.pdf
Mitich, L. (No Year), Cheeseweed - The Common Mallows, Weed Science Society of America.
http://www.wssa.net/Weeds/tD/WorldOfWeeds.htm#x.
Monsanto (2008), Technology Use Guide, Technical report, Monsanto.
http://www.monsanto.eom/monsanto/ag_products/pdf/stewardship/2008tug.pdf
NAFA (2007) National Alfalfa and Forage Alliance, California Alfalfa Seed Production
Symposium. March 5-6, 2007. http://ucce.ucdavis.edU/specialsites/aif_seed/2007/l.pdf
NAFA (2008) National Alfalfa and Forage Alliance, Winter Survival, Fall Dormancy & Pest
Resistance Ratings for Alfalfa Varieties, Technical report. National Alfalfa and Forage
Alliance. http://www.alfaIfa.org/pdf/0708varietyLeaflet.pdf
G-39
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Nandula, V, K.; Reddy, K. N.; Duke, S. O. & Poston, D. H. (2005), Glyphosate-Resistant
Weeds: Current Status and Future Outlook, Outlooks on Pest Management, 1 83-187.
NPS (2007) National Park Service. Junglerice Invasive Map.
http://www.nps.gov/plants/ALIEN/map/eccol.htm.
OMAFRA (2008) Ontario Ministry of Agriculture, Food and Rural Affairs, Guide to Weed
Control, Technical report.
http://www.omafra.gov.on.ca/english/crops/facts/notes/notes2.htm
Organic Garden (2007), Small Nettle Weed Information.
http://www.gardenorganic.org.uk/organicweeds/weed_information/weed.php?id=53.
Orloff, S. B.; Carlson, H. L. & Teuber, L. R.Orloff, S. B.; Carlson, H. L. & Teuber, L. R., ed.
(1997), Intermountain Alfalfa Management, Vol. 3366, University of California, Division
of Agriculture and Natural Resources.
http://ucce.ucdavis.edU/files/filelibrary/2 1 29/1 8336.pdf
Peeper, T.; Kelley, J.; Edwards, L. & Krenzer, G. (2000), Italian Ryegrass Control in Oklahoma
Wheat for Fall 2000, Technical report, Oklahoma State University.
http://www.wheat.okstate.edu/wm/ptfs/weedcontrol/pt-00-23/pt2000-23.htm,
Pittwater Council (No Year), Noxious Weeds: Morning Glory.
http://www.pittwater.nsw.gov.au/environment/noxious_weeds.
Pratt, M.; Bowns, J.; Banner, R. & Rasmussen, A. (2002), Redstem Filaree, Utah State
University. http;//extension.usu.edu/range/forbs/fllaree.htm.
Puricelli, E. & Tuesca, D. (2005), Weed Density and Diversity Under Glyphosate-resistant Crop
Sequences, Crop Protection 24, 533-542.
Putnam, D.; Russelle, M.; Orloff, S.; Kuhn, J.; Fitzhugh, L.; Godfrey, L.; Kiess, A. & Long, R.
(2001), Alfalfa, Wildlife, and the Environment: The Importance and Benefits of Alfalfa
in the 21st Century, Technical report, California Alfalfa and Forage Association.
http://alfalfa.ucdavis.edu/-files/pdf/AIf_Wild_Env_ BrochureFINAL.pdf.
Rainbolt, C.; Thill, D. & Young, F. (2004), Control of Volunteer Herbicide-Resistant Wheat and
Canola, Weed Technology 18, 71 1-718.
Renz, M. (2007), Fall Alfalfa Removal Using Herbicides, University of Wisconsin.
http://ipcm.wisc.edu/WCMNews/tabid/53/EntryID/387/Default.aspx.
Robinson, S. E. & Alex, J. (1987), Poisoning of Livestock by Plants, Ministry of Agriculture,
Food, and Rural Affairs, Technical report. Ministry of Agriculture, Food, and Rural
Affairs, http://www.omafra.gov.on.ca/english/livestock/dairy/facts/87-016.htm.
G-40
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Rogan, O. & Fitzpatrick, S. (2004), Petition for Determination ofNonregulated Status; Roundup
Ready Alfalfa (Medicago saliva L.) Events JlOl and J163, Technical report, Monsanto.
http://www.aphis.usda.gOv/brs/aphisdocs/04_11001p.pdf.
For Appendix G-3 - Regional review of weeds in alfalfa. Monsanto. Cites the following sources:
• Loux, M.M., J. M. Stachler, W. Johnson, G. Nice, and T. Bauman. 2007. Weed Control
Guide for Ohio and Indiana. Ohio State University Extension and Purdue Extension
[WWW. btny .purdue.edu/pubs/W S/W S- 1 6/] .
• Dillehay, B. and W. Curran. 2006. Guidelines for Weed Management in Roundup Ready
Alfalfa®, - Agricultural Research and Cooperative Extension. The Pennsylvania State
University. Agronomy Facts 65, 2006. [cropsoil.psu.edu/extension/facts/agfact65.pdf];
• Weed Control Guide for Field Crops 2007, Michigan State University
[http://www.msuweeds.com/publications/2007_weed guide/].
• Guide for Weed Management in Nebraska. 2007. University of Nebraska - Lincoln
Publication EC130. [http://www.ianrpubs.unl.edu/epublic/live/ecl30/build/ecl30.pdf];
• Wrage, L., D. Deneke. 2006. Weed Control in Forages Legumes- South Dakota State
University, [http://agbiopubs.sdstate.edu/artieles/FS525L.pdf];
• Becker, R., 2006 Cultural and Chemical Weed Control in Field Crops,- University of
Minnesota;
• Boerboom, C.M., E.M. Cullen, R.A. Flashinski, CR. Grau, B.M. Jensen and M.J. Renz.
2007. Pest Management in Wisconsin Field Crops,- University of Wisconsin.
[http://learningstore.uwex.edu/pdf/A3646.PDF].
• Scouting Alfalfa in North Carolina. Scouting for Common Weed Problems; 2007 North
Carolina Agricultural Chemical Manual.
[http://ipm.ncsu.edu/alfalfa/Scouting_Alfalfa_for_common_weed probiems.html].
• Beck, K.G., F.B. Peairs, D.H. Smith and W.M. Brown Alfalfa: Weeds, Diseases and Insects,
, Colorado State University, Bulletin No. 706.
[http://www.est.colostatc.edu/pubs/crops/00706.html].
» Caddel et al. Alfalfa Production Guide for the Southern Great Plains - Oklahoma State
University Extension Service [http://alfalfa.okstate.edu/].
• PNW Weed Management Handbook 2007, University of Idaho, Oregon State University,
Washington State University [http://pnwpest.org/pnw/weeds713W_GRAS16.dat]
• Schmierer, J.L. and Orloff, S.B. Weeds (1995) - Intermountain Alfalfa Management,
Division of Agriculture and Natural Resources, University of California, Publication 3366.
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Season Grass Stands and in Cropland, Technical report, USDA and Ohio State
University. http://agcrops.osu.edu/weeds/documents/AgronomyTechnicalNoteOH-
1 kochiaamaranth.pdf.
Sheaffer, C., N. P. Martin, J.F.S. Lamb, G. R. Cuomo, J. G. Jewett and S. R. Quering. 2000.
Stem and leaf properties of alfalfa entries. Agronomy Journal. 92: 733-739.
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Schneider, N. & Undersander, D. (2008), Italian Ryegrass as a Companion for Alfalfa Seeding,
Focus on Forage, University of Wisconsin 10.
http://www.uwex.edu/ces/crops/uwforage/ltalRye-FOF.pdf
Steckel, L. (no year a) Horseweed, University of Tennessee Extension W 106.
http://www.utextension.utk.edU/publications/wfiles/W 1 06.pdf
Steckel, L. (no year b) Pigweed Description, History and Management
http://www.utextension.utk.edu/fieldcrops/weeds/pigweed.htm.
Steckel, L. (no year c) Goosegrass, University of Tennessee Extension W 1 16.
http://www.utextension.utk.edU/publications/wfiles/W 1 1 6.pdf.
Stoltenberg, D. E. & Jeschke, M. R. (No Year), Occurrence and Mechanisms of Weed
Resistance to Glyphosate, Technical report. University of Wisconsin-Madison.
http://www.soils.wisc.edu/extension/FAPM/2003proceedings/Stoltenberg.pdf
Stritzke, J. (No Year), Crabgrasses, Oklahoma State University.
http://alfalfa.okstate.edu/weeds/sumanngrass/crabgrasses.htm.
Thome Research (2007), Urtica dioica\ Urtica urens (Nettle), Alternative Medicine Review 12,
280-284. http://www.thome.com/raedia/UrticaMonol2-3.pdf.
Tickes, B. (2002), Evaluation of Stinger (Clopyralid) for Weed Control in Broccoli, Technical
report, University of Arizona Cooperative Extension.
http://cals.arizona.edu/pubs/crops/azl292/azl292_5d.pdf
Trainor, M. & Bussan, A. J. (2001), Redstem Filaree, Montana State University.
http://weeds.montana.edu/crop/redstem.htm.
Undersander, D. J. & Pinkerton, B. W. (1989), Utilization of Alfalfa, Cooperative Extension
Service Clemson University. Forage Leaflet 15.
http://virtual.clemson.edu/groups/psapubIishing/PAGES/AGRO/FORAGE15.PDF
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Van Deynze, A. V.; Putnam, D. H.; Orloff, S.; Lanini, T. & Canevari, M. (2004), Roundup
Ready Alfalfa: An Emerging Technology, Agriculture Biotechnology in California ,
Technical report. University of California, Davis.
http://anrcatalog.ucdavis.edu/pdf/8153.pdf
Virginia Tech (no year) Junglerice.
http://turfweeds.contentsrvr.net/plant.php?do=view&batch=&id= 1 84.
G^2
1141
Wall, A. & Whitesides, R. (2008), Buckhorn Plantain, Technical report, Utah State University.
http://extension,usu.edu/files/publications/publication/AG_Weeds_2008-01pr.pdf
Wilen, C. A,; M. E. McGiffen, J. & Elmore, C. L. (2003), Nutsedp: Integrated Pest
Management for Home Gardeners and Landscape Professionals, Technical report,
University of California. http://www.ipm.ucdavis.edu/PDF/PESTNOTES/pnnutsedge.pdf
Wilson, R. G. (1981), Weed Control in Established Dryland Alfalfa (Medicago saliva). Weed
Science 29, 615-618.
York, A.; Stewart, A.; Vidrine, P. & Culpepper, A. (2004), Control of Volunteer Glyphosate-
Resistant Cotton in Glyphosate-Resistant Soybean, Weed Technology 18, 532-539.
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Appendix G-2. Literature Search
1.0 Literature Search Strategy
The following literature search was done for two of the technical reports:
Effects of Glyphosate-tolerant weeds in agricultural systems (former title: Increase in RR
resistant weeds in crops)
Effects of Glyphosate-tolerant weeds in non-agricultural ecosystems (former title: Increase in RR
resistant weeds in non-crop ecosystems)
1.1 Purpose
The purpose of this literature search is to locate references about the potential impacts of
glyphosate-tolerant weeds in agricultural systems and in natural ecosystems.
The following DIALOG databases were included in the search:
□ File 10:AGRICOLA 70-2008/Jun
□ (c) format only 2008 Dialog
□ File 156:ToxFile 1965-2008/Jun W2
□ (c) format only 2008 Dialog
□ File 266:FEDRIP 2008/Feb
□ Comp & dist by NTIS, Inti Copyright All Rights Res
□ File 245:WATERNET(TM) 1971-2008Apr
□ (c) 2008 American Water Works Association
File 55;Biosis Previews(R) 1993-2008/Jun W2
□ (c) 2008 The Thomson Corporation
File 6:NTIS 1964-2008/Jun W4
□ (c) 2008 NTIS, Inti Cpyrght All Rights Res
File 41 :Pollution Abstracts 1966-2008/May
□ (c) 2008 CSA.
File 40:Enviroline(R) 1975-2008/Apr
□ (c) 2008 Congressional Information Service
File 76:Environmental Sciences 1966-2008/Jun
0 (c) 2008 CSA.
File 24:CSA Life Sciences Abstracts 1966-2008/Mar
D (c) 2008 CSA.
File 1 17: Water Resources Abstracts 1966-2008/Mar
□ (c) 2008 CSA.
File 144:Pascal 1973-2008/Jun W2
0 (c) 2008 INIST/CNRS
File 50:CAB Abstracts 1972-2008/Apr
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□ (c) 2008 CAB International
File 44:Aquatic Science & Fisheries Abstracts 1966-2008/Mar
(c) 2008 CSA.
0 File 7 1 :ELSEVIER BIOBASE 1 994-2008/May W4
0 (c) 2008 Elsevier B.V.
File 143:Biol. & Agric. Index 1983-2008/Apr
(c) 2008 The HW Wilson Co
□ File 203 ;AGRJS 1 974-2008/Feb
Dist by NAL, Inti Copr. All rights reserved
Descriptions of these files are available at http://library.dialog.com/bluesheets/.
1 .2 Scope of Search
The search focused on any published references between 2000 and the present. A list of titles
was screened followed by screening of abstracts for relevant titles. There were no limits on
language for titles but only English language publications were retrieved for evaluation.
1.3 Keywords
A list of search parameters is listed below.
Synonyms of key topic
Glyphosate toleran*
Glyphosate resistan*
Roundup® Ready
Key words in combination with key topic Weed management Weed mitigation Weed control
Alfalfa
Medicago
Evolution
1 .4 Results
SI 471 1 GLYPHOSATEOfTOLERAN? OR RESIST?) OR ROUNDUP0READYS2 3534 S1/2000:2008S3
121649 ALFALFA OR MEDICAGO S4 1796168 WEED? OR EVOLUTION
55 27S2 AND S3 ANDS4
56 14 RD S5 (unique items)
□ 7/K,6/l (Item 1 from file; 144)DIALOG(R)File 144 :(c) 2008 INIST/CNRS. All rts. reserv.
17594709 PASCAL No.: 06-0183713
*A!falfa* management in no-lillage corn
•2006’
•Glyphosate*-*resistant’ com was no-till planted into ’alfalfa* that wasin the early bud stage (UNCUT) or had
been cut 3 to 4 d earlier and baledfor hay (CUT). ’Alfalfa* control and com yield were measured in nontreatedplots
as well as plots treated with or tank-mixed with 2,4-D or dicamba applied at planting (AP) or POST.* Alfalfa’
control was greater for all AP treatments of UNCUT compared toCUT ’alfalfa’. Glyphosate plus dicamba applied
AP controlled ’alfalfa’better than the other AP treatments resulting in increased com yieldcompared with other
G-45
1144
AP... Postemergence applications of glyphosate alone ortank^ixed with 2,4-D or dicamba controlled *alfalfa*
better 6 weeks after treatment than ^ applications of the same herbicides; however, com yield same herbicides.
Com yield averaged 13% higher following herbicideappHcations to UNCUT compared with CUT *alfalfa*, so the
value of *alfalfa* hay must be weighed against the loss of com yield when makingdecisions concerning the
management of an *alfalfa*-corn rotation.Descriptors: Zero tillage; *Weed* control; *Weed* science; *Medicago*
sativa
0 7/K,6/2 (item 2 from file; 10)DIALOG(R)File 10:(c) format only 2008 Dialog. All rts. reserv.4712341
43956730 Holding Library; AGL
Comparing *Roundup* ♦Ready* and Conventional Systems of * Alfalfa* Establishment
*2007*
URL:http;//dx.doi.org/10.1094^G-2007-0724-0!-RS
♦Roundup* ♦Ready* (RR) technology provides a new approach for *weed*
0 control during *alfalfa* (♦Medicago* sativa L.) establishment. We determined the effect of RR and
conventional establishment systems on*alfalfa* yield, *weed* yield, and forage quality when *aifalfa* was
established using solo-seeding or oat mulch methods. A RR system was a RR*a!falfa* in combination with
glyphosate (Roundup) and a conventional system was a non-RR variety with imazamox (Raptor). Non-RR and RR
aifelfaswere also seeded with an oat companion crop. *Alfalfa* yields, plantpopulations, and forage quality were
similar for the RR and conventionalsystems within solo-seeding and oat establishment methods in the seedingyear.
Total seeding-year *alfalfa* yield was greater when solo-seeded usingan herbicide than when seeded with an oat
companion crop harvested at boot. ♦Alfalfa* yield for the oat mulch and oat companion crop treatments werenot
consistently different over...
DESCRIPTORS: *Medicago* sativa ‘alfalfa*; ‘weeds*; *weed* control;
Identifiers: ‘Roundup* ‘Ready* *alfalfa*Sectton Headings: F120 PLANT PRODUCTION-
FIELD CROPS; F900 ‘WEEDS*
□ 7/K,6/3 (item 3 from file: 55)DIALOG{R)File 55:(c) 2008 The Thomson Corporation. All rts.
reserv.i8335235 BIOSISNO.: 200510029735 Influence of ‘Roundup* ‘Ready* (R) soybean production systems
and
glyphosate application on pest and beneficial insects in wide-row soybean*2004* ABSTRACT: ‘Roundup*
♦Ready* (R) soybean, Glycine max (L.) Merrill, in
widerow planting systems were investigated in 1997 and...
□ ...pest and beneficial insects. Populations of adult bean leaf beetle, Cerotoma trifurcata (Forster), and
threecomered ‘alfalfa* hopper, Spissistilus festinus (Say), and larvae of green cloverworm, Hypenascabra (F.),
and velvetbean cateq3illar, Anticarsia gemmatalis (Hubncr),were not affected by genetically altered ‘Roundup*
♦Ready* soybean or byapplications of glyphosate. Numbers of adult big-eyed bug, Geocoris
punctipes (Say.. .influenced G. punctipes densities in 3 of ! I weeks. These
1.0 effects were attributed to increased ‘weed* densities having a positive effect on G.punctipes numbers
during this 3-week period. Increased...
0 ...1 of 2 years. These elevated numbers, however, were also related tohigher densities of ‘weeds*. The results
presented herein demonstratedthat the ‘Roundup* ‘Ready* soybean system, including applications
ofglyphosate, had no detrimental effects on pest and beneficial insects ORGANISMS: Spissistilus festinus
(threecomered ‘alfalfa* hopper}
(Homoptera strain-*Roundup* ‘Ready*;
O 7/K,6/4 (item 4 from file: 55)DlALOG(R)File 55:(c) 2008 The Thomson Corporation. All rts.
reserv.l 7883376 BIOSIS NO.: 200400254133 Influence of ‘Roundup* ‘Ready* soybean production systems and
glyphosate
application on pest and beneficial insects in narrow-row soybean. *2004* ABSTRACT: ‘Roundup* *Ready*(R)
soybeans, Glycine max (L.) Meirill, in
narrow-row planting systems were investigated in 1998...
...numbers for meaningful analysis included adult bean leaf beetle, Cerotoma trifurcata (Forster); adult three-
comered ‘alfalfa* hopper, Spissistilus festinus (Say); adult big-eyed bug, Geocoris punctipes (Say), and;
larvae of green...
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...C. trifurcata, S. festinus, P. scabra and A. gemmatalis were not reducedin genetically altered *Roundup*
*Ready* soybean, or by recommended (bylabel) or ddayed applications of glyphosate. Numbers of G,
punctipesalso were not reduced in *Roundup* *Re 2 KJy* «)ybean, but were reduced byrecommended
applications of glyphosate during weeks three and four
following been indirectly reduced by glyphosate within sample weeks two
and threebecause of variations in *weed* densities after treatment with the
herbicide.
...ORGANISMS: Spissistilus festinus {*alfalfa* hopper) (Homoptera oil crop, *Roundup* *Ready* line...
^Roundup* *Ready* productionsystems......*weed* densities
0 7/K,6/5 (Item 5 from file: 1 0)DIALOG(R)File iO:(c) format only 2008 Dialog. AH rts. reserv.459S987
43898530 Holding Library: AGL
0 Evaluating Glyphosate Treatments on ^Roundup* *Ready* ♦Alfalfa* for Crop
2.0 Injury and Feed Quality*2007* URL: http://dx.doi.org/I0.1094/FG-2007-0201-0I-RS*Weed* control is
one of the factors that impact *a!falfa* producers,
with negative effects on quality often in the year of establishmentGlyphosate is a broad-spectrum herbicide that
controls many troublesomeannua! and perennial *weeds* , and new cultivars that are tolerant of glyphosate
application have been developed. The crop response of glyphosateon these new varieties has not been reported. This
research examined*alfalfa* tolerance under field conditions, and high rates were used tochallenge the plants to
determine ranging from 0.75 to 3 lb a.eyacre sprayed before each of four ♦alfalfa* harvests had no meaningful
crop injury in the establishment yearor in the subsequent two.. .of 9 lb a.e./acre over a 3*year period caused
noreduction in *alfalfa* yield or nutritive value at any cutting in any of thethree years.
DESCRIPTORS: ♦Medicago* sativa...,..*alfalfa*;
postemergent ♦weed*control;Identifiers: *Roundup*
♦Ready* *a!falfa*
0 7/K,6/6 (Item 6 from file: 55)DIALOG(R)Filc 55:(c) 2008 The Thomson Corporation. Ail rts.
reserv.002026506 1 BIOSIS NO.: 2008003 1 2000 Establishment systems for ♦gIyphosate*-*resistant*
*alfa!fa**2008* ABSTRACT; Glyphosare-resistant ‘alfalfa* offers new ‘weed* control options
for *alfalfa* establishment. Field studies were conducted in 2004 and 2005 to determine the effect of
establishment method and *weed* control method on forage production and *alfalfa* stand establishment.
Seedingmethods included clear seeding and companion seeding with oats. Herbicidetreatments
Included.. .reduce forage yield or stand density in 2004. No
glyphosate injury was observed in 2005. *Weed* control with glyphosate was
3.0 more consistent than with imazamox or imazamox + clethodim. In 2004, total seasonal forageyield, which
consisted of ‘alfalfa*, ‘weeds*, and oats (in sometreatments), was the highest where no herbicide was applied in
the...
...was reduced where herbicides were applied in both establishment systems.In 2005, seeding method or ‘weed*
control method did not affect totaiseasona! forage production. ‘Alfalfa* established with the clear-
seededmethod and treated with glyphosate yielded the highest ‘alfalfa* dry
matter in both years. Imazamox injury reduced first-harvest *a1falfa*yield in the clear-seeded system in both
years. When no herbicide wasapplted, ‘alfalfa* yield was higher in the clear-seeded system. The oatcompanion
crop suppressed *alfa!fa* yield significantly in both years. ‘Alfalfa* established with an oat companion crop had
a lower *weed*biomass than the clear-seeded system where no herbicide was applied in both
years. ...ORGANISMS: ‘Medicago* sativa {‘alfalfa*} (Lcguminosae)
D 7/K,6/7 (Item 7 from file: 10)DIALOG(R)Fiie I0:{c) format only 2008 Dialog. All rts. reserv.4823604
44034732 Holding Library: AGL
*Glyphosate*-*resistant* crops: adoption, use and future considerations*2008* URL:
http://dx.doi.Org/I0.1002/ps.150iBACKGROUND: *GIyphosate*-*resistant* crops (GRCs) were first
introduced
in the United States in soybeans in 1996. Adoption has 13.2 million ha), cotton (5.1 million ha), canola (2.3
million ha) and*alfalfa* (0.1 million ha). Currently, the USA, Argentina, Brazil andCanada have the largest
plantings of GRCs. Herbicide use patterns wouldindicate that over 50% of ‘glyphosate* -‘resistant* (GR) maize
hectares and70% ofGR cotton hectares receive alternative mode-of-action treatments production system. Tillage
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was likely used for multiple purposes rangingfrom seed-l^ preparation to *weed* management.CONCLUSION:
GRCs representone of the more rapidly adopted *weed* management technologies in recenthistoiy. Current use
patterns would indicate that GRCs will likely continue© be a popular ♦weed* management choice that may also
include the use ofother herbicides to complement giyphosate. Stacking...
□ 7/K,6/8 (Item 8 from file: 55)DEALOG(R)FiIe 55:(c) 2008 The Thomson Corporation. All rts.
reM:rv. 18808410 BfOSIS NO.: 200600153805 *GIyphosate*-*resistant* crops: History, current status, and
future*2004*
...ORGANISMS: ♦alfdfa* (ieguminosae MISCELLANEOUS TERMS: *weed* management...
□ 7/K.6/9 (Item 9 from file: 50)DIALOG(R)FiIe 50:(c)2008 CAB International. Ail rts. reserv.0009n3458
CAB Accession Number: 20063199990
□ *Glyphosate*-*to!erant* *alfalfa* is compositionally equivalent to
conventional *alfalfa* ( *Medicago* sativa L.).Publication Year: 2006 *GIyphosate*-*tolerant* *alfaifa* (GTA)
was developed to withstand
Q over-the-top applications of giyphosate, the active ingredient in...
□ ... United States during the 2001 and 2003 field seasons along with controiand other conventional
*alfaifa* varieties for compositional assessment.Field trials were conducted using a randomized complete block
design withfour replication blocks at each site. *Alfalfa* forage was harvested atthe late bud to early bloom
stage from each plot at...
... from GTA JlOl x J163 is compositionally equivalent to forage from the
control and conventional *alfalfa* varieties. IDENTIFIERS: *alfaifa*;
....*weedicides*; .„*weedkillers*...*Medicago*sativa
□ 7/K,6/10 (Item 10 from file: 50)DlALOG(R)FiIe 50:(c) 2008 CAB International. All rts.
reserv.0007976368 CAB Accession Number: 20003004906
*Roundup* *Ready* *alfalfa*.Pubtication Year: 2000 Genetic engineering has been used to develop
*Roundup* *Ready* SUP TM
□ (i.e. giyphosate herbicide tolerant) *alfalfa*. There is a significant
interest in the use of RR ’alfalfa* to improve options for effective,
crop-safe ’weed* control, both for establishment and for the control of
tough perennial ’weeds* in established stands. The project to develop
’Roundup* ’Ready* ‘alfalfa* is a collaboration between Monsanto, Montana
State University and Forage Genetics International (FGI). Transformation,
event...
... application of Roundup Ultra. Applications at later reproductive slagesreduced seed yield. The current RR
♦alfalfa* timeline predicts thecommercial release of a wide range of RR ’alfalfa* varieties in
2004.0RGANISM DESCRIPTORS: ’Medicago* sativa...CABlCODES: ’Weeds* and Noxious
Plants
□ 7/K,6/n (Item U from file: 10)DIALOG(R)File I0:(c) format only 2008 Dialog. All rts. reserv.4660649
43931909 Holding Library: AGL
Is ’Roundup* ’Ready* ’alfalfa* right for you
*2007*
URL: http://cropwatch.unl.edu/
DESCRIPTORS: ’alfalfa*; ’weed* control;
Section Headings: F120 PLANT PRODUCTION-FIELD CROPS; HOOO
PESTICIDES-GENERAL; F200 PLANT BREEDING; F900 ’WEEDS*
7/K,6/I2 (Item 12 from file; lO)DIALOG(R)Filc i0:(c) format only 2008 Dialog. All rts. reserv.
□ 4442412 30961704 Holding Library: WYU; AGX ‘Roundup* ’Ready’.reg. ’alfalfa* a new technology for
high plains hay
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producers / Stephen D. Miller ... [et al.]*2006* URL:
http://www.uwyo.edU/CES/PUBS/B 1 1 73.pdfDESCRIP'IO^:
*Alfaifa*; *Weeds*;
D 7/K,6/13 (Item 13 from file: 50)DIALOG(R)File 50:{c) 2008 CAB international. All rts.
reserv.0008500330 CAB Accession Number; 2(M)33I67182
D Seed bank changes following the adoption of *glyphosate*-*tolerant*
□ crops.Publication Year; 2003 *Weed* seed banks in long-term tillage/rotation plots were sampled in
the early spring of 1999 and 2002, before and after the adoption of^glyphosate*-*tolerant* soyabean { Glycine max
) and maize ( Zea mays ), respectively. Canonical discriminant analysis was used to characterize first canonical
function was strongly associated with crop rotation. Themaize-oat ( Avena saliva )-luceme ( '''Medicago’* sativa )
rotation clustered separately from continuous maize and maize-soyabean rotations
when visualized in a...05), suggesting that practices used in the varyingsystems selected for divergent
communities. After employing *glyphosate**tolerant* maize and
soyabean varieties for three growing seasons (1999-2001), differences incommunity composition between.. .use
of a single, non-selective herblcideacross all treatments resulted in a more homogeneous *weed* seed
bankcommunity.
...ORGANISM DESCRIPTORS: *Medicago*; ...
S9 9600 HERBICIDE? ?0(TOLERAN? OR RESIST?)/2000:2008S3 121649 ALFALFA OR MEDICAGO S4
1796168 WEED? OR EVOLUTION S5 27 S2 AND S3 AND S4 SIO 35 S9 AND S3 AND S4 NOT S5 Sll 20
RD SIO (unique items)
□ 12/K,6/1 (Item I from file: 55)DIALOG(R)Filc 55:(c) 2008 The Thomson Corporation. All rts.
reserv, 1 8075829 BIOSIS NO.: 200400443748 Development of 2,4-D-resistant transgenics in Indian oilseed
mustard(Brassica juncea)*2004* ...ABSTRACT: monooxygenase, cloned downstream to the 35S promoter along
with a leader sequence from RNA4 of *a!falfa* mosaic virus (AMV leader
n sequence), for improved expression of the transgene in plant cells.Southem available transgenic lines
can be used for testing the potential of
2,4-D in *weed* control including the control of parasitic *weeds*
(Orobanche spp) of mustard and for low-till cultivation of mustard.
ORGANISMS: *Alfalfa* mosaic virus (Bromoviridae...vegetable crop,
♦herbicide* •resistant* transgenic line pest, ’weed*
D l2/K,6/2 (Item 2 from file: 50)DIALOG(R)File 50:(c) 2008 CAB International. All rts. reserv.0008797522
CAB Accession Number: 20053050074
O Efficacy of imidazolinone herbicides applied to imidazolinone-resistant
maize and their carryover effect on rotational crops.Publication Year: 2005 ... a 31% petroleum hydrocarbon
adjuvant at 125 and 250 mL ha SUP -I ,
□ respectively. Overall *weed* control varied from 85%, up to 95%. *Weed*spec!es controlled were
Setaria sp., Chenopodium album , Solanum sp.,Amaranthus retroflexus and Digitaria sanguinalis , and...
...to low, was the following: Beta vulgaris > Capsicum annum > Lycopersicumesculentum > Cucumis melo >
Hordeum vulgare > *Medicago* sativa > Loliummultiflorum > Avena sativa > Pisum sativum > Allium cepa >
Zea mays ....DESCRIPTORS: *herbicide* ‘resistance*; *wecd* control *weeds*... ORGANISM
DESCRIPTORS: ‘Medicago*; ...
n 12/K,6/3 (Item 3 from file: 50)DIALOG(R)File 50:(c) 2008 CAB International. All its. reserv.0009065754
CAB Accession Number: 20063137864
□ Influence of forage legume species, seeding rate and seed size on
competitiveness with annual ryegrass ( Lolium rigidum ) seedlings.Publication Year: 2006 ... as short-term forage
crops are an important non-chemical option for
the control of *herbiclde*-*resistant* annual ryegrass ( Lolium rigidum L.). The relative ability of 5 annual forage
legume species ( Trifoliumsubterraneum L., T. michelianum Savi., T. alexandrinum L., *Medicago*murex Wild
and Vicia benghalensis L.) to suppress annual ryegrassscedlings was examined in a DESCRIPTORS: *weed*
control ...ORGANISM DESCRIPTORS: ‘Medicago* murex
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□ 12/K,6/4(Item 4 from fiie: 1 56)DIALOG(R)File 156:(c) format only 2008 Dialog. All rts. reserv.3840082
NLMDocNo: 12852606
Injfluence of *herbicide* *to!erant* soybean production systems on insectpest populations and pest-induced
crop damage.Jun *2003*
Conventional soybean *weed* management and transonic *herbicide*-*tolerant* management were examined
to assess their effects on soybeaninsect pest populations in south Geoigia leafliopper, Empoasca fabae (Harris),
and grasshoppers Melanoplus spp.were more numerous on either conventional or *herbicide*-*tolerant* varieties on
certain dates, alUiough these differences were not consistentthroughout the season. Soybean looper, Pseudopiusia
includens (Walker), threecomered *alfalfa* hopper, Spissistilus festinus (Say), and whitefringed beetles,
Graphognathus spp , demonstrated no varietal preference in this study. Few *weed* treatment differences were
observed,but if present on certain sampling dates, then pest numbers were higher inplots where *weeds* were
reduced (either postemeigence herbicides or preplant herbicide plus postemergence herbicide). The exception to
this*weed* treatment effect was grasshoppers, which were more numerous in *weedy* plots when differences were
present. In post emergence herbicideplots, there were no differences in.. .the conventional herbicides (e.g., Classic,
Select, Cobra, and Storm) compared with specific gene-inserted*herbicide*-*tolerant* materials (i.e., Roundup and
Liberty).Defoliation, primarily by velvetbean cateipillar, was different betweensoybean We did not observe
differences in seasonal abundance of arthropod pestsbetween conventional and transgenic *herbicide*-*tolerant*
soybean.
n 12/K,6/5 (Item 5 from file: 50)DIALOG(R)FiIe 50:(c) 2008 CAB International. All rts. reserv.0008298057
CAB Accession Number: 20023152152
Effect of herbicide treatment on the productivity of some annual pasturelegumes.
Book Title: 13th Australian *Weeds* Conference: *weeds* "threats now and forever?", Sheraton Perth
Hotel, Perth, Western Australia, 8-13Seplember 2002: papers and proceedings
Publication Year: 2002
... seed production of 1 1 pasture legume cultivars ( Trifolium subterraneum cultivars Dalkeith and Urana, burr
medic [ *Mcdicago*polymorpha ] cv. Santiago, French serradella [ Omithopus sativus ] cv.Cadiz, yellow
serradella [ O. compressus ] cv. Charano DESCRIPTORS: *herbicide* *resistance*; *weed*
control *weeds*... ORGANISM DESCRIPTORS: *Medicago* polymorpha
0 12/K,6/6 (Item 6 from file; 55)DIALOG(R)File 55:(c) 2008 The Thomson Corporation. All rts.
reserv. 18860532 BIOSIS NO.: 200600205927
Effects of Artemisia afra leaf extracts on seed germination of selected crop
and *weed* species
•2005*
ABSTRACT; *Herbicide* *resi5tance* in *weeds* is a phenomenon threateningsustainable cereal production in
the winter rainfall region of South Africa. Every possible *wecd* control measure that may be used
tocompiement chemical *weed* control measures should be Investigated. Theeffect of aqueous leaf extracts of
the aromatic shrub African wormwood(Artemisia afra) on germination of selected crop and *wecd* species
wereinvestigated. The selected plant species included wheat (Triticumaestivum L.), *herbicide* *resistant*
and non-resistant ryegrass (Lolium,spp.), canola (Brassica napus) and lucerne (♦Medicago* saliva). Various
dilutions were investigated and the original extract was the most effective
in inhibiting ORGANISMS: *Medicago* saliva (Leguminosae
D 1 2/K,6/7 (Item 7 from file: 50)
DIALOG(R)File 50;{c) 2008 CAB International. All rts. reserv.
0008298120 CAB Accession Number: 20023152089 *Evolution* of paraquat
resistance in barley grass ( Hordeum leporinumLink. and H. glaucum
Steud.).Book Title: 13th Australian *Weeds* Conference; *weeds* "threats
now and forever?", Sheraton Perth Hotel, Perth, Western Australia, 8-
ISSeptember 2002: papers and proceedingsPublication Year; 2002
•Herbicide* *resistance* in *weed* species can eliminate the usefulnessof herbicides. In Australia, 25 *weed*
species have been documented withresistance to one or more of nine herbicide groups. Two *weedy* barleygrass
species, H. glaucum and H. leporinum [ H. murinum subsp. leporinum], infest crops and.. .paraquat on these two
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species, principally in lucerne and
grain crops, has resulted in the *evolution* of paraquat tesistance at a number ofsites in southern Australia. The
♦evolution* of paraquat resistance occursafter a prolonged period of use, often up to 20 years...
... will lead to a better understanding of how resistance is spread as wellas the *evolution* of paraquat resistance in
field populations.-DESCRlPTORS: *evolution*; ......*herbicide* *resistance*; ......*weeds*
...*Medicago* sativa.-.CABICODES: *Weeds* and Noxious Plants (FF500...
□ 12/K,6/8 (Item 8 from file: 50)
DIALOG(R)File 50;(c) 2008 CAB International. AH its. reserv.
0008751520 CAB Accession Number: 20053008750 *Evolution* spread of
♦herbicide* *resistant* barley grass ( Hordeumglaucum Steud. and H. ieporinum
Link.) in South Australia.Book Title: *Weed* management: balancing people, planet,
profit. HthAustralian *Weeds* Conference, Wagga Wagga, New South Wales,
Australia,6-9 September 2004: papers and proceedingsPubllcation Year: 2004 The
barley grasses ( H. glaucum and H. Ieporinum (H. murinum subsp.leporinum )) are
important *weeds* of crops and pastures in South Australia. Populations of both
species have evolved resistance to paraquat, primarily following intensive use of
paraquat for winter *weed*
control in lucerne { ♦Medicago* sativa ) crops. In the past few years.agricultura! consultants have been reporting an
increase in This research was conducted to determine the relative importance of seedmovement compared with
independent *evolution* for paraquat resistance in
D Hordeum spp. H. glaucum and H. Ieporinum seeds were collected from...
... by 7 km appeared to be the same genotype. These results suggest thatboth independent *evolution* and seed
movement are important in thedistribution of paraquat-resistant Hordeum spp. in South. ..DESCRIPTORS:
*evolution*; *herbicide* *resistance*; *weeds*
...♦Medicago* sativa.-.CABICODES; *Weeds* and Noxious Plants (FF500
□ 12/K,6/9 (Item 9 from file: 50)DIALOG(R)Fiie 50;(c) 2008 CAB International. All rts. reserv.0008324661
CAB Accession Number: 20023162508
Herbicides in *alfalfa* culture.
Original Title: Herblcidas na cultura da alfafa.
Publication Year: 2002
... the tolerance of lucerne cv. Crioula and the efficiency of
□ pre-emergent herbicides on broadleaved *weed* control, in 2 differentsoils having (a) 0.96% organic
matter (OM) and pH of 5.4 and (b) 2.61% OMand pH of 6.1 . The *weed* control efficiency of oxyfluorfen and
mixture ofdiuron+paraqiiat was also evaluated one day after...
... 24 and 0.36 of oxyfluorfen. Two controls were added to all experiments,
□ i.e. *weeded* unweeded. Pre-emergence herbicides were sprayed one dayafter planting in
moistened soil. In...
□ ... plants. Oryzalin was selective to the crop, providing a better controlof grasses and broadleaved
♦weeds* at the 2 highest doses, regardless ofthe amount of OM and soil pH. Acetochlor...
□ ... both contents of OM and soil pH, with excellent control of the broadleaved and grass *weeds*.
Flumeteulam and imazaquin may be appliedonly at the lowest dose tested, regardless of OM content in the
soil.providing good control of some broadleaved *weeds*, with spraying offiuazifop-P-butyl [fluazifop-P]
needed in post-emergence. The herbicidesshowed, in average, 10% more control of the *weeds* in soil with
2.61% oR)M and pH of 6.1, in comparison to the *weeds* in the soil with 0.96% ofOM and pH of 5.4. Lucerne
budding...
□ .. oxyfluorfen up to 12 days after application; this herbicide presentedgood potential for post-lasting
♦weed* control and excellent pre-emergencecontrol. Mixture application in tank (diuron^paraquat) just after
cutting
DESCRIPTORS: ♦herbicide* ♦resistance*; *weed*
control *weeds*... ♦Medicago* sativa
□ 12/K,6/10 (Item 10 from file: 50}DIALOG(R)FiIe 50:(c)2008 CAB International All rts.
reserv.0009320611 CAB Accession Number; 20073193351
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*Herbicide*-*resistant* crops as *weeds* in North Ameiica.
Publication Year: 2007
Growers have rapidly adopted transgenic *herbicide*-*rcsistant* (HR)
Q crops, such as canola ( Brassica napus L.), soyabean [ Glycine max (L.)
Merr.], maize ( Zea... crops and subsequent potential for volunteerism of these crops are assessed. HR volunteers
arc common *weeds* and the relative *weediness*
0 depends on species, genotype, seed shatter prior to harvest and
disbursement of seed at harvest-.limited if the crop volunteers are HR.There are generally no marked changes in
volunteer *weed* problemsassociated with these crops, except in no-tillage systems when glyphosate(GLY) is
used...
...DESCRIPTORS; *Herbicide* *resistance*; *Weed*conCrol....,.*Weeds*;
IDENTIFIERS: *alfalfa*; *weedicides*; ...... *weedkiners*
...ORGANISM DESCRIPTORS: *Medicago* sativa
12/K, 6/1 i (Item 11 from file; 50)
DiALOG(R)File 50:(c) 2008 CAB International. All rts. reserv.
0008751696 CAB Accession Number; 20053008458
How profitable are perennial pasture phases in Western Australian cropping systems?
Book Title: *Weed* management: balancing people, planet, profit. 14th Australian ‘Weeds* Conference,
Wagga Wagga, New South Wales, Australia, 6-9 September 2004; papers and proceedings
Publication Year: 2004
... that, in most parts of Western Australia, it is not currentlyprofitable to plant lucerne ( ‘Medicago* sativa )
on the scale requiredfor salinity abatement. However, these investigations have not incorporated the long-term
benefits that accrue from the use of lucerne toenhance management of ‘weeds* , especially for those growers
facing thethreat or actual presence of ‘herbicide* *resistance*. This work is an investigation of the economics
of lucerne when these various benefits are considered simultaneously. An existing model for analysing
•herbicide**resistance* in annual ryegrass ( Loltum rigidum ) in Western Australia(Ryegrass Resistance and
Integrated Management) is extended...
... pasture phase increase long-term profitability, relative to that ofcontinuous cropping, because of improved
‘weed* management, reduced chemical use and through increasing yields in subsequent cereal crops. Thefirst two
benefits help reduce the ‘evolution* of ‘herbicide* ‘resistance* . In addition, the incorporation of lucerne in a
rotation can significantly reduce recharge. These results DESCRIPTORS: ‘herbicide* ‘resistance*;
‘herbicide* ‘resistant*
‘weeds*; ...
...‘weed* control ‘weeds*. ..‘Mcdicago* sativa
D 12/K, 6/12 (Item 12 from filet 55)
DiALOG(R)Fi!e 55:(c) 2008 The Thomson Corporation. All rts. reserv.
0019917724 BIOSIS NO.: 200700577465
New annual and short-lived perennial pasture legumes for Australianagricuiture - 15 years of
revolution
‘2007*
ABSTRACT: Fifteen years ago subterranean clover (Trifolium subterraneum)and annual medics
(‘Medicago* spp.) dominated annual pasture legumesowings in southern Australia, while limited pasture
legume options
existed...
...glanduliferum), arrowleaf (Trifolium vesiculosum), eastern star(Trifolium dasyurttm) and crimson (Trifolium
incamatum) clovers andsphere (‘Medicago* sphaerocarpos), button (‘Medicago* orbicularis) andhybrid disc
(‘Medicago* tomaia x ‘Medicago* littoralis) medics have beencommercialised. Improved cuitivars have also
been developed ofsubterranean (T. subterraneum), balansa (Trifolium michelianum), rose(Trifolium hirtum),
Persian (Trifolium resupinatum) and purple (Trifoliumpurpurcum) clovers, burr (‘Medicago* polymorpha),
strand (M. littoraiis),snail (‘Medicago* scutellata) and barrel {‘Medicago* 'truncatula) medicsand yellow
serradeila (Ornithopus compressus). New tropical legumes for
pasture phases in subtropical...likely to increase due to the increasing cost
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of inorganic nitrogen, the need to combat *herbicide*-*resistant* crop
*weeds* and improved livestock prices. Mixtures ofth^e legumes allows for
more robust pastures buffered against...
i2/K,6/I3 (Item 13 from file: 50)
DlALOG(R)File 50:(c) 2008 CAB International. AH its. reserv.
0008415606 CAB Accession Number: 20033074295
□ Preharvest glyphosate in *aifaifa* for seed production: control of
O Canada thistle. Publication Year: 2003 Canada thistle ( Cirsium arvense ) is increasing in both frequency
and
density in Saskatchewan lucerne ( *Medicago* sativa ) seed fields. Application of preharvest glyphosate is an
effective means ofcontroilingCanada thistle...
...DESCRIPTORS: ^herbicide* ^resistance*; *weed* control...,..*wceds*...*Medicago* sativa
□ 12/K,6/14(Ilera 14 from file: 10)DIALOG(R)File I0:(c) format only 2008 Dialog. All rts. reserv,4818901
44029738 Holding Library: AGL
Role and value of including lucerne (*Medicago* saliva L.) phases in croprotations for the management of
*herbicide*-*resistant* Lolium rigidum inWeslern Australia
*2008* URL: http://dx.doi.Org/10.1016/j.cropro.2007.07.018Use of lucerne (*Medicago* sativa L.) pastures in
crop rotations has been
proposed as a method to enhance *weed* management options for growersfacing *herbicide* *resistance* in
Western Australia. An existing model foranalysing *herbicide* *resistance* in the important crop *weed*
annualryegrass (Lolium rigidum Gaud.) is consequently extended to include lucerne, used for grazing by.. .options
are analysed, including variouscombinations of lucerne, annual pastures, and crops. Lucerne providesadditional
*weed* management benefits across the rotation, but in the region studied these benefits are only sufficient...
n. 12/K,6/15 (Item 15 from file; 50)DfALOG(R)File 50:(c) 2008 CAB International. All rts.
reserv.0008983866 CAB Accession Number: 20063055062
□ Sensitivity of selected crops to isoxaflutole in soil and irrigation
D water. Publication Year: 2005 ... hectarage crops grown in Michigan, USA. 'Fhe crops evaluated were:
□ adzuki bean ( Vigna angularis ), lucerne ( ♦Mcdicago* sativa ), carrot (Daucus carota ), cucumber (
Cucumis sativus ), dry bean (navy and blackbeans; Phaseolus vulgaris. ..of the rates that resulted In injury were
substantially less than the rates used for *weed* control in maize.
Carryover from isoxaflutoleapplications in maize production may require plant back
restrictions DESCRIPTORS; *herbicide* *resistancc*;...*Medicago* sativa
C 12/K,6/17 (Item 17 from file; 55)DIALOG(R)File 55:(c) 2008 The Thomson Corporation. All rts.
reserv. 17533797 BIOSIS NO.: 200300491454 Tolerance of annual forage legumes to herbicides in Alberta.*2003*
...ABSTRACT: under irrigation. Results indicate that recommended rates of
either ethalfluralin or imazethapyr have potential for *wecd* control in
*aifa!fa*, berseem clover, balansa clover, fenugreek, pea, and vetches. *alfalfa*
(Leguminosae...*herbicide* *tolerance*; ..,.*weed* controlpotential
G 12/K,6/I8 (Item 18 from file: 50)
DIALOG(R)File 50:(c) 2008 CAB International. All rts. reserv.
□ 0008566544 CAB Accession Number: 20043017840 * Weed* control in lucerne and pastures
2004.Publication Year: 2003 Information to aid the planning of *weed* control in lucerne and
pastures in Australia, is presented under the following headings:
identification of...
...establishing pasture legumes; poison warnings on herbicide labels; usingherbicides successfully; using
herbicides in pastures; *weed* glossary;time interval needed between herbicide application and rainfall;
*wced*control in seedling lucerne > grass ‘weeds*; ‘weed* control in seedlingluceme broadleaf ‘weeds*;
‘weed* control in established lucerne stands(over one-year-old) -broadleaf ‘weeds*; ‘weed* control in
estabii-shedluceme stands (over one-year-old) -grass ‘weeds*; clover and medic pastures -grass ‘weeds* -for
G-53
1152
presowing, seedling and establishmenticlovw and medic pastures - broadleaf *weeds* - for presowing,
seedlingand established pastures; *weed* control in grass pastures only -broadleaf *weeds*; *herbicide*
♦resistance* management; direct drill andsurface sowing; perennial grass *weed* control; approximate retail
pricesof chemicals us«i on lucerne and pastures; herbicide volatility; winter
crop DESCRIPTORS: *herbicide* *resistance*; .*weed* control......*weeds*
...♦Medicago* saliva
12/K,6/19 (Item 19 from file: 50)DIALOG(R)File 50:(c) 2008 CAB International. Ail its. reserv.
0008415608 CAB Accession Number: 20033074293 *Weed* management in
irrigated fenugreek grown for forage in rotationwith other annual
crops.Publication Year: 2003 ... determine the tolerance of fenugreek (cv.
Amber) to several herbicides and their efficacy on various *weeds* ( Avena
fatua, Setariaviridis and Amaranthus rctroflcxus ) in 1997-99 in Alberta,
Canada.Potentially, fenugreek...effect of herbicides, seeding method, and 1 1
previous crops on fenugreek yield. Without herbicide application, *weeds*
contributed 37-86% to total dry matter production. When imazamox/imazethapyr, or combinations of
imazamoz/imazethapyr or imazethapyr with ethalfluralin was applied, *weed*contents were 5% of the
total dry matter and the herbicides did notreduce fenugreek yield compared to the hand-*weeded*
control. Total foragesamples with a low *weed* ccmtent had lower fibre content and higherprotein and
digestible dry matter content than forages with a high *weed*content. When imazamox/imazethapyr
was used for *weed* control, fenugreekyields and *weed* biomass were similar after direct seeding
and aftercultivation plus seeding. In addition, the effect...
... and the previous crop by seeding method interaction was not significantfor fenugreek yield and *weed*
biomass. Therefore, irrigated fenugreek canbe successfully grown in conservation tillage systems in rotation
widisevera! crops provided an effective herbicide is used for *weed* control.
...DESCRIPTORS: *herfaicide* *resistance*; *weed* control... *Medicago*sativa
D 12/K,6/20 (Item 20 from file: 55)
DIALOG(R)File 55i(c) 2008 The Thomson Corporation. All rts. reserv.
0020265062 BIOSIS NO.: 200800312001
Winter annual *weed* control with herbicides in *alfalfa*-orchardgrass
mixtures
•2008*
4.0 ABSTRACT: *Alfalfa*-orchardgrass hay is popular in the Western UnitedStates because of an expanding
horse-hay market. However, ‘weed* controlin mixed ♦alfalfa*-orchardgrass stands is problematic, as herbicides
mustbe safe for both species. Most growers rely solely on the competitlvenessof the crop for *weed* control,
which is often insufficient, especiallyin older stands. Field experiments were established in northemCalifomia to
determine the efficacy and crop safety of severalherbicides for winter annual *weed* control in established
*alfalfa* -orchardgrass. Metribuzin at 560 or 840 g/ha and hexazinone at 420 g/ha
applied...
...Paraquat at 560 g/ha applied shortly after crop green-up gave 50 to 82%*weed* control and caused significant
injury to orchardgrass, which wasstill noticeable at first cutting. ...ORGANISMS: *Medicago* saliva {*alfalfa*}
(Leguminosae)MlSCELLANEOUS TERMS: *herbicide* *toIerance*
1.5 Supplemental Searches
www.scirus.com
Terms:
alfalfa AND glyphosate (40 titles evaluated)
wwrv.scholar.google.com
Terms:
alfalfa AND glyphosate
G-54
1153
www.yahoo.com
Terms:
Alfalfa hay
Alfalfa sprouts
Organic alfalfa sprouts
Alfalfa seeds
Alfalfa glyphosate
Feral alfalfe
Wild alfalfa
Alfalfa state extension guidance
Perennial bluegrass
Quackgrass
Red homed poppy
Sprangletop weed
Tall waterhemp
White cockle weed
Butyrac
Butoxone
Benefm
Balan herbicide
Bromoxyni! herbicide
www.google.com
Terms:
alfalfa bloom
alfalfa crop rotation
alfalfa cultivation
alfalfa harvest
alfalfa quality definitions
alfalfa quality standards
alfalfa quality statistics
alfalfa sprouts
alfalfa weeds
dandelion off-taste milk
dairy cows
Eleucine indica
Burdock weed
Certified organic alfalfa seed
Common ragweed
Common ragweed weed problem
Gene flow simulation
GENESYS gene flow
Glyphosate
Glyphosate resistant weeds
Growing regions
Herbicide active ingredients
Clethodim herbicide
Prism herbicide
Select herbicide
Diuron herbicide
EPTC herbicide
Velpar herbicide
Raptor herbicide
Pursuit herbicide
Sencor herbicide
Solicam herbicide
Paraquat herbicide
Pronamide herbicide
Kerb herbicide
Poast herbicide
Terbacil herbicide
Sinbar herbicide
Trifluralin herbicide
Treflan/TR-1 0 herbicide
Horseweed
Lucerne Medicago
Meadow foxtail
Organic alfalfa acres
Organic alfalfa acres USDA
Organic alfalfa certified
Organic alfalfa seeds
Organic alfalfa statistics
Pigweed
Roundup ready label
Tansymustard
Tansyweed
Teuber gene flow alfalfa
Visual definition for alfalfa quality
Weed interference with rhyzobium
Weeds off tasting milk
Weeds taste in milk
Horseweed Italian ryegrass
Italian ryegrass weed
Palmer amaranth
Buckhom plantain
Goosegrass
G-5S
1154
Junglerice
Echinochloa j unglerice
Burning nettle
Utica uren
Erodiura filaree
Purslane weed
Large crabgrass in alfalfa
Bermudagrass weed alfalfa
Large crabgrass weed
Morning glory toxic livestock
Morning glory weed
Nutsedge
Nutsedge toxic livestock
alfalfa stand removal
volunteer alfalfa
alfalfa autotoxicity
G-56
1155
Appendix G-3. Weeds in Alfalfa
Table G-9. Weeds In Alfalfa
Common Name
Scientific Name
and Synonyms^®
Type
Season
East Central
North Central
Southeast
Winter Hardy
inter-mountain
Great Plains
z
a
Moderate Inter-
mountain
Southwest
Source
African musterd
Brassica
toumefortii
Asian mustard
wild turnip
Broadl
eaf
WA
X
Rogan
and
Fitzpatrick
2004
Barnyardgrass
Echinochloa
crus-galli,
cockspur grass,
Japanese millet
watergrass
cockspur
waterqrass
Grass
SA
X
X
X
X
X
X
Rogan
and
Fitzpatrick
2004
Bermudagrass
Cynodon spp.
Grass
P
X
X
X
Rogan
and
Fitzpatrick
2004
Blessed milk
thistle
Silybum
mahanum
blessed
milkthistle
milk thistle
spotted thistle
variegated
thistle
Dicot
A
X
Canevari
etai.,
2007
Blue mustard
Cdorispora
tenella,
beanpodded
mustard
chorispora
crossflower
purple mustard
tenella mustard
Broadl
eaf
WA
X
X
Rogan
and
Fitzpatrick
2004
Bluegrass
(annual)
Poa annua
walkgrass,
annual bluegrass
Grass
WA
X
X
X
Rogan
and
Fitzpatrick
2004
Bluegrass
(perennial)
Poca spp.
Perennial
bluegrass
Broad!
eaf
P
X
Rogan
and
Fitzpatrick
2004
Bristly
oxtongue*
Picris echioides
Dicot
WA
X
Canevari
etaL,
2007
Bromes
Bromus spp.
Grass
WA
X
Rogan
and
Fitzpatrick
2004
Buckhorn
plantain
Plantago
lanceolata
Broadl
eaf
P
X
X
Rogan
and
Source: http://plants,usda.gov/java/lnvasiveOne.
G-57
1156
Common Name
Scientific Name
and Synonyms^®
Type
Season
East Central
North Central
Southeast
Winter Hardy
Inter-mountain
Great Plains
Moderate Inter-
mountain
<U
1
3
O
—
Source
English plantain
buckhorn
plantain
lanceieaf
plantain
narrowleaf
plantain
ribgrass
ribwort
Piantago major
broadleaf
plantain
buckhorn
plantain
common plantain
rippieseed
plantain
Fitzpatrick
2004
Buffalobur
Solanum
rostratum
Colorado bur
Kansas thistle
Mexican thistle
Texas thistle
Buffalobur
nightshade
BroadI
eaf
SA
1
Rogan
and
Fitzpatrick
2004
Bulbous
bluegrass
Poa bulbosa
Grass
P
■
1
1
1
1
Rogan
and
Fitzpatrick
2004
Bull thistle
Cirsium
lanceolatum
BroadI
eaf
P
X
Rogan
and
Fitzpatrick
2004
Burououmber
Sicyos angulatus
Wall bur
cucumber
BroadI
eaf
SA
X
Rogan
and
Fitzpatrick
2004
Burning nettle
Urtica dioica
California nettle
slender nettle
stinging nettle
tall nettle
Broad!
eaf
A
X
Canevari
et al.,
2004;
Canevari
et a!.,
2006b
Bushy
wallflower
Ersimum
rapandum
Treacle mustard
BroadI
eaf
WA
X
Rogan
and
Fitzpatrick
2004
California
burclover
Medicago
polymorpha
burclo\«r
Dicot
WA-P
X
Canevari
etal.,
2007
Canada thistle
Cirsium arvense
Californian
thistle
creeping thistfe
BroadI
eaf
P
X
X
X
X
Rogan
and
Fitzpatrick
2004
G-5B
1157
Common Name
Scientific Name
and Synonyms^®
Type
Season
East Central
North Central
(0
«
o
(O
>..£
•o (0
a c
J i
i|
(A
c
'S
E
IS
£
o
PNW
Moderate inter-
mountain
Southwest
Source
field thistle
Cirsium thistle
■
m
■
■
■
■
Canarygrass
Phalaris
arundinacea
canary grass
reed canarygrass
Phalaris
canariensis
canary grass
Phalaris minor
canarygrass
littleseed
canarygrass
Grass
WA
1
Rogan
and
Fitzpatrick
2004
Carolina
geranium
Geranium
carolinianum
BroadI
eaf
WA
X
Rogan
and
Fitzpatrick
2004
Cheatgrass
Bromus tectorum
downy brome
early diess
military grass
thatch
bromeqrass
Grass
WA
X
X
X
X
X
X
X
Rogan
and
Fitzpatrick
2004
Cheeseweed
Malva neglecta
buttonweed
cheeseplant
little mallow
common mallow
BroadI
eaf
WA-P
1
1
1
1
Rogan
and
Fitzpatrick
2004
Chickwsed
(common)
Stellaria media
BroadI
eaf
WA
X
X
X
X
X
Rogan
and
Fitzpatrick
2004
Chicory
Cichorium
iniybus
blue sailors
chicory
coffeeweed
succory
Broad!
eaf
P
X
Rogan
and
Fitzpatrick
2004
Coastal
fiddleneck
Amsinckia
menziesii var.
intermedia
coast buckthorn
coast fiddieneck
common
fiddieneck
fiddieneck
BroadI
eaf
WA
X
Rogan
and
Fitzpatrick
2004
Gocklebur
(common)
Xanthium
strumarium
cockiebur
common
cockiebur
rough cockiebur
Broad!
eaf
SA
X
X
X
X
Rogan
and
Fitzpatrick
2004
Cornflower
Centaurea
cvanus
BroadI
eaf
WA
X
Rogan
and
G.59
1158
Common Name
Scientific Name
and Synonyms^^
Type
Season
East Central
North Central
Southeast
Winter Hardy
Inter-mountain
Great Plains
5
z
a
Moderate inter-
mountain
Southwest
Source
bachelor’s
button
garden
cornflower
Fitzpatrick
2Q04
Crabgrass
Digitaria
bicomis
Asian crabgrass
D^ftaria ciliaris
Henry's
crabgrass
fingergrass
kukaepua'a
saulangj
smooth
crabgrass
tropical
crabgrass
Digitaria
ischaemum
small crabgrass
smooth
crabgrass
Digitaria
Sanguinalis
hairy crabgrass
targe crabgrass
purple crabgrass
Grass
SA
X
X
X
X
Rogan
and
Fitzpatrid?
2004
Creeping
swinecress
Coronopus
didymus
(esser
swinecress
Coronopus
squamatus
creeping
wartcress
swinecress
Dicot
WA
X
Canevari
et al„
2007
Cupgrasses
Briochloa
gracilis
southwestern
cupgrass
tapertip
Cupgrass
Briochloa
contracta
prairie ojpgrass
Eriochfoa villosa
woolly cupgrass
Grass
SA
X
X
Rogan
and
Fitzpatrick
2004
Curiy dock
Rumex crispus
narrowleafdock
sour dock
yellow dock
Rumex
docJ<:
Broadi
eaf
P
X
X
X
X
Rogan
and
Fitzpatrick
2004
Cytleaf
Oenothera
Broadi
WA
X
Roaan
G-60
1159
Common Name
Scientific Name
and Synonyms^®
Type
1
East Central
c
o
O
£
t
O
2
Southeast
Winter Hardy
Inter-mountain
Great Plains
PNW
Moderate Inter-
mountain
Southwest
Source
eveningprimros
e
laciniata
cut-leaved
evening
primrose
eaf
1
1
and
Fitzpatrick
2004
Dallisgrass
Paspalum
dilatatum
dallies grass
herbs de mie!
herbe sirop
hiku nua
palpalum dilate
water grass
Grass
P
1
X
Canevari
et al.,
2007
Dandelion
(common)
Taraxacum
officinale
blowball
common
dandelion
faceclock
BroadI
eaf
P
1
X
X
X
X
Rogan
and
Fitzpatrick
2004
Dodder
Cuscuta
50 common
names for
species in the
genus
Broad!
eaf
SA
X
X
X
Rogan
and
Fitzpatrick
2004
Fail panicum
Panicum
dichotomifomm
western
witchgrass
Grass
SA
X
1
X
Rogan
and
Fitzpatrick
2004
Fescue
Festuca spp.
66 common
names for
species in the
genus
Grass
p
1
1
1
1
1
1
■
Fescue (tall)
Festuca
arundinacea
Festuca
pratensis
Alta fescue
coarse fescue
reed fescue
tall fescue
Grass
SA
X
Rogan
and
Fitzpatrick
2004
Field bindweed
Convolvulus
arvensis
creeping jenny
European
bindweed
morningglory
perennial
morningglory
smallflowered
morningglory
BroadI
eaf
P
X
X
Rogan
and
Fitzpatrick
2004
Field
pepperweed
Lepidium
camoestre
Dlcot
WA
X
X
Orioff et
ai.. 1997
Flixweed
Descurainia
Sophia
BroadI
eaf
WA
X
X
X
Rogan
and
G-61
1160
Common Name
Scientific Name
and Synonyms^®
Type
Season
1
c
0
1
ut
E
c
a>
o
£
t
o
z
»
S
£
3
O
tf)
Winter Hardy
inter-mountain
V)
c
m
a
IS
S
a
g
z
CL
Moderate Inter-
mountain
Southwest
Source
fllxweed
pinnate
tansvmustard
1
1
1
Fitzpatrick
2004
Foxtail (giant)
Setaria faberi
Chinese foxtail
Chinese millet
giant
bristlegrass
giant foxtail
nodding foxtail
Grass
SA
X
X
X
X
X
Rogan
and ■
Fitzpatrick
2004
Foxtail (green)
Setaria viridis
bottle grass
green
bristlegrass
green foxteil
green millet
pigeongrass
wild millet
Grass
SA
X
X
X
X
X
Rogan
and
Fitzpatrick
2004
Foxtail (yellow)
Setaria glauca
pear! millet
pigeongrass
wild millet
yellow
bristlegrass
yellow foxtail
Grass
SA
X
Rogan
and
Fitzpatrick
2004
Foxtail barley
Hordeum
jubatum
Grass
P
1
1
1
■
1
1
1
Rogan
and
Fitzpatrick
2004
Goosegrass
Eleusine indica
crowsfOot grass
Indian
goosegrass
manlenie ali'l
silver crabgrass
wiregrass
Grass
SA
X
X
Rogan
and
Fitzpatrick
2004
Groundsel
(common)
Senecio vulgaris
ragwort
oid-man-ln-the-
Sprinq
1
1
■
1
X
Canevari
eta!.,
2007
Hairy
nightshade
Solarium
sarrachoides
hairy nightshade
hoe nightshade
1
1
1
■
1
X
Rogan
and
Fitzpatrick
2004
Hare barley
Hordeum
leporinum
hare barley
leporinum
barley
wild barley
1
1
1
1
X
X
Orloff et
al.. 1997
Lamium
amplexicaule
deadnettle
Broadl
eaf
WA
X
■
1
Rogan
and
Fitzpatrick
2004
G-62
1161
Common Name
Scientific Name
and Synonyms^®
Type
Season
East Central
North Central
Southeast
Winter Hardy
Inter-mountain
Great Plains
PNW
Moderate Inter-
mountain
Southwest
Source
Hoary alyssum
Berteroa incana
hoary false
alyssum
hoary false
madwort
BroadI
eaf
P
X
Rogan
and
Fitzpatrick
2004
Hoary alyssum
Berteroa incana
hoary false
alyssum
hoary false
madwort
BroadI
eaf
SA
X
Rogan
and
Fitzpatrick
2004
Horse weed
Conyza
canadeniss
horseweed
fieabane
mares tail
fieabane
BroadI
eaf
SA/WA
X
Rogan
and
Fitzpatrick
2004
Japanese
brome
Bromus
japonicus
Japanese
bromegrass
Japanese ctiess
Grass
WA
X
Rogan
and
Fitzpatrick
2004
Jimsonweed
Datura
stramonium
Jamestown weed
mad apple
moonflower
stinkwort
thorn apple
BroadI
eaf
SA
X
X
Rogan
and
Fitzpatrick
2004
Johnsongrsss
Sorghum
halepense
aleppo
miiletgrass
herbe de Cuba
sorgho d’ Alep
sorgo de alepo
zacate johnson
Grass
P
X
X
Rogan
and
Fitzpatrick
2004
Jointed
goatgrass
Aegilops
cylindrical
jointgrass
Grass
P
X
Rogan
and
Fitzpatrick
2004
Junglerice
Echinochloa
colona
junglerice
waterarass
Grass
SA
X
Rogan
and
Fitzpatrick
2004
Kentucky
bluegrass
Poa prantensis
Grass
P
X
Rogan
and
Fitzpatrick
2004
Knawel
Sclerantus annus
German
knotgrass
BroadI
eaf
WA
X
Rogan
and
Fitzpatrick
2004
Knotweed
Polygonum
arenastrum
Broad!
eaf
SA
X
X
Rogan
and
G-63
1162
Common Name
Scientific Name
and Synonyms^®
Type
Season
East Central
2
c
s
JZ
■c
o
z
Southeast
>"i
p 5
X 3
"t o
3 E
l|
(A
C
’5
0.
fS
2
O
PNW
Moderate Inter*
mountain
Southwest
Source
common
knotweed
doorweed
matweed
ovalleaf
knotweed
prostrate
knotweed
Fitzpatrick
2004
Kochia
Kochia scoparia
Mexican
burningbush
Mexican
fireweed
fireweed
mock cypress
summer cypress
Broad!
eaf
SA
X
1
X
Rogan
and
Fitzpatrick
2004
Lambsquarters
(common)
Chenopodium
album
Lambsquarters
White qoosefoot
Broadl
eaf
SA
1
1
X
X
X
1
Rogan
and
Fitzpatrick
2004
Little barley
Hordeum
pusiHum
little wildbariey
Grass
WA
1
1
1
Rogan
and
Fitzpatrick
2004
London rocket
Sisymbrium irio
Grass
WA
1
Rogan
and
Fitzpatrick
2004
Meadow
foxtail*
Alopecurus
pratensis
Grass
1
■
X
1
Rogan
and
Fitzpatrick
2004
Mexican
sprangletop
Leptochloa
uninervia
Grass
1
■
X
Rogan
and
Fitzpatrick
2004
Mexican tea
Chenopodium
ambrosioides
Dicot
P
■
■
■
Miner's lettuce
Claytonia
peifoliata
Dicot
WA-P
■
■
Morningglory
Ipomoea spp.
Broadl
eaf
SA
1
■
Rogan
and
Fitzpatrick
2004
Muhly
Muhienbergia
frondosa
wirestern muhly
Muhienbergia
racemosa
green muhly
marsh muhly
Grass
P
X
Rogan
and
Fitzpatrick
2004
Musk thistle
Caruus nutans
Broad!
WA
X
Rogan
G-64
1163
Common Name
Scientific Name
and Synonyms^®
Type
Season
East Central
North Centra!
Southeast
Winter Hardy
Inter-mountain
Great Plains
PNW
Southwest
Source
Nodding
piumeless
thistle
chardon penche
nodding thistle
piumeless thistle
eaf
and
Fitzpatrick
2004
Mustards
Brassica spp.
BroadI
eaf
WA
X
X
Rogan
and
Fitzpatrick
2004
Mustards
Brassica spp.
BroadI
eaf
SA
X
1
Rogan
and
Fitzpatrick
2004
Nettleleaf
goosefoot
Chenopodium
murale
BroadI
eaf
SA
X
Rogan
and
Fitzpatrick
2004
Night-flowering
catchfly
Silene noctiflora
nightflowering
silene
sticky cockle
BroadI
eaf
WA
X
1
1
Rogan
and
Fitzpatrick
2004
Nightshade
Solanum
sairachoides
hairy nightshade
hoe nightshade
BroadI
eaf
SA
X
X
1
1
Rogan
and
Fitzpatrick
2004
Nightshade
(E. black)
Solanum
plychanthum
Eastern black
nightshade
black nightshade
BroadI
eaf
SA
X
X
Nutsedge
(yellow)
Cyperus
escufentus
yellow nutgrass
yellow nutsedge
Grass
P
X
H
Nutsedges
Cyperus
esculentus
yellow nutgrass
yellow nutsedge
Cyperus
rotundus
chaguan
humatag
cocograss
kili’o'opu
nutgrass
pakopako
purple nutsedge
Grass
P
Rogan
and
Fitzpatrick
2004
Palmer
amaranth
Amaranthus
palmeri
carelessweed
{type of pigweed)
BroadI
eaf
SA
X
1
1
Rogan
and
Fitzpatrick
2004
Pennycress
Thiaspi arvense
Frenchweed
Broad!
eaf
WA
X
X
X
G-65
1164
Common Name
Scientific Name
and Synonyms^®
Type
Season
2
c
«
o
w
(0
U1
1
c
U
x:
r
0
z
Southeast
Winter Hardy
Inter-mountain
Great Plains
z
a.
2 3
ffi o
S
Southwest
Source
Fanweed
field pennycress
pennycress
stinkweed
1
1
1
Fitzpatrick
2004
Pepperweeds
Lepidium
densifforum
common
pepperweed
greenflower
pepperweed
papperqrass
Broadl
eaf
WA
X
1
Rogan
and
Fitzpatrick
2004
Persian
speedwell
Veronica persica
birdeye
speedwell
winter
speedwell
Broadl
eaf
WA
1
1
1
Rogan
and
Fitzpabick
2004
Pigweed spp.
Amaranthus spp.
redroot pigweed
smooth pigweed
Powell amaranth
spiny amaranth
tumble pigweed
prostrate
pigweed
common
waterhemp
tail waterhemp
Palmer amaranth
Broadl
eaf
SA
X
X
X
X
X
X
X
X
Rogan
and
Fitzpatrick
2004
Plains
coreopsis
Coreopsis
tinciorla
golden tickseed
Broadl
eaf
WA
X
Rogan
and
Fitzpatrick
2004
Plantains
Plantago major
common
plantain
broadleaf
plantain
buckhorn
plantain
rippteseed
plantain
Broadl
eaf
P
X
X
Rogan
and
Fitzpatrick
2004
Poverty
sumpweed
Iva axillaris
Iva poverty weed
Lesser
marshelder
mouseear
povertyweed
poverty
sumpweed
poverty weed
smaiiflowered
marshelder
Broadl
eaf
P
X
Rogan
and
Fitzpatrick
2004
Prickiy lettuce
Lactuca serriola
China lettuce
Broadl
eaf
WA
X
X
X
Rogan
and
G-66
1165
Common Name
Scientific Name
and Synonyms^®
Type
1
East Central
North Central
Southeast
Winter Hardy
Inter-mountain
Great Plains
$
z
0.
Moderate Inter-
mountain
Southwest
Source
wild lettuce
Fitzpatrick
2004
Purslane
Portulaca
oleracea
akulikuli-kula
common
purslance
duckweed
parsley
pusley
wild portulaca
BroadI
eaf
SA
X
Rogan
and
Fitzpatrick
2004
Quac^grass
Elytrigia repens
couchgrass
quackgrass
quickgrass
quitch
scutch
twitch
Elymus repens
couchgrass
dog grass
Grass
P
X
X
1
1
X
X
Rogan
and
Fitzpatrick
2004
Rabbitsfoot
grass
Polypogon
monspelienisis
rabbitfoot
polypogon
rabbitfootqrass
Grass
SNA
1
1
1
1
X
Rogan
and
Fitzpatrick
2004
Ragweed
(common)
!
Ambrosia
artemisiifolia
Roman
wormwood
annual ragweed
common
ragweed
low ragweed
short ragweed
small ragweed
BroadI
eaf
SA
X
rx
X
nr
Rogan
and
Fitzpatrick
2004
Red horned
poppy*
Glausium
carniculatum
BroadI
eaf
WA
X
Rogan
and
Fitzpatrick
2004
Red
sprangletop*
Leptochloa
filiformis
Grass
SA
X
Rogan
and
Fitzpatrick
2004
Redstem filaree
Erodium
cicutarium
redstem stork’s
bill
aifilaree
filaree
stork's bill
Broad!
eaf
WA
X
Rogan
and
Fitzpatrick
2004
Resouegrass
Bromus
catharticus
rescue brome
Grass
WA
X
Rogan
and
Fitzpatrick
G-67
1166
Scientific Name
and Synonyms^®
Type
Season
1
c
o
O
w
(Q
tu
North Centra!
Southeast
Winter Hardy
Inter-mountain
ifi
c
ii
a.
£
O
Moderate Inter-
mountain
Southwest
Source
2004
Roughseed
buttercup*
Ranunculus
muricatus
Dicot
WA-P
1
X
Canevari
et al..
2007
Salsoia kali
tumbleweed
Salsoia iberica
prickly Russian
thistle
tumbleweed
tumblinq thistle
BroadI
eaf
"SA
X
X
X
X
Rogan
and
Fitzpatrick
2004
Lolium
muftiforum
Italian ryegrass
annual ryeqrass
Grass
1
1
■
1
X
Rogan
and
Fitzpatrick
2004
Ryegrass
(perennial)
Lolium perenne
Perennial
ryegrass
WA
1
■
X
Rogan
and
Fitzpatrick
2004
Sandbur
Cendirus
echinatus
burgrass
common
sandbur
field sandbur
konpeilo-gusa
se mbulabuia
vao tui tui
Grass
SA
1
X
Rogan
and
Fitzpatrick
2004
Shepardspurse
Capsella bursa-
pastoris
Shephardspurse
BroadI
eaf
WA
1
1
1
■
1
1
1
Rogan
and
Fitzpatrick
2004
Silversheath
knotweed*
Polygonum
argyrocoleon
Broad!
eaf
WA
1
1
■
1
1
1
I
Rogan
and
Fitzpatrick
2004
Smartweed
Polygonum
persicaria
lady's thumb
ladysthumb
smartweed
BroadI
eaf
SA
X
X
X
Rogan
and
Fitzpatrick
2004
Sowthistle
Sonchus spp.
(6 species)
BroadI
eaf
P
Rogan
and
Fitzpatrick
2004
Spiny
sowthistle
Sonchus asper
perennial
sowthistle
prickly
sowthistle
BroadI
eag
WA
X
Rogan
and
Fitzpatrick
2004
Sprangletops
Leptochloa
fascicufaris
bearded
sprangietop
Grass
SA
X
Rogan
and
Fitzpatrick
2004
G-68
1167
Common Name
Scientific Name
and Synonyms^^
Type
East Central
North Central
Southeast
Winter Hardy
Inter-mountain
Great Plains
PNW
Moderate Inter-
mountain
Southwest
Source
Also other
leptochloa
■
■
■
Squirreltair
Sitanion hystrix
Grass
P
1
1
1
Rogan
and
Fitzpatrick
2004
Stinkgrass
Eragrostis
cifianensis
candy grass
lovegrass
strongscented
loveqrass
Grass
SA
1
1
1
Rogan
and
Fitzpatrick
2004
Sunflower
(common)
Helianthus
annuus
annual
sunflower
common
sunflower
sunflower
wild sunflower
Broadi
eaf
SA
1
1
X
X
Rogan
and
Fitzpatrick
2004
Swamp
knotweed*
Polygonum
coccineum
Broadi
eaf
P
1
1
1
1
1
1
Tall waterhemp
Amaranthus
tuberoulatus
roughfrult
amaranth
tall waterhemp
Broadi
eaf
SA
X
X
Rogan
and
Fitzpatrick
2004
Tansy mustard
Descurainia
pinnata
green
tansymustard
tansvmustard
Broad!
eaf
1
1
1
1
1
1
1
Rogan
and
Fitzpatrick
2004
Toad rush
Juncus bufonius
Grass
WA
X
Canevari
et ai.,
2007
Tumble
mustard
Sisymbrium
altissimum
Jim hill mustard
tall mustard
tumble mustard
tumbleweed
mustard
Broadi
eaf
SA
X
X
X
Rogan
and
Fitzpatrick
2004
Velvetleaf
Abutilon
theophrasti
Indian mallow
butterprint
buttonweed
Broad!
eaf
SA
X
X
X
Rogan
and
Fitzpatrick
2004
Virginia
pepperweed
Lepidium
virginicum
Virginia
Pepperweed
Virginia
Broadi
eaf
WA
X
Rogan
and
Fitzpatrick
2004
G-69
1168
Common Name
Scientific Name
and Synonyms®*
Type
Season
-
(9
■£
0
o
to
n
UJ
North Central
Southeast
Winter Hardy
Inter-mountain
(0
c
is
K
"5
0
o
PNW 1
Moderate Inter-
mountain
Southwest
Source
peppercress
peppergrass
poorman’s
pepper
1
1
1
Volunteer
grains
Grass
WA-SA
X
X
X
Rogan
and
Fitzpatrick
2004
White cockle
Silene laiifolia
bladder campion
evening lychnis
white campion
Broad!
eaf
p
1
X
1
1
Rogan
and
Fitzpatrick
2004
VWId celery*
Apium
graveolens
Dicot
SA-P
X
Canevari
etat,
2007
Wild mustard
Brassica
arvensis
wild mustard
Brassica kaber
canola
charlock
mustard
kaber mustard
rapeseed
wild mustard
BroadI
eaf
SA
X
Rogan
and
Fitzpatrick
2004
Wild oats
Avena fatua
flaxgrass
oatgrass
wheat oats
1
1
1
■
1
X
1
X
Rrsgan
and
Fitzpatrick
2004
Wild radish
Raphanus
raphanistrum
BroadI
eaf
SA
1
1
1
■
1
1
1
1
Rogan
and
Fitzpatrick
2004
Windmillgrass
Chloris
verticillata
tumble windmill
grass
windmillgrass
Grass
P
1
1
1
1
1
1
1
Rogan
and
Fitzpatrick
2004
Witchgrass
Panicum
capiflare
panic^rass
ticklegrass
tumble panic
tumbleweed
grass
witches hair
Grass
SA
X
X
Rogan
and
Fitzpatrick
2004
Yellow rocket
Barbarea
vulgaris
garden yellow
rocket
winter cress
BroadI
eaf
P
X
X
Rogan
and
Fitzpatrick
2004
Yellow
Btarthistle
Caniaurea
solstifialis
Dicot
WA
X
X
Canevari
et al.,
2007
G-70
1169
Common Name
Scientific Name
and Synonyms^®
Type
S^son
East Central
North Central
Southeast
Winter Hardy
Inter^mountain
Great Plains
PNW
Moderate Inter-
mountain
Southwest
Source
Yellowflower
pepperweed
Lepidium
perfoliatum
clasping
pepperweed
Dicot
WA
X
X
Orloff et
a).. 1997
G-71
1170
G-72
1171
Appendix
F
Selected Comments to Draft Environmental Impact
Statement form Farmers Using Roundup Ready
Alfalfa
1172
APHIS-2007-0044-0320
Name: Daniel M. Luckwaldt
Address: Woodville, Wl
Submitter's Representative: Daniel Luckwaldt
Organization: Luckwaldt Agriculture Inc.
I am a dairy farmer who planted 100 acres of round-up ready alfalfa when it was available. I
seemed to work very good. Additionally it allowed me to plant my alfalfa in a no-till manner
(which leaves a smaller carbon footprint) and not worry about weeds. Seemed like it was the
best alfalfa I ever grew and was very easy/simple to manage.
APHIS-2007-0044-0516.1
Name: Gene Robben
Address: Dixon, CA
Organization: Robben Ranch
Robben Ranch is a large farming operation located near the town of Dixon, California. This
farming operation normally raises approximately 4,000 acres of alfalfa each year. The hay that
is produced on this ranch supplies several dairy and cattle operations in the southern part of the
Sacramento valley and the northern part of the San Joaquin vailey. Each fall this ranch tries to
replace older stands of alfalfa and replaces fields of alfalfa that are of poor quality. These fall
plantings can range from 800 to 1 ,000 acres. Fall planting of alfalfa has been the most
successful for Robben Ranch,
Three years ago, Robben Ranch planted 600 acres of Roundup Ready Alfalfa to see how this
new variety would produce and what type of quality it would have. This fall was the third year of
production for the new Roundup Ready variety. It was found from production records that the
Roundup Read Alfalfa equaled other varieties in production per acre, and had outstanding tests
in T.D.N. (total digestible nutrients). The other factor that was a concern was how resistant was
this alfalfa to Roundup Herbicide. After a few Roundup sprays, there was no apparent loss of
plants or stands over the three year period.
Many farmers know that with our standard varieties of alfalfa, w can spend form $50 - $100 per
acre annually for weed control. With Roundup Ready Alfalfa, expenses range from $1 0 - $30
per acre per year, which is a considerable savings over standard weed control. It was also
noticeable that in the Roundup Ready Alfalfa fields almost 100% weed control was obtained.
Robben Ranch hopes the government will release Roundup Ready Alfalfa seed for the 201 0
planting season. If so, this ranch will probable plant 1 ,000 acres of Roundup Ready Alfalfa this
coming fall season. I feel that the government regulators fully analyze the benefit that Roundup
Ready Alfalfa has for the American farmer and the environment they will release the seed for
sale.
From an environmental standpoint, one can only hope that the regulators will find that with the
release of Roundup Ready Alfalfa seed, several million pounds of current herbicides will be
greatly decrease or eliminated. Velpar, Sincor, Direx, Gramoxone, and Treflan TR-10 granules
1173
are just a few examples of these current herbicides being used. With the reduction of these
herbicides, our streams and waterways wili be much safer for our environment and us.
Document: APHIS-2007-0044-0813
Name: Kurt Robert Brink
Address: Richview, IL
Biotechnology-based breeding methods safety enhance and extend a crop’s yield potential, feed
value, adaptation, pest tolerance, environmental benefits, crop management and utilization
options, as other biotech crops have demonstrated. The Roundup Ready alfalfa system
provides dependable, cost-effective control of broadleaf and grassy weeds for the life of the
alfalfa stand.
I have had a plot of RR Alfalfa now for at least 3 years and it has proven to be a major plus for
our Dairy business in that we usually are able to maintain at least a RFV of 155 or better in each
of 5 cuttings/year. With the ability to control weed growth, it is one of, if not the best stand I have
among the 4 fields I do have in alfalfa.
It is imperative in these tough economic times that we are not deprived of whatever advantage
we can glean from the seed technology this variety provides.Roundup Ready alfalfa can lead to
more consistent, high-quality, weed-free hay, resulting in an increased supply of dairy-quality
hay. The forage produced from Roundup Ready alfalfa is comparable in composition, nutritional
value and safety to that produced from conventional alfalfa varieties, resulting in proven feed
safety. Dairy farmers can benefit from increased milk production per ton of feed and fewer
animals sickened by weeds in their feed.
I urge the USDA to consider biotechnology's long history of success and allow alfalfa growers to
join other American farmers in the benefits and new opportunities offered by biotechnology.
Kurt Brink
B&B Dairy Farms
Illinois
Document: APHIS-2007-0044-1094
Comment from John Maddox
Name: John Maddox
Address: Burrell, CA
I am a dairyman and alfalfa grower. 1 currently grow 2,400acs of conventional alfalfa and I would
like to have the ability to purchase and grow Roundup Ready alfalfa. I did grow 40acs of
Roundup Ready alfalfa when it was first avialable and was extremely satisfied with it.
The Roundup Ready system is extremely effective in controlling some of our toughest weeds
that we have in our hay fields especially nutgrass which is a big problem for us to control with
the currently avialable products that we have.
It eliminates summer grasses in the alfalfa which gives me greater flexibility in my winter spray
applications.
I firmly believe that if I am able to grow Roundup Ready alfalfa, I am going to be able to better
protect my workers because they will not have to be exposed to the more toxic herbicides that I
currently have to use to control my weeds. This is a huge issue for us in California especially
- 2 -
1174
with the many worker safety regulations that we put in place to provide a safe work environment
for our employees.
For our dairy, it is of high importance to us to provide the highest quality feed that we can find
for our milk cows so that we can maximize their production of high quality milk and butterfat. By
growing Roundup Ready alfalfa, I found that my alfalfa was higher in quality and tonnage per
acre due to the fact that it was much cleaner than my conventional fields. My 40acres of
Roundup Ready alfalfa was the first field that ever produced 10 tons/acre for the year. We have
never been able to do that with our conventional varities. This higher production per acre allows
me to use less alfalfa acres to provide me the same amount of hay that I currently get from my
conventional fields. This frees up some ground for me to rotate into other crops.
Third, because herbicide resistance is a heritable trait, it takes multiple growing seasons for
herbicide tolerant weeds to emerge and become the predominant biotype in a specific area
(Cole, 2010a, p, 4). Researchers have concluded that even if growers completely relied on only
one herbicide, it is likely to take at least five years for an herbicide-resistant weed population to
develop (Kniss, 2010a, p4; Beckie 2006, Neve, 2008; Werth et al., 2008). This is a reason why
crop monitoring and follow up by University and industry weed scientists in cases of suspected
resistance are important parts of all herbicide resistance stewardship programs.
The practice of repeated, in-season mowing combined with alfalfa’s perennial
nature reduce the likelihood of glyphosate-resistant weed development in >99 percent
of the crop's acreage. The ability for alfalfa to fix nitrogen encourages the decision to
follow alfalfa in the rotation with a crop that requires additional nitrogen, such as the
annual grasses of corn and various cereal crops. These subsequently rotated crops can
tolerate a spectrum of herbicides substantially different from the herbicides used in
alfalfa. This encourages rotation of crops and herbicides, both of which are highly
recommended for reducing the probability of developing herbicide resistant weeds
(Orloff et al., 2009; USDA APHIS, 2009, P. 109).
- 3 -
1175
Appendix
G
Chart of Anticipated Adoption of RRA Under Partial
Deregulation, Prepared by Monsanto/FGI (August 4,
2010)
1177
Appendix
H
Roundup Ready Alfalfa Satisfaction Study
(Study #091 113 1108)
Prepared by Market Probe, Inc., December 2008
1178
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1179
1180
Appendix
Putnam, D. and D. Undersander. 2009.
Understanding Roundup Ready Alfalfa (Full
Version). Originally Posted on the Hay and Forage
Grower Magazine Web Site at;
http://hayandforage.com/understanding_roundup_re
ady_alfalfa_revised.pdf (January 1, 2009)
1181
Appendix I
Putnam and Undersander (2009)
Pages 1-3 of Appendix I:
Magazine Version
Holin, F. 2009. Roundup Ready Reality? (Partial version of Putnam and Undersander.
2009. Available at:
http://iicense. icopyright.net/user/viewF reeUse.act?fuid=OTQxOTg4Mg%3D%3D
(August 3, 2010)
Pages 4-6 of Appendix I:
Full Version
Putnam, D. and D. Undersander. 2009. Understanding Roundup Ready Alfalfa (full
version). Originally posted on the Hay and Forage Grower Magazine web site at:
http://hayandforage.com/understanding_roundup_ready_alfalfa_revised.pdf (January 1 ,
2009).
1182
Hay & Forage Grower: Roundup Ready Reality?
Page 1 of 3
Finae.
January 1, 2009
Roundup Ready Reality?
by Fae Holin
Is emotion trumping science in debates over the release of Roundup Ready alfaifa? Two forage specialists
think so. They’ve put together a paper debunking what they call misinformation presented at annual
conferences around the country.
"We want to dispel some of those myths," says Dan Undersander, University of Wisconsin extension forage
specialist. Undersander and his colleague at University of California-Davis, Dan Putnam, offer "a scientific
perspective" for alfalfa growers and industry representatives as they evaiuate Roundup Ready (RR) alfaifa.
RR alfalfa, legalized in 2005. lost that designation with a court injunction just about two years later. A USDA
environmental impact statement, required by the court, Is nearing completion with a public comment period
expected in the next month. A decision on whether the transgenic crop should again be made available to
growers is expected to follow several months later.
In the meantime, the forage specialists want to make sure the alfalfa industry is well-informed. They’ve
offered Hay & Forage Grower a preview of their paper, which will be published in its entirety at
hayandforage.com [http://hayandforage.com/understandlng_roundup_ready_alfalfa_revised.pdf].
Here's a synopsis of their concerns;
1. Once you release this gene, you can't call it back.
Undersander and Putnam respond that the gene is already out - more than 300,000 acres of RR alfalfa have
been planted for hay and a limited amount planted for seed. The real question, they write, is whether
growers can continue to plant conventional seed. Their answer: Only non-RR alfalfa is being planted now
and. if concerned about contamination, growers can test it for the RR gene.
2. Won't contamination from neighboring fields result in all seed being Roundup Ready eventually?
"No," they emphasize, citing that seed production methods and isolation distances will keep the presence of
the gene "at a very low level for seed" and that "non-genetically enhanced (non-GE) seed will always be
available."
3. Won’t my neighbor's RR hayfields contaminate my non-GE alfalfa hay production through pollen
and gene flow?
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1183
Hay & Forage Grower: Roundup Ready Reality?
Page 2 of 3
"No,” they write. "There is an extremely low probability of gene flow among hayfields. For this to happen,
fields must flower at the same time, pollinators must be present to move pollen (it does not blow in wind),
plants must remain In fields four to six weeks after flowering for viable seed production, seed must shatter to
fell to the ground and establish on the soil surface, seedlings must overcome autotoxicity to germinate and
seedlings must overcome competition from existing plants."
Pollen can only be carried by pollinators such as bees, and honey bees don't like to pollinate alfalfa, they
add. The specialists discuss the difficulties of the seed gemiinaling, concluding that if growers take care to
plant non-RR seed, it's unlikely their hayfields will become contaminated with the gene.
4. Will the seed companies be able to keep seed from being contaminated?
"Yes. The greatest real potential for pollen flow and contamination Is during seed production," Undersander
and Putnam write. They cite ways the seed industry has agreed to keep track of transgenic seed and
reasons why it's in the companies’ best interests to do so.
5. Won't feral alfalfa be a source of contamination?
"Feral (wild growing) alfalfa can act as a bridge for moving genes from one seed field to another, and thus
should be controlled to prevent gene flow in any area where seed production occurs, whether GE or not.
Feral alfalfa is primarily an issue in portions of Western states because little occurs elsewhere," write the
forage specialists. They discuss reasons why feral seed would have low production and suggest that
removing plants from ditches and roads is a good idea to prevent gene flow.
6. Won't hard seed be a source of contamination?
"Hard seed of alfalfa generally does not persist for more than one year in moist soils, much less after years
of hay production," they respond, "To guard against hard seed carryover, seed growers take steps to
eliminate residua! alfalfa volunteers prior to planting. State seed certification standards already require that
the alfalfa seed field's history include a two-year exclusion period before planting alfalfa for seed."
7. Much of the hay in my area Is cut late with mature seed - we have good farmers but weather and
equipment problems force late cuttings.
"This occasionally happens," Putnam and Undersander answer. "However, plants must remain in a field for
four to six weeks after pollination of flowers for viable seed to form and longer for seed to shatter." Delayed
cutting will cause little to no seed production in hayfields, and hay harvest should remove seed.
The last seven concerns have to do with 8) growing organic hay; 9) export markets; 10) whether seed
companies bias the research on RR alfalfa; 11) possible effects it may have on insects, animals or the
environment; 12) whether farmers can or will follow stewardship protocols; 13) weed resistance to Roundup
and 14) whether the risks of RR alfalfa outweigh the rewards.
"There is also a risk with NOT moving ahead with a technology," Under-sander and Putnam contend. RR
alfalfa will control tough weeds, they write. "Further, if this breeding methodology is permanently banned, it
would mean fewer genetic advancements for alfalfa in the future.
"it is important that alfalfa growers and the industry understand how to use this important new genetic tool,
while at the same time, protecting those farmers who don't wish to adopt it."
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8/3/2010
1184
Hay & Forage Grower; Roundup Ready Reality?
Page 3 of 3
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8/3/2010
1185
Authors: Dan Putnam. University of California, and Dan Undersander, Univeristy of Wisconsin
January 2009
Understanding Roundup Ready Alfalfa
A number of concerns have been raised about the release of Roundup Ready (RR| alfalfa, the first biotech trait in
alfalfa. Many of these concerns have been fueled by misinformation. In this article, we provide a scientific
perspective on these concerns that we hope will inform.
Concern 1. Once you release this gene - you can’t call it back.
Over 300,000 acres of RR alfalfa have been planted for hay over the past 2 to 3 years, with a limited amount
planted for seed. The real question is whether you can continue to plant conventional alfalfa seed and the answer
is a resounding 'yes’ - all of the seed currently for sale is 'conventional' - and you only need to test it {or ask the
seed company to test it) with inexpensive test strips to make sure it does not contain the gene if you don't want it.
Conventional alfalfa seed will continue to be available after Roundup Ready alfalfa is released.
Concern 2. Won't contamination from neighboring fields result in all seed being Roundup Ready, eventually?
No. Seed production methods and isolation distances currently recommended by seed companies should keep
adventitious presence at a very low level for seed. A gene will increase in a population only if the new gene gives
the plant an advantage over other plants and the conditions creating the advantage are consistently present.
Conversely, if plants are grown in an environment where the gene provides no advantage, the gene is more likely
to remain in the population at very low levels or to be lost from the population. The formulas for computing these
changes in gene frequency can be found in most books on population or quantitative genetics, such as Falconer
and MacKay, 1996, introduction to Quantitative Genetics, Longman Press. Thus non-GE seed will always be
available.
Concern 3. Won’t my neighbor’s Roundup Ready hay fields contaminate my conventional or organic alfalfa hay
production through pollen and gene flow?
No. There is almost zero probability of gene flow among hay fields. For this to happen all the following must occur :
• fields must flower at same time.
• pollinators must be present to move pollen (it does not blow in wind).
• plants must remain in field 4 to 6 weeks after flowering for viable seed production.
• seed must shatter, to fall to ground and establish on soil surface.
• seedlings must to overcome autotoxicity to germinate.
• seedlings must to overcome competition from existing plants.
Pollen moves among alfalfa plants only when carried by pollinators such as bees, and honey bees do not like to
pollinate alfalfa. Alfalfa seed takes many weeks after flowering to mature sufficiently to germinate and longer to
shatter and fall onto the ground. Alfalfa seed does not readily spread. Alfalfa does not germinate well on the soil
surface. Germination will be further reduced by alfalfa autotoxicity from existing planting in the hay field (this is
why interseeding alfalfa to thicken a stand generally fails). Germinating seeds must compete with established
plants for water, nutrients and sunlight. Data has shown that interseeded plants generally die during the first
growing season. Thus, if a grower takes care to plant conventional seed, it Is very unlikely that the Roundup Ready
gene will move to their hay fields. (See Gene Flow in Alfalfa; Biology, Mitigation, and Potential impact on
Production, Special Publication of the Council for Agricultural Science and Technology (CAST) at httD://www. cast-
science. orR/displavProductDetails.asD?idProduct=157 )
Concern 4. Will the seed companies be able to keep seed from being contaminated?
Yes, the greatest real potential for pollen flow and contamination is during seed production. The seed industry has
agreed on a field tagging technique in areas where RR alfalfa seed will be grown so neighbors and other seed
companies will know where RR seed is being produced. The bulk of non-GE alfalfa seed is produced for export by
seed production companies and it is in their own best interest to control seed production to continue to produce
the 30% or more of total production as non-biotech for export. This large volume of export seed production is
much more significant economically than the less than 1% of total seed market for organic seed production.
However, concerns and methodology for exported seed will allow organic seed production indefinitely, making
non-biotech seed available to growers.
Concern 5. Won't feral alfalfa be a source of contamination?
1186
Authors: Dan Putnam, University of California, arwi Dan Undersander. Univeristy of Wsconsin
January 2009
Feral (wild growing) alfalfa can act as a bridge for moving genes from one seed field to another, and thus should be
controlled to prevent gene flow in any area where seed production occurs, whether biotech or not. Feral alfalfa is
primarily an issue in portions of Western states because little occurs elsewhere. Feral alfalfa will have low seed
production for the reasons described in #3 plus damage from lygus bug and infection from seed-borne fungi when
seed develops under damp conditions. Seed from any feral plants will contribute to new plants only over a very
short term, but removing feral alfalfa from ditches and roads is a good idea for organic and export growers to
prevent gene flow. If feral alfalfa is deemed a problem in a specific area, then it must be controlled as off types of
alfalfa and other problem weeds are currently controlled using cultural and other herbicide methods.
Concern 6, Won't hard seed be a source of contamination?
Hard seed of alfalfa generally does not persist for more than one year in moist soils (Albrecht et al. 2008 Forage
and Grazingiands), much less after years of hay production. To guard against hard seed carryover, seed growers
take steps to eliminate residual alfalfa volunteers prior to planting. State Seed Certification Standards already
require that the alfalfa seed field's history include a 2-year exclusion period before planting alfalfa for seed.
Concern 7. Much of hay in my area is cut late with mature seed - we have good farmers but weather, equipment
problems force late cuttings.
Although late cuttings occasionally happen viable seed development is unlikely. However, plants must remain in
field for 4 to 6 weeks after pollination of flowers for viable seed to form and longer for seed to shatter. Delaying
harvest 1 to 2 weeks due to weather, equipment problems and other issues will cause little to no seed production
in hay fields (see item #3). Furthermore, hay harvest should remove this small amount of seed so that it doesn't
become a problem.
Concern 8, Organic producers may have difficulty growing organic hay.
No - there is no reason that organic growers can't continue to successfully grow organic hay. In fact the presence
of Roundup Ready alfalfa hay in the marketplace may increase the value of organic hay, for buyers who are
sensitive to biotech traits. Current demand for organic hay has been high, in spite of the introduction of Roundup
Ready alfalfa. There are a number of growers who currently grow both Roundup Ready alfalfa and organic hay on
the same farm without difficulty, Organic growers should 1) select conventional seed that is tested for the trait if
their customers have set a standard of no adventitious presence, 2) take simple steps to protect their crop from
gene flow and 3) identify hay lots after harvest. Feedstuffs can be tested to ensure low biotech levels desired for
these markets. Organic growers currently are certified to show that their crops are not grown with pesticides or
non-organic fertilizers, and similar steps can be taken to show that they do not use genetically engineered crops.
Concern 9. Couldn't we lose our entire export market?
No. White export growers and buyers are sensitive to the presence of biotech traits in crops, they have developed
market-assurance methods to demonstrate that they are marketing non-biotech alfalfa hay, including testing to
assure buyers of the non-biotech status of hay. Japan, Taiwan, and Korea (main U.S. hay market) already use
biotech corn and soybeans and have accepted some RR alfalfa hay. The European Union has approved use of
certain biotech varieties of corn and soybeans in food and feedstuffs. While significant in some growing regions in
the US, exported hay represents less than 1 % of total alfalfa hay production.
Concern 10. Isn't the research biased by the seed companies that stand to gain most?
RR technology at has been evaluated at many universities. This research Is independent of the concerned
commercial parties. The goat is to independently test a technology for its viability and environmental safety for
farmers and for the general public. These studies must be well-designed, accurate and can only be published only
after review by anonymous individuals from other institutions selected for impartiality.
Concern 11. Won't the Roundup Ready gene in alfalfa have a negative effect on insects, diseases, other biota, or
the environment?
There is currently no evidence that this gene would have a negative effect on insects or animals, or the
environment. The Roundup Ready gene has been thoroughly tested as other crops were released (corn, soybeans,
cotton) and no impact on any other biota has been found. No toxicology issues have been identified with roundup
ready alfalfa fed to animals. In the past ten years, billions of tons of corn, soybeans, cotton and alfalfa have been
1187
Authors; Dan Putnam, University of California, and Dan Undersander, Univeristy of Wisconsin
January 2009
produced with this gene, and there has been no documented harm to animals, humans or wildlife. In fact the use
of Roundup would replace some more toxic pesticides that have been used and found in ground water (e.g.
Vetpar).
Concern 12. Farmers can't/won't follow stewardship protocols.
All technology requires stewardship by farmers (e.g. fertilizer use, pesticide use, irrigation). Farmers must be
educated about stewardship needed and required to use appropriate stewardship for any technology. The
possibility of gene flow is no different in scope than controlling pesticide drift, fertilizer contamination from
conventional farms, or for that matter, the influence of weeds from organic fields that may contaminate
neighbor's fields. Good farmers know how to do this.
Concern 13. Won't there be weed resistance to Roundup from use of RR alfalfa?
Weed resistance and weed shifts are issues with all herbicides. New management programs have always resulted
in shifts in weed pressure. For example, no-till crop production has resulted in different weed problems than when
crops were grown with conventional tillage. Resistance to glyphosate has occurred in row crop situations,
inclusion of alfalfa might actually slow increase of resistant populations of weeds because an additional
mechanical control {frequent hay harvest) Is being added to the weed management program. Techniques are
readily available to avoid weed shifts or weed resistance using the Roundup Ready system as detailed in a recent
article {Orloff et a!., 2008).
Concern 14. Risk far outweighs reward/Do we really need this? Are we willing to take this kind of gamble?
There is also a risk with NOT moving ahead with a technology that has dear potential benefits to farmers and the
environment. Currently, many animals are killed or hurt each year by weedy alfalfa fields - something that
Roundup Ready technology could help address. Also, some of the conventional herbicides have been found in well
water - something not true with glyphosate. Additionally, Roundup Ready alfalfa would allow farmers to control
tough weeds for which no other good method of control exists (e.g. winter annuals such as chickweed, wild garlic,
wild onion, perennials such as dandelion, difficult weeds such as nutsedge and dodder, and poisonous weeds such
as groundsel).
Further, If this breeding methodology is permanently banned, it would mean fewer genetic advancements for
alfalfa in the future. Some traits currently under development, such as a low lignin gene that could mean higher
forage yield and fewer cuttings for farmers, a leaf retention gene to retain leaves through harvesting process,
genes which confer pest resistance, or genes to increase bypass protein, would never be available to farmers. It is
not reasonable or fair to farmers to restrict a technology from use in alfalfa that is available in other crops.
A series of articles on biotech alfalfa and coexistence of GE and conventional alfalfa seed and hay production is
available at http://www.alfaifa.org/CSCoexistenceDocs.html and http://alfalfa.ucdavis.edu/-fproducing/biotech.aspx .
In summary, it is essential that alfalfa growers and the industry understand how to use this important new
genetic tool, while at the same time, protecting those farmers who don't wish to adapt it. Research has proceeded
with great deliberation in the development of Roundup Ready alfalfa and shown it to be a good tool that will
benefit many farmers. Like every other tool, it must be used with care and appropriate stewardship. It is
important for the industry to manage for coexistence of biotech-adapting and non biotech-adapting farmers, since
other important biotech traits are being developed which might be much greater benefit to farmers and society.
Dr. Dan Putnam, University of California
Dr. Dan Undersander, University of Wisconsin
1188
Appendix
J
Roundup Ready Alfalfa Harvesting Study, Study
#3482 (Originally Submitted as Appendix 6 to
Monsanto/FGI Comments to Draft EIS)
1189
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Appendix
K
Fitzpatrick, S. and G. Lowry. 2010. Alfalfa Seed
Industry Innovations Enabling Coexistence.
Proceedings of the 42"*^ North American Alfalfa
Improvement Conference, Boise, Idaho, July 28-30,
2010
1195
Alfalfa Seed Industry Innovations Enabling Coexistence
S. Fitzpatrick and G. Lowry
The alfalfa seed industiy has recently implemented two complementary programs that together
enable mutual coexistence between conventional and Roundup Ready alfalfa (RRA) seed
producers. The 2010 Alfalfa Seed Stewardship Program (ASSP-2010) is an identity preserved
process-based certificate offered by state seed certification agencies. It was developed by the
Association of Official Seed Certifying Agencies (AOSCA) designed to serve GE-trait sensitive
conventional seed producers (e.g,, export). In 2008, the Best Management Practices for RRA
Seed Production (BMPs) was adopted by the National Alfalfa & Foage Alliance. These BMPs
are required coexistence protocols that apply only to RRA seed-producing companies (i.e., no
new requirements are imposed upon external conventional seedproducers). These market-driven,
science-based programs were developed with the involvement of alfalfa industry stakeholders
over a 5-year period (2005 to 2010) using all available market and gene flow data. An array of
stakeholders were involved that represented diverse<'segments of the alfalfa seed and hay
industries: scientists, seed certifiers, breeders, etSporters, marketers, producers, growers and
organic. These new programs are independent frorniand more stringent than .AOSCA or OECD
Seed Certification Programs. Forage Genetics and Pt<meer'Hi-Bred International (the only
companies producing RRA seed), have collectively repdrted to inspectors that in 2009 greater
than 97% of their conventional seed lots were produced wilhouttdctection of the RRA trait (>500
lots tested with <0.00% RRA). If detected, :AP' was less than 0.5%T;overall lot average <0.1%).
Seed Program
Market
No Program USDA National
(e.g., Organic
common Program
seed) ■’^''Gertification
US, domestic ^ f
cmivendonal Orgwicforage
(baseline)
Certified Seed
U.S domestic
conventional &
RRA seed
' Roundup Ready
Alfalfa (RRA) Seed
U.S. domestic RRA
seed
AOSCA AASP-
2010 Identity
Preserved,
Certified Seed
U.S. conventional
seed for export
Purit> Standard
or Objective
Spatial isolation
front other seed
field
No ofRcial purity
, ' , ^"standards;
c ^ process-based
lequtrements
<1% off types
<0.5%GE in
neighboring
conventional seed
production
Non~detect GE
' Customized farm
i?5vp!an; not uniform
n/a .
mitigation
standard
165ft
900 ft to 3 mi at RRA
seed field planting
(pollinator specific)
>5 miles
Program conforms
to:
, USDA-AMS
,o/a f National Organic
N Program
Federal Seed Act
Industiy consensus
and RRA seed co.
contracts
AOSCA
1. P. Program
Program
monitored by:
: Local Organic
•ti/a Certifying
Agency
State Seed
Certifying Agency
State Seed
Certifying Agency
State Seed
Certifying Agency
Program
obligations fulfilled
by:
Organic,
n/a conventional
grower
Seed company and
seed grower
RRA seed company
and seed grower
GE-sensitive seed
company and
conventional seed
grower
Growers using the
program:
Conventional Conventional
only only
Both, conventional *i, r.r.A i
Jr. TV* All RRA, only
and RRA
Conventional only
Forage Genetics International, West Salem, WI
**Idaho Crop Improvement Association, Meridian, Idaho
1196
RECEIVED
By APHIS BRS Document Control Officer at 3:19 pm, Aug 09, 2010
MONSANTO
My 29, 2010
Michael C. Gregoire
Deputy Administrator
Bioteclmology Regulatory Services
Animal and Plant Health Inspection Service
U.S. Department of Agriculture
4700 River Road. Unit 98
Riverdale,MD 20737
Re; Petition 03-323-0 Id for Non-Reeulated Status. Roundup Ready® Suearbeet-l :
Event H7 Supplemental Reouest for “Partial Deregulation" or Similar Administrative Action
Dear Mr. Gregoire:
Monsanto Company (“Monsanto”) and KWS SAAT AO (“KWS”) jointly filed the petition
for nonregulated status for Roundup Ready sugarbeet' Event H7-1 (“RRSB”) which USDA’s
Animal and Plant Health Inspection Service (“APHIS”) previously granted in March 2005. In light
of recent developments in litigation, and with the support of thousands of sugarbeet growers
nationwide and all sugarbeet cooperatives, processors and seed-producers, Monsanto and KWS
jointly submit this supplemental request for “partial deregulation” or similar administrative action,
as set forth below.
Background
On March 17, 2005, APHIS granted nonregulated status for RRSB following nearly 100
field trials, a 60-day comment period and issuance of an environmental assessment (“EA”)
concluding that the event presented “no significant impact on the human enviromnent,” In the
years thereafter, a majority of our nation’s sugarbeet groweis adopted RRSB; wide-scale RRSB
seed production began by 2006, and tlte multi-year process to develop appropriate RRSB varieties
for growers in 10 states resulted in RRSB cultivation on roughly 95% of all U.S. sugarbeet
acreage. The Government of Canada likewise approved RRSB for cultivation and human and
animal consumption, and the European Union, Japan, Mexico, South Korea, Australia, New
Zealand, China, Colombia, Russia, Singapore, and the Philippines each approved importation of
sugar and other products derived from RRSB. Today, RRSB is processed into roughly half of our
nation’s domestic sugar supply.
® Roundup and Roundup Ready are registered trademarks of Monsanto Technology LLC.
I
1197
On September 2 1 , 2009, however, a Federal district court in San Francisco ruled that
APHIS’S 2005 EA for RRSB did not adequately evaluate potential cross-pollination from RRSB
seed crops to other crops. The court held that APFIIS “did not consider the effects of gene
transmission on conventional faiTnera and consumers of sugar beet seed or of gene transmission to
the related crops of red table beets and Swiss chard” and noted that such “seed production takes
place primarily in the Willamette Valley of Oregon.” Center for Food Safety v. Vilsack ("CFS"),
No. 08-484, 2009 WL 3047227, *5, 13-14 (N.D. Cal. Sept. 21, 2009). That litigation is currently
in the remedies phase, where the plaintiffs in the suit have sought a j udicial order halting further
planting of RRSB. Representatives of the thousands of sugarbeet gi'owcrs nationwide along with
sugarbeel cooperatives and processors, the seed companies who produce RRSB seed and Monsanto
have intervened in this suit to urge the court not to halt ongoing or future RRSB cultivation.
Specifically, the district court has been presented with evidence that an order immediately halting
RRSB planting would have profound consequences for the nation’s growers and many other
parties, including that:
• Fanning communities could suffer losses e,Kceeding $2 billion;
• Approximately eight sugarbeet processing facilities would close (likely forever);
• More than 5,500 jobs would be lost; and
• The resulting domestic sugar shortages would, under USDA estimates, cost
consumers $2,972 billion in 201 1 alone.
Recently, the Supreme Court has addressed deregulation of a similar crop. Roundup Ready
alfalfa, and provided significant guidance applicable here. See Monsanto Co, v. Geertson Seed
Farms, No. 09-475, -- S. Ct. ~, 2010 WL 2471057 (2010). The Supreme Court concluded that,
even where a court has held that APHIS has violated NEM with respect to a complete
deregulation determination,“[a]t that point, it was for the agency [APHIS] to decide whether and to
what extent it would pursue aparha/ deregulation.” Id. al*13. “If... a limited and temporary
deregulation satisfied applicable statutory and regulatory requirements, it could proceed with such
a deregulation even if it had not yet finished the onerous EIS required for complete deregulation.”
Id. The Supreme Court went on to identify a combination of geographic restrictions, isolation
distances, and enforcement measures tliat could serve to eliminate any risk of “injury at all, much
less irreparable injury.” Id. at *15,
In light of this recent Supreme Court ruling, the Goveiranent has represented to the district
court in San Francisco that, in the event the court vacates the existing RRSB deregulation, APHIS
has authority to deregulate “in part” to “allow planting to occur under the conditions proposed by
APHIS while the EIS is being prepared.” As APHIS explained, it could take such action if
“[ijnteivenors submitted a new petition or a supplement or amendment to a previous petition for a
determination of nonregulated status of RRSB.” Federal Defs.’ Supp. Br. on Penn. Inj. Relief at 1,
13-14. The Government further explained that the Supreme Court’s decision in “Monsanto clearly
indicates that tliis type of interim administrative action would be permissible.” Id. at 14; see also
Monsanto, 20 1 0 Wl, 247 1 057, at * 1 5 (citing “representation from the Solicitor General” that
APHIS has authority to do so). Separately, based on its expert analyses and review', APHIS has
proposed to the district court a series of carefully tailored interim measures designed to address any
potential risk of harm to other parties from continued cultivation of RRSB during the time period
necessary for APHIS to reevaluate the RRSB petition for nonregulated status. Although there has
been no record of any harm to any grower of any other crops in the multiple years of wide-scale
RRSB production without these restrictions in place, tlie interveners in this litigation have agreed
that these additional interim requirements will reduce further an already negligible potential for
any impact to other parlies from RRSB.
2
1198
Request for Interim Measures
With the support of each of the sugarbeet growers, cooperatives, processor and seed
companies who have intervened in the pending RRSB iitigation, Monsanto and KWS now jointly
request that, in the event the court in the RRSB litigation vacates the existing deregulation
determination, APHIS grant nonregulated status in part or take similar administrative action to
authorize continued cultivation of 3ie RRSB crop subject to the carefully tailored interim measures
proposed by APHIS. Petitioners believe this request is appropriate in this context because;
(1) As APHIS explained its recent Supplemental Brief, the U.S. Supreme Court has
clarified that APHIS has authority to implement interim measures through partial deregulation or
similar means for this putpose;
(2) Sugarbeet growers nationwide, along with sugarboct cooperatives, processors, seed
companies and other interests, face significant harm from any halt in RRSB planting, cultivation,
harvesting or processing; and
(3) Petitioners are requesting that APHIS implement measures that APHIS has already
itself reviewed, analyzed and supported in the litigation context.
Attached to this letter is an Environmental Report, providing additional analysis of the
proposed interim measures. The analysis in APHIS’s original EA addressing Monsanto and
KWS’s petition, along with the 5000-page administrative record relating thereto and this
Environmental Report all support petitioners’ request for partial deregulation or similar
administrative action.
Thank you very much for your attention to this matter.
Sincerely,
H. Keith Reding, Ph.D,
Regulatory Affairs Managi
isanto
3
1199
I
Philip vonMcm ,
Chairman of the
iussche
Executive Board of KWS SAAT AG
Dr. peter Hofmann
Head of Sugar Beel Division
4
1200
ENVIRONMENTAL REPORT
Interim Measures for Cultivation of
Roundup Ready® Sugar Beet Event H7-1
July 30, 2010
1201
ACRONYMS AND ABBREVIATIONS
ACCase
aoetyl-CoA carboxylase (enzyme)
a.e.
acid equivalent
ALS
acetolactate synthase (enzyme)
AMS
Agricultural Marketing Service (USDA)
AP
Adventitious presence
APHIS
Animal and Plant Health Inspection Service (USDA)
APM
American Public Media
ARS
Agricultural Research Service (ARS)
ASIA
American Seed Trade Association
BNF
Biotechnology Notification Files
BRS
Biotechnology Regulatory Service (USDA APHIS)
CEQ
Council on Environmental Quality
CFIA
Canadian Food Inspection Agency
CFR
Code of Federal Regulations
CFS
Center for Food Safety
CMS
cytoplasmic male sterility
cPAD
chronic Population Adjusted Dose
CTIC
Conservation Technology Information Center
DEIS
Draft Environmental Impact Statement
DNA
Deoxyribonucleic Acid
EA
Environmental Assessment
EC
European Commission (EU)
EEC
Estimated Environmental Concentration
EFSA
European Food Safety Authority
EiQ
Environmental Impact Quotient
EIS
Environmental Impact Statement
EPA
Environmental Protection Agency (US)
EPSPS
5-enolpyruvy!shikimate-3-phosphate synthase (enzyme)
ER
Environmental Report
ERS
Economic Research Service (USDA)
EU
European Union
FDA
Food and Drug Administration (US)
FFDCA
Federal Food, Drug, and Cosmetic Act
FIFRA
Federal Insecticide, Fungicide, and Rodenticide Act
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Acronyms
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FONSI
Finding of No Significant Impact
FQPA
Food Quality Protection Act
FSA
Farm Service Agency
FSANZ
Food Standards Australia New Zealand
ft
feet
GE
Genetic engineering or genetically engineered
GM
Genetically modified
GMO
Genetically modified organism
GPS
Global Positioning System
GR
Glyphosate resistant
GT
Glyphosate-tolerant
HQ
Hazard quotient
HTS
Harmonized Tariff Schedule
IM/NRC
institute of Medicine and National Research Council
IPM
Integrated pest management
IPA
Isopropylamine
ISF
International Seed Federation
NASS
National Agricultural Statistical Service (USDA)
NEPA
National Environmental Policy Act
NOAEL
No-Observed-Adverse-Effect-Level
NOP
National Organic Program
NRC
National Research Council
OECD
Organization for Economic Cooperation and Development
OP
Open-pollinated
OSTP
Office of Science and Technology Policy
PCR
Polymerase chain reaction
PHI
Post Harvest Intervals
PNT
Plant with a Novel Trait
POEA
Polyethoxylated Tallow Amine
PPA
Plant Protection Act
PPE
Personal Protective Equipment
PPI
Pre-plant incorporated (herbicide)
rDNA
Recombinant DNA
RED
Reregistration Eligibility Decision
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RfD
RR
R&D
SBRED
SOP
TUG
T-DNA
UC
U.S.
use
USDA
USDC
USFWS
WCBS
WHO
WSSA
WVSSA
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Reference Dose
Roundup Ready®
Research and Development
Sugar beet Research and Education Board of Minnesota and North Dakota
Standard Operating Procedures
Technology Use Guide
Transferred DNA
University of California
United States
United States Code
US Department of Agriculture
U.S. District Court
U.S. Fish and Wildlife Service
West Coast Beet Seed Company
World Health Organization
Weed Science Society of America
Willamette Valley Specialty Seed Association
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TABLE OF CONTENTS
INTRODUCTION 1
1.1 PURPOSE OF THIS ER 1
1.1.1 Background 1
1.1.2 Purpose of and need for action 3
1.1.3 APHIS proposed interim measures/time frames for
implementation 3
1.2 RATIONALE FOR CREATION OF EVENT H7-1 8
1.3 COURT RULING AND ISSUES IDENTIFIED 9
1.3.1 Gene transmission from H7-1 sugar beets in production fields.. 9
1.3.2 Gene transmission to conventional sugar beets in seed
production 10
1.3.3 Gene transmission to red table beets and Swiss chard 10
1.3.4 Socioeconomic impacts 10
1.3.5 Willingness of buyers to accept sugar derived from GE sugar
beets 11
1.3.6 Restrictions/labeling requirements by some countries on GE
products 11
1.3.7 Potential for development of glyphosate-resistant weeds 11
1.3.8 Cumulative effects of increased use of glyphosate 12
1.4 FEDERAL REGULATORY AUTHORITY - COORDINATED FRAMEWORK 12
1.4.1 USDA Regulatory Authority 13
1.4.2 EPA regulatory authority 14
1.4.3 FDA regulatory authority 14
1.5 THE NATIONAL ORGANIC PROGRAM AND BIOTECHNOLOGY 15
1.5.1 Non-GMO Project Working Standard 17
1.5.2 Growth in organic and GE farming 17
1.6 COEXISTENCE IN US AGRICULTURE 17
1.6.1 Coexistence and biotechnology 17
1.6.2 USDA position on coexistence and biotechnology 18
1.6.3 Coexistence in US crop production 19
1.7 ROLE OF THE NATIONAL ACADEMIES IN AGRICULTURAL
BIOTECHNOLOGY 20
1.8 ALTERNATIVES CONSIDERED 21
1.8.1 Alternative 1 - No Action (full regulation) 21
1.8.2 Alternative 2 - Partial Deregulation with Interim Conditions... 21
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SECTION 2.0 AFFECTED ENVIROMENT 22
AFFECTED ENVIROMENT 22
2.1 SUGAR BEET CHARACTERISTICS AND USES 22
2.2 ACCEPTANCE OF EVENT H7-1 SUGAR BEETS 23
2.3 SUGAR BEET ROOT PRODUCTION 24
2.3.1 US Production by regions 24
2.3.2 Grower-processor relationships 27
2.3.3 Sugar beet cultivation practices 29
2.3.4 Sugar beet bolters and volunteers 31
2.4 GENE FLOW 36
2.5 SUGAR BEET WEED MANAGEMENT 39
2.5.1 Weed characteristics and concerns 39
2.5.2 Sugar beets and weeds 40
2.5.3 Problem weeds in sugar beet production 41
2.5.4 Other non-herbicide weed management practices 43
2.5.5 Use of herbicides to control weeds 43
2.5.6 Weed control with conventional sugar beets 43
2.5.7 Weed control with event H7-1 51
2.6 HERBICIDE RESISTANCE 51
2.7 SUGAR BEET SEED PRODUCTION 53
2.7.1 Variety development 53
2.7.2 Hybrids and cytoplasmic male sterility 54
2.7.3 Commercial sugar beet seed production 55
2.8 RED TABLE BEET, SWISS CHARD, AND SPINACH BEET PRODUCTION62
2.8.1 Vegetable beet production 62
2.8.2 Red table beet and Swiss chard seed production 63
2.8.3 Organic Red Table Beet and Swiss Chard Production 65
2.9 NATIVE AND UNCULTIVATED NON-NATIVE BEETS 70
2.9.1 Native beets 70
2.9.2 Uncultivated wild beets in the US 70
2.9.3 Weed beets 74
2.9.4 Feral crops 75
2.10 FOOD AND FEED USES OF SUGAR BEET 76
2.11 PHYSICAL AND BIOLOGICAL ISSUES 76
2.12 SOCIOECONOMICS AND HEALTH 76
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SECTION 3.0 ENVIRONMENTAL CONSEQUENCES 78
3.1 PLANT PEST PROPERTIES AND UNINTENDED EFFECTS 78
3.1.1 Background 78
3.1.2 Evaluation of intended effects 82
3.1.3 Evaluation of possible unintended effects 83
3.2 WEEDINESS PROPERTIES, VOLUNTEERS AND FERAL CROPS 85
3.2.1 Weediness properties of sugar beet 85
3.2.2 Event H7-1 sugar beet and weediness 85
3.2.3 Sugar beet volunteers 86
3.2.4 Impact summary 87
3.3 IMPACTS OF EVENT H7-1 SUGAR BEET ROOT CROPS ON
CONVENTIONAL SUGAR BEET CROPS 88
3.3.1 Pollen sources in production fields 88
3.3.2 Potential for gene flow in root production fields 89
3.3.3 Potential for mixing of event H7-1 and conventional sugar beets89
3.3.4 Consequences of gene flow in production fields 90
3.3.5 Potential consequences from mechanical mixing 90
3.3.6 Impact Summary 91
3.4 IMPACTS OFOF EVENT H7-1 ROOT CROPS ON ORGANIC SUGAR BEET
CROPS 92
3.4.1 Impact summary 92
3.5 IMPACTS OFOF EVENT H7-1 ROOT CROPS ON OTHER BETA (NON-
SEED) CROPS 92
3.5.1 Impact summary 93
3.6 IMPACTS OF EVENT H7-1 SUGAR BEET ROOT CROPS ON OTHER BETA
SEED PRODUCTION AREAS 94
3.6.1 Impact summary 94
3.7 IMPACTS OF EVENT H7-1 ROOT CROPS ON NATIVE BEETS 95
3.7.1 Impact summary 95
3.8 IMPACTS OF EVENT H7-1 CROPS ON NON-NATIVE WILD AND
WEEDBEETS 95
3.8.1 Impact summary 96
3.9 IMPACTS OF EVENT H7-1 SEED PRODUCTION ON CONVENTIONAL
SUGAR BEET AND OTHER BETA SEED CROPS 97
3.9.1 Maintaining seed purity, identify and quality 97
3.9.2 Summary of practices for sugar beet seed production 98
3.9.3 Sugar beet seed production since 2007 98
3.9.4 Measured sugar beet pollen dispersal 100
3.9.5 Modeled sugar beet pollen dispersal 101
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3.9.6 Site-specific assessment of cross-pollination potential in the
Willamette Valley 101
3.9.7 Use of event H7-1 trait on male-sterile female 102
3.9.8 Red table beet offtypes 102
3.9.9 No sensitivity to event H7-1 by conventional sugar beet
growers; Stewardship regarding mechanical mixing 103
3.9.10 Question of zero tolerance 104
3.9.11 Seed availability 105
3.9.12 Impact Summary 105
3.10 LIVESTOCK PRODUCTION SYSTEMS 107
3.11 FOOD AND FEED 107
3.11.1 FDA authority and policy 108
3.11.2 FDA biotechnology consultation note to the file BNF 000090 .109
3.11.3 Health Canada approval 2005 112
3.11.4 Canadian Food Inspection Agency (CFIA) approval 2005 112
3.11.5 EFSA risk assessment and EC authorization 113
3.11.6 Other approvals 114
3.11.7 Willingness of the buyer to accept sugar from event H7-1 115
3.11.8 Impacts 115
3.12 WEED CONTROL AND GLYPHOSATE RESISTANCE 116
3.12.1 Herbicide-resistant weeds 116
3.12.2 Glyphosate-resistant weeds 119
3.12.3 Impact summary 122
3.13 PHYSICAL 123
3.13.1 Land Use 123
3.13.2 Air Quality and Climate 125
3.13.3 Surface water quality 126
3.13.4 Groundwater quality 127
3.14 BIOLOGICAL 128
3.14.1 Plant and Animal Exposure to Glyphosate 128
3.14.2 Threatened and Endangered Species 134
3.15 HUMAN HEALTH AND SAFETY 136
3.15.1 Consumer Health and Safety 136
3.15.2 Hazard Identification and Exposure Assessment for Field
Workers 137
3.16 ECONOMIC IMPACTS 139
3.16.1 Sugar beet processing 139
3.16.2 USDA's role in sugar marketing 140
3.16.3 Economic Impacts 140
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3.17 SOCIAL AND ECONOMIC IMPACTS ON RED BEET AND
CHARD GROWERS 145
SECTION 4.0 CUMULATIVE IMPACTS 14S
4.1 CLASS OF ACTIONS TO BE ANALYZED 148
4.2 GEOGRAPHIC AND TEMPORAL BOUNDARIES FOR THE ANALYSIS ..148
4.3 PARTIAL.CUMULATIVE IMPACTS RELATED TO THE DEVELOPMENT OF
GLYPHOSATE RESISTANT WEEDS 149
4.4 CUMULATIVE IMPACTS OF POTENTIAL INCREASED GLYPHOSATE
USAGE WITH THE CULTIVATION OF GLYPHOSATE TOLERANT CROPS149
4.4.1 Land Use, Air Quality and Climate 152
4.4.2 Water Quality 152
4.4.3 Biological 153
4.4.4 Human Health and Safety 154
4.4.5 Summary of Potential Cumulative Impacts from Increased Use
of Glyphosate 160
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APPENDICES
A Willamette Valley Specialty Seed Association (WVSSA) specialty seed production
isolation guidelines and Columbia basin vegetable seed field isolation standards
B West Coast Beet Seed Company protocol for genetically modified (GM) seed production
and GM grower guidelines
C International Seed Federation Code of Conduct
D Sugar Beet Production by County and State
E 2010 Technology Use Guide (TUG)
TABLES
Table 2-1 U.S. sugar beet production, 2009/2010 season
Table 2.2 Rotational crops following U.S. sugar beet production and an estimation of
rotational crops as Roundup Ready® crops
Table 2-3 Herbicide applications to sugar beet acres in the U.S., 2000
Table 2-4 Effectiveness of herbicides on major weeds in sugar beets
Table 3-1 Major sugar beet weeds with resistance to herbicide groups used in sugar beets
Table 3-2 Sugar beet acres planted 2005 to 2010
Table 3-3 Production loss and project costs from a GT sugar beet injunction
Table 4-1 Comparison of Potential Effects of Glyphosate and Sugar Beet Herbicides on
Freshwater Fish
Table 4-2 Comparison of Potential Effects of Glyphosate and Sugar Beet Herbicides on
Freshwater Aquatic Invertebrates
Table 4-3 Comparison of Potential Effects of Glyphosate and Sugar Beet Herbicides on
Aquatic Plants (Algae and Duckweed)
Table 4-4 Alternative Herbicides for Weed Control in Sugar Beets - Label Comparison /
Exposure Mitigation
Table 4-5 Potential Reduction in Risk from Use of Glyphosate Compared to Traditional
Herbicides Used in US Sugar Beet Production
FIGURES
Figure 1-1 Alternative 3 Roundup Ready® Sugar Beet-Free Zone
Figure 2-1 U.S. sugar beet regions and county production
Figure 2-2 2010 distribution by state of acres planted in sugar beets
Figure 2-3. Herbicide resistance worldwide
Figure 2-4 Willamette Valley
Figure 2-5 Distribution of “other" organic vegetable production, 2008
Figure 2-6. California acreage of organic beets (non-sugar), 2007
Figure 2-7 California gross sales of organic beets (non-sugar), 2007
Figure 2-8 California acreage of organic Swiss chard, 2007
Figure 2-9 California gross sales of organic Swiss chard, 2007
Figure 2-10 All CA counties with Beta records
Figure 4-1 Growth in adoption of genetically engineered crops in US
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INTRODUCTION
This Environmental Report (ER) examines the environmental impacts of continued cultivation of
Roundup Ready® sugar beet event H7-1 (event H7-1) for a temporary period subject to a range
of interim measures, including geographic restrictions, stewardship requirements and other
limitations -- identified and analyzed by the US Department of Agriculture's (USDA) Animal and
Plant Health Inspection Service (APHIS) in Center for Food Safety v. Vilsack, No. 08-484, N.D.
Cal. This ER is provided in connection with the petitioners' supplemental request for non-
regulated status in part (commonly known as “partial deregulation”) for event H7-1 . This
document is intended to provide information that may be utilized by APHIS in complying with the
National Environmental Policy Act (NEPA)' and its applicable regulations^ either in connection
with partial deregulation of event H7-1 or for any other regulatory or administrative action by
APHIS adopting the interim measures addressed herein. The interim measures are intended to
apply until APHIS completes its NEPA review of the petition for nonregulated status for event
H7-1 and reaches a final determination regarding the petition.
The sugar produced from sugar beets, which were planted on approximately 1 .2 million acres in
the US in 2010, accounts for over half the US sugar production. Cash receipts for sugar beets
were $1 .3 billion in the 2007-2008 crop year. Event H7-1 . which has been genetically
engineered to be tolerant to the herbicide glyphosate, has been grown on a large scale in the
US for multiple years and accounted for approximately 95 percent of the sugar beet planted in
the US in the 2009/2010 crop year (USDA NASS. 2010b; USDA ERS, 2009a and 2009b).
1.1 PURPOSE OF THIS ER
1.1.1 Background
In 2003, under the requirements of the Plant Protection Act (PPA),^ Monsanto Company and
KWS SAAT AG (Monsanto/KWS) submitted a petition (Petition No. 03-323-01 P) to APHIS for a
determination of non-regulated status for event H7-1 and all progeny derived by conventional
breeding from this event (Schneider, 2003). APHIS, through its Biotechnology Regulatory
Service (BRS), is one of three federal agencies responsible for regulating biotechnology in the
US under the Coordinated Framework described in Section 1 .4. APHIS regulates genetically
engineered (GE) organisms that may be plant pests, the Environmental Protection Agency
’ NEPA of 1969, as amended: Title 42 of the US Code (42 USC) §§4321-4347
^ Council on Environmental Quality (CEQ) regulations implement NEPA and are found in Title 40 of the Code of
Federal Regulations (40 CFR), Parts 1500 through 1508. The U.S. Department of Agriculture has implemented
NEPA regulations, which are found at 7 CFR Part It), as has APHIS, and those are found at 7 CFR part 372.
^7 use §§7701-7786
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(EPA) regulates plant incorporated protectants and herbicides used with herbicide-tolerant
crops, and the US Department of Health and Human Services' Food and Drug Administration
(FDA) regulates food and animal feed. The FDA completed its consultation process for event
H7-1 in 2004 and EPA agreed that its previous approval for glyphosate residue in sugar beet
roots, tops and dried pulp was also applicable to event H7-1 ((Tarantino, 2004; Bonette, 2004;
Schneider, 2003, p. 14). NEPA requires federal agencies to evaluate the potential impact of
proposed major federal actions and consider such impacts during the decision-making process.
After agency review for safety, including an evaluation of relevant scientific data and all public
comments relating to potential plant pest risks and related environmental impacts, APHIS
issued an EA pursuant to NEPA in 2005 (USDA APHIS, 2005). Based on that EA, APHIS
reached a finding of no significant impact (FONSI) on the environment from the unconfined
cultivation and agricultural use of event H7-1 and its progeny (USDA APHIS, 2005, p. 1).
Accordingly, in March 2005, APHIS granted non-regulated status to event H7-1 (USDA APHIS,
2005, p. 26).
After event H7-1 was deregulated, the multi-year process of bringing it to commercial production
began. Large scale commercial seed production began in 2006 to produce the seed crop used
for planting root crops in 2008, Small scale root production occurred in 2006 and 2007, In
January 2008, the Organic Seed Alliance, Sierra Club, High Mowing Organic Seeds, and the
Center for Food Safety (CFS) filed a lawsuit against the USDA over its decision to deregulate
event H7-1 , claiming the USDA failed to take a "hard look" at the environmental effects of its
decision to deregulate. The plaintiffs in the suit did not seek a preliminary injunction to halt
planting. In September 2009, the court granted the plaintiffs' motion for summary judgment in
the merits phase of the lawsuit, concluding that APHIS was required to prepare an
environmental impact statement (EIS) before approving its deregulation of GE sugar beets. In
December 2009, the court issued a schedule for the remedies phase of the lawsuit. At that
point, representatives of thousands of family farms that were growing event H7-1 sugar beet
root crops along with the four seed companies who produced seed and other interested parties
were permitted to participate in the suit.
In May 2010, while the remedies phase of the lawsuit was proceeding, Cindy Smith, the APHIS
Administrator, filed a declaration in the suit anticipating completion of the EIS in May 2012
(Smith, 2010b, pp. 7-8) and suggested that the court enter an order imposing certain interim
measures that would allow continued cultivation of event H7-1 . These interim measures would
include geographic restrictions and a range of stewardship requirements, and would apply for a
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temporary period pending completion of the EIS and the corresponding record of decision
(ROD), and implementation of that decision. (Smith, 2010b, pp. 19-22). Alternatively,
Administrator Smith proposed that the Court remand the case to APHIS with the intention that
APHIS would take action to implement these interim measures administratively. On May 25,
2010, APHIS issued a notice of intent to prepare an EIS and a proposed scope of study (APHIS
2010).
On June 21, 2010, the U.S. Supreme Court ruled in litigation related to Roundup Ready®
alfalfa, clarifying that a court in a NEPA case may not preemptively bar APHIS from issuing a
“partial deregulation” or taking other administrative action to implement interim measures for
cultivation of a genetically engineered crop while the agency completes an EIS evaluating
complete deregulation. Monsanto Co. v. Geertson Seed Farms, No. 09-475, 561 U.S. (2010).
1 .1 .2 Purpose of and need for action.
The purpose of this ER, which has been prepared to support an anticipated EA, is to examine
the environmental impacts of implementing interim measures, either through a partial
deregulation of event H7-1 lines of glyphosate tolerant sugar beets or certain other
administrative means. The interim measures have been identified to address concerns
regarding potential impacts related to the planting and cultivation of event H7-1 while the EIS
evaluating complete deregulation is being prepared. If APHIS concludes that an EA supports a
FONSI for such interim measures, APHIS could decide to implement such measures through
“partial deregulation" pending APHIS'S determination on complete deregulation.
1.1.3 APHIS proposed interim measuresftime frames for implementation
APHIS' proposed interim measures for Roundup Ready® sugar beets (RRSB), to be
implemented either through a partial deregulation or other administrative means, are detailed
below. These measures are the same as those proposed by Administrator Smith to the court
(Smith, 2010b, pp. 19-22), along with time frames for implementation of those measures.
Interim measures Proposed by APHIS to the Court
Administrator Smith proposed the following interim measures in the lawsuit discussed above:
1 ) Roundup Ready® Sugar Beet-Free Zone
The planting of RRSB is prohibited in the entire State of California and in the State of
Washington in the following counties west of the Cascades; Clallam, Jefferson, Grays Harbor,
Island, Pacific, Mason, Thurston, Lewis, Cowlitz, Clark, Whatcom, Skagit, Snohomish, King,
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Pierce, Skamania, San Juan, Kitsap, and Wahkiakum Counties. [These counties are shown in
this ER in Figure 1-1],
2) A Coexistence Zone for Beta Seed Crop Production in the Willamette Valley in Oregon
a. All parties to this action who grow Beta seed crops in the Willamette Valley must adhere
to a four mile isolation distance between RRSB seed crops and other Beta seed crops,
b. All parties to this action who grow Beta seed crops in the Willamette Valley must follow
the Willamette Valley Specialty Seed Association (WVSSA) pinning procedures,
3) Disclosure of Information Regarding Male Fertile RRSB Seed Crops.
All growers of RRSB male fertile seed crops must provide locations with GPS coordinates to
APHIS/BRS of any RRSB male fertile seed crops in the United States that exist at the time the
Court's Order is issued or that are planted at any time during the interim period in which the EIS
is being prepared. Information regarding existing plantings must be provided to APHIS within
30 days after issuance of the Order; information regarding future plantings during the interim
period must be provided to APHIS within one week after the completion of planting of any RRSB
male fertile seed crops. Within 60 days after issuance of the Order, APHIS/BRS shall set up a
toll-free number that growers of non-GE Beta seed crops may use to request from APHIS/BRS
the approximate distances from the nearest RRSB male fertile seed crop to their non-GE Beta
seed crop.
Upon calling this number, the caller shall certify to APHIS/BRS that the caller is a grower of non-
GE Beta seed crops or intends to grow non-GE Beta seed crops at an existing location in the
United States. APHIS/BRS shall only provide to the caller the approximate distance from the
nearest RRSB male fertile seed crop location to the caller's non-GE Beta seed crop.
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4) Measures to Prevent Mixing of ConvenOona} Sugar Beet Seed and RRSB.
RRSB seed producers shall follow protocols to ensure that mechanical mixing of material
containing the RRSB trait and non-GE Beta seeds does not occur. Those protocols shall
include;
a. A visual identificalion system for RRSB material (basic seed, stock seed, transplants
(stecklings), and commercial seed) that accompanies seed material throughout the
production system to delivery to ultimate purchaser;
b. A companion seed-lot based tracking and tracing system that is fully auditable;
c. Requirements for physical separation of RRSB material at all points in the seed
production process from non-GE Beta material;
d. Requirements for monitoring, treating, and cleaning of all planting, cultivation and
harvesting equipment to prevent RRSB seed, pollen or stecklings from being physically
transferred out of production areas by inadvertent means;
e. Requirements for disposal of all unused RRSB stecklings by returning unused stecklings
to the nursery field of origin and subsequent destruction through standard agricultural
practices (physical destruction with tillage and chemical destruction in the subsequent
crop};);
f. Requirements for contained seed transport from field to cleaning facility, vehicle cleaning
after transport of RRSB seed before use for other purposes, and devitalization of RRSB
material derived from cleaning vehicles or processing facilities;
g. Prohibition on grower production of a RRSB seed and chard/red beet seed production
on the same location/premises in the same year;
h. Prohibition on RRSB seed grower use or sharing of pianting/cultivation equipment that
might be used in a non-GE Beta seed production in the same growing year;
i. Prohibition on RRSB seed grower use of the same combine to harvest RRSB and non-
GE Beta seed in the same year;
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j. Provisions to force same-year sprouting of any RRSB seed left behind in production field
for removal and destruction; plus 3-year monitoring of fields thereafter, along with
removal and destruction of any beet plants;
k. Employee training in all aspects of a. through j. above;
l. No RRSB seed shall be cleaned or processed in any processing facility that also cleans
and processes red beet or Swiss chard seed;
m. Recordkeeping to document compliance of a-l.
5) Control of Any Bolters in the RRSB Root Crop Fields.
All RRSB root crop growers must have contractual measures in place that require RRSB root
crop growers to survey, identify, and eliminate any bolters in their root crop fields before they
produce pollen or set seed.
6) Control of Any Bolters in Harvested RRSB Root Crop in Outdoor Storage.
All sugar beet processors or cooperatives that use RRSB must have measures in place to
sunrey, identify, and eliminate any bolters in outdoor storage before they produce pollen or set
seed.
7) Third Party Audit for Compliance.
APHIS will require third party audits to ensure that RRSB producers comply with requirements
in paragraphs two and four above, APHIS expects that AMS [Agricultural Marketing Service],
USDA, will be the third party auditor using its AMS-USDA Process Verified Program.
Time frame for Implemeiitaiioit
While certain interim measures could be implemented shortly after APHIS issues its interim
order of partial deregulation or takes other administrative action regarding event H7-1 (e.g., Item
3), certain measures may require some additional time to fully implement. This ER makes the
following assumptions as to when the various components of the interim measures would be
implemented:
(1) RRSB-free zone. The sugar beet seed companies have represented that no RRSB
sugar beet crops have been or would be planted in California or the subject counties In
Washington State. Thus, these restrictions can be implemented immediately.
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(2) Willamette Valley coexistence zone
While certain isolation distance and pinning requirements have already existed for years, the
four-mile isolation distance and the pinning and audit requirements proposed in the interim
measures will be implemented in full with the summer 201 1 seed crop planting, which will occur
in July and August of 201 1 (Items 2 and 7). The current isolation distance provided by the
Willamette Valley Specialty Seed Association pinning provisions is four miles between sugar
beet seed crops on one hand and open-pollinated (OP) red beet or chard seed crops on the
other. Most of these crops will have been pinned and planted by the end of August 2010.
3) Disclosure of information regarding male fertile crops
Time frames are included in the proposed interim measures, described above.
4) Measures to prevent mixing of seed
While these measures have already largely been implemented in the major seed production
area, as discussed in Section 2.7.3 of this ER, we assume that full implementation will occur
before the 2011 seed harvest.
5) Control of bolters - root crop fields
Contracts requiring control of bolters are in place currently for the 2011 spring planting.
6) Control of bolters - root crop outdoor storage
These measures will be in place before the 201 1 harvest.
7) Third-party audits
Measures would be in place at the time of the partial deregulation or other administrative action
Imposing the interim measures.
1 .2 RATIONALE FOR CREATION OF EVENT H7-1
Event H7-1 offers sugar beet growers a simpler, more flexible, and less expensive alternative
for weed control relative to conventional weed control measures.
According to the World Agriculture Series volume Sugar Beets, "Weeds have been a major
problem in sugar beet since the crop was first grown in the late 1700s" and “unlike insects,
diseases and nematodes, weeds occur in all sugar beet fields every year, usually at populations
that cause crop failure unless controlled" (May and Wilson, 2006, p. 359). Other researchers,
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working before the introduction of event H7-1, have reported that “weed management is one of
the main production costs with sugar beef (Odero et al, 2008, p. 50).
As discussed in detail in Section 2.5, prior to widespread cultivation of event H7-1, sugar beet
growers used a variety of means to control weeds, and herbicides are a key component.
Herbicides are used by virtually all sugar beet growers; in 2000, approximately 98 percent of
planted sugar beet acres received one or more herbicide applications (Ali, 2004, Table 4). In
the 2000 growing season. 12 different active ingredients formulated as various herbicide
products were commonly used in U.S. sugar beet production with a total of about 1.4 million
pounds of herbicides applied (USDA APHIS, 2005, pp. 6-7). Typical conventional weed control
consists of multiple applications of several different herbicides, often combined with hand or
mechanical weeding (Odero et al, 2008).
Glyphosate is little-used for conventional sugar beets (those without glyphosate tolerance)
because it damages the plants. With glyphosate-tolerant sugar beets, growers have an
additional option for weed control.
1.3 COURT RULING AND ISSUES IDENTIFIED
During the lawsuit discussed above, the court identified certain specific issues as requiring
additional analysis by APHIS (US District Court [USDC] 2008). These issues are described
below and are addressed in the Affected Environment and Environmental Consequences
sections of this ER. Additionally, this ER addresses issues that were not found to be
problematic by the court in APHIS’ initial EA. These issues are nevertheless addressed again
here to ensure full disclosure and analysis of any potential impacts associated with partial
deregulation of event H7-1 under the proposed interim measures.
1.3.1 Gene transmission from H7-1 sugar beets in production fields
Sugar beet is largely wind pollinated and has a biennial, two year life cycle when grown for
seed; plants develop a large root the first year, then overwinter and flower, producing a seed
stalk the second year. When grown to produce sugar, sugar beet roots are harvested during
the first year while still in the vegetative (non-flowering) phase. Sugar beets grown for root
crops rarely flower and thus rarely produce any pollen. However, certain conditions such as low
temperatures after planting and longer day length can occasionally cause the sugar beet to
“bolt" or produce a seed stalk (which can ultimately flower) during the first growing season (Bell
1946; Jaggard efat. 1983; Durrant and Jaggard 1988). Thus, further analysis to determine the
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potential for gene transmission from event H7-1 being grown for root production to conventional
sugar beets was conducted and is discussed in Section 3.3 of this ER.
1.3.2 Gene transmission to conventional sugar beets in seed production
Unlike sugar beet root production, seed production requires that the plants flower, become
pollinated and develop seed. The court concluded that APHIS did not take a “hard look" at the
potential for gene transmission in seed production in its initial EA in reference to the 2003
petition, and did not consider the fact that isolation distances set by the Oregon Seed
Certification Standards are voluntary; whether the isolation distances were actually followed and
are likely to be followed in the future; or if the isolation distances are sufficient to protect the
non-GE crops that are inter-fertile with sugar beets. Therefore, further analysis to determine the
potential for gene transmission from sugar beets being produced for seed production was
conducted and is discussed in Section 3.9 of this ER.
1.3.3 Gene transmission to red table beets and Swiss chard
Gross-pollination between cultivated sugar beet and sexually compatible Beta species can
occur when these plants grow close together and have overlapping flowering periods. The court
found that because sugar beet pollen can travel large distances by wind, and because seed for
sugar beets, Swiss chard, and table beets (which are all members of the same species and are
all sexually compatible) are all grown in one valley in Oregon (albeit principally in different parts
of the same valley), additional analysis is required to determine whether deregulation may
significantly affect the environment as a result of any potential cross-pollination. Therefore,
further analysis was conducted and is discussed in Sections 3.5 and 3.6 of this ER.
1.3.4 Socioeconomic impacts
The court found that APHIS failed to analyze in its initial EA the socio-economic impacts of
deregulating event H7-1 on farmers and processors seeking to avoid GE sugar beets and
derived products, stating,
Economic effects are relevant and must be addressed in the environmental review
"when they are Interrelated’ with ’natural or physical environmental effects."' Ashley
Creek Phosphate Co. v. Norton, 420 F.3d 934, 944 (9th Ctr. 2005) (emphasis in
original) (quoting 40 C.F.R. 1508. 14): see also Geertson Seed Farms v. Johanns, 2007
WL 518824, *7 (N.D. Cat. Feb. 13, 2007). In Geertson Seed Farms, the court found
that "the economic effects on the organic and conventional farmers of the government’s
deregulation decision are interrelated with, and, indeed, a direct result of, the effect an
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the physical environment; namely, the alteration of a plant specie[s]' DNA through the
transmission of the genetically engineered gene to the organic and conventional [crop]."
Id., 2007 WL 518624, *8 (emphasis added).
The court held that APHIS was required to consider these effects in assessing whether the
impact of its proposed action of deregulation was significant. Therefore, further analysis was
conducted and is discussed in Section 3.17 of this ER.
1.3.5 Willingness of buyers to accept sugar derived from GE sugar beets
The court's ruling included a reference to a 2004 comment from Imperial Sugar, a company that
at that time processed sugar beets (but no longer does) and currently produces and markets
only cane sugar. Imperial Sugar raised a concern in response to the petition for deregulation
that buyers of industrial and consumer sugars have expressed reluctance or opposition to
receiving sugar derived from GE sugar beet. Imperial Sugar's opinion was that the industrial
buyers' reluctance was caused by their belief that consumers would react negatively to products
containing or derived from GE crops. Imperial Sugar was therefore concerned that industrial
buyers would be unwilling to test the reaction of consumers by using sugar from event H7-1 in
their branded products.
Currently, event H7-1 sugar beet is processed into a large percentage of our domestic sugar
supply, and has been well accepted. Nevertheless, further analysis of this issue was conducted
and is discussed in Section 3.11 of this ER.
1.3.6 Restrictions/labeling requirements by some countries on GE products
Imperial Sugar also commented that some countries will not allow GE products to be imported
and that many nations require labeling of food products with GE content. However, less than
two percent of the sugar produced in the US is exported (USDA FAS, 2010), and exports of
products derived from event H7-1 sugar beets are expressly allowed in many foreign countries.
Further information is available in Section 3.11 of this ER.
1 .3.7 Potential for development of glyphosate-resistant weeds
As the adoption of glyphosate-tolerant crops has grown, the use of glyphosate has increased
(National Research Council [NRC], 2010, Figures S-1, S-2, and S-3; Young, 2006). Concerns
have been expressed that increased use of glyphosate may lead to development of glyphosate-
resistant weeds. Further information is available in Sections 2.5 and 3.12 of this ER.
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1.3.8 Cumulative effects of increased use of glyphosate
Further analysis of cumulative impacts from increased use of glyphosate was conducted and is
discussed in Section 4 of this ER. However, since this ER is intended to address only the
period of time until the EIS is completed, cumulative effects are considered for that time period.
1 .4 FEDERAL REGULATORY AUTHORITY - COORDINATED FRAMEWORK
Interagency coordination in scientific and technical matters is the responsibility of the federal
Office of Science and Technology Policy (OSTP), which was established by law in 1976. A
large part of the OSTP's mission is “to ensure that the policies of the Executive Branch are
informed by sound science" and to "ensure that the scientific and technical work of the
Executive Branch is properly coordinated so as to provide the greatest benefit to society”
(OSTP, undated).
In 1 986, the OSTP published a “comprehensive federal regulatory policy for ensuring the safety
of biotechnology research and products", the Coordinated Framework for the Regulation of
Biotechnology (Coordinated Framework) (OSTP, 1 986). The OSTP concluded that the goal of
ensuring biotechnology safety could be achieved within existing laws (OSTP, 1986),
The Coordinated Framework specifies three federal agencies responsible for regulating
biotechnology in the US: USOA's APHIS, the EPA, and the FDA. APHIS regulates GE
organisms under the Plant Protection Act of 2000 (PPA). EPA regulates piant-incorporafed
protectants and herbicides used with herbicide-tolerant crops under the Federal Insecticide,
Fungicide, and Rodenticide Act (FIFRA) and Federal Food, Drug, and Cosmetic Act (FFDCA).
FDA regulates food (including animal feed, but not including meat and poultry, which is
regulated by USDA), including food and feed produced through biotechnology, under the
authority of the FFDCA. Products are regulated according to their intended use and some
products are regulated by more than one agency. Together, these agencies ensure that the
products of modem biotechnology are safe to grow, safe to eat, and safe for the environment.
USDA, EPA, and FDA enforce agency-specific regulations to products of biotechnology that are
based on the specific nature of each GE organism.
in 2001 , in a joint CEQ/OSTP assessment of federal environmental regulations pertaining to
agricultural biotechnology, the CEQ and OSTP found that “no significant negative environmental
Impacts have been associated with the use of any previously approved biotechnology product”
(CEQ/OSP, 2001, p.1).
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For glyphosate-tolerant sugar beet event H7-1, the plant is reviewed by USDA and FDA,
whereas ERA is responsible for registering the use of the glyphosate herbicide and establishing
a tolerance for allowable glyphosate residues. As indicated herein, although certain issues such
as weed resistance and impacts of glyphosate on animals or plants are addressed by ERA (not
APHIS), this ER nevertheless addresses those issues.
1.4.1 USDA Regulatory Authority
The Animal and Plant Health Inspection Service (APHIS) Biotechnology Regulatory Service
(BRS) mission is to protect US agriculture and the environment using a dynamic and science-
based regulatory framework that allows for the safe development and use of GE organisms.
Under its authority from the PPA, APHIS regulates the introduction (importation, interstate
movement, or release into the environment) of certain GE organisms and products.’’ A GE
organism is presumed to be a regulated article if the donor organism, recipient organism, vector,
or vector agent used in engineering the organism belongs to one of the taxa listed in the
regulation® and is also presumed to be a plant pest. APHIS also has authority under these rules
to regulate a GE organism if it has reason to believe that the GE organism may be a plant pest
or APHIS does not have sufficient information to determine that the GE organism is unlikely to
pose a plant pest risk.®
Under APHIS’ regulations a person may petition APHIS to evaluate submitted data and
determine that a particular regulated article is unlikely to pose a plant pest risk, and, therefore,
should no longer be regulated,^ The petitioner is required to provide information related to plant
pest risk that the agency may use to determine whether the regulated article is unlikely to
present a greater plant pest risk than the unmodified organism.® If the agency determines that
the regulated article is unlikely to pose a plant pest risk, the GE organism will be granted
nonregulated status. In such a case, APHIS authorizations (i.e. permits and notifications)
would no longer be required for environmental release, importation, or interstate movement of
the non-regulated article or its progeny.
It was under these regulations that Monsanto/KWS submitted the petition for a determination of
non-regulated status for event H7-1 (Schneider, 2003). Event H7-1 sugar beets were
considered regulated because they contain non-coding DNA segments derived from plant
VC.F.R, §.340
®7C.F.R. §.340.2
® 7C.F.R. §.340.1
’ 7 C.F.R. §.340.6 entitled “Petition for determination of nonregulated status'
‘id. §340,6(c)(4)
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pathogens and the vector agent used to deliver the transforming DNA is a plant pathogen (See
Section 3,1 for a discussion of these concepts) (APHIS, 2005, p. 4).
1.4.2 EPA regulatory authority
EPA is responsible for regulation of pesticides (including herbicides such as glyphosate) under
the FiFRA.® FIFRA requires that all pesticides be registered before distribution, sale, and use,
unless exempted by EPA regulation. Before a product is registered as a pesticide under FIFRA,
it must be shown that when used in accordance with the label, it will not result in unreasonable
adverse effects on the environment. EPA granted the registration of glyphosate for use over the
top of sugar beets on IVlarch31, 1999.
Under the Federal Food, Drug, and Cosmetic Act (FFDCA), as amended, pesticides added to
(or contained in) raw agricultural commodities generally are considered to be unsafe unless a
tolerance or exemption from tolerance has been established. EPA establishes residue
tolerances for pesticides under the authority of the FFDCA. EPA is required, before establishing
pesticide tolerance to reach a safety determination based on a finding of reasonable certainty of
no harm under the FFDCA, as amended by the Food Quality Protection Act of 1996 (FQPA).
The FDA enforces the tolerances set by the EPA. EPA established a tolerance for glyphosate
residue found on beets, including sugar, roots, tops, and dried pulp on April 14, 1999 (64 Fed.
Reg. 18360).
1.4.3 FDA regulatory authority
In 1992 FDA, which has primary regulatory authority over food and feed safety, published a
policy statement in the Federal Register concerning regulation of products derived from new
plant varieties, including those genetically engineered (FDA, 1992). Under this policy, FDA
uses a consultation process to ensure that human food and animal feed safety issues or other
regulatory issues (e.g. labeling) are resolved prior to commercial distribution of a bioengineered
food, Wlonsanto/KWS submitted a food and feed safety and nutritional assessment summary for
event H7-1 to FDA in April 2003. FDA completed its consultation process in August 2004
(Tarantino, 2004; Bonette, 2004),
’7 use §13Betseq.
’°21 U.S.C. §301 etaeq.
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1.5 THE NATIONAL ORGANIC PROGRAM AND BIOTECHNOLOGY
Congress passed The Organic Foods Production Act of 1990 (OFPA) to avoid the confusion
and misrepresentation then taking place in the “organic” marketplace." The OFPA required the
USDA to establish a National Organic Program (NOP) to develop uniform standards and a
certification process for those producing and handling food products offered for sale as
“organically produced."’^ The OFPA requires certification under the NOP, which was finalized in
2000, to be process-based.” “The certification process does not guarantee particular attributes
of the end product; rather it specifies and audits the methods and procedures by which the
product is produced" (Ronald and Fouche, 2006). The NOP defines certain "excluded
methods" of breeding that cannot be used in organic production, describing them as "means
that are not possible under natural conditions or processes.”" Along with genetic engineering,
three other modern breeding techniques are specified as “excluded methods" in the
regulations,” Thus, a certified organic grower cannot intentionally plant seeds that were
developed by these specific excluded methods. However, because “organic” is based on
process and not product, the mere presence of plant materials produced through excluded
methods in a crop will not jeopardize the integrity of products labeled as organic, as long as the
grower follows the required organic production protocol. Also, other modern breeding methods -
for example, induced radiation or chemical mutagenesis - are not specified as excluded
methods by the NOP (discussed in Section 3.1.1),
All organic growers’ production plans must be approved by an organic certifying agent before
the farm can be certified as "organic."” Such plans must include, among other things, steps the
organic grower is taking to avoid what the NOP refers to as "genetic drift" from any neighboring
crops using excluded methods.”’ Certification must include on-slte inspections of the farm to
verify the procedures set forth in the organic production plan.”
Thus, the NOP recognizes the coexistence of organic growers with neighboring growers who
may choose to grow products developed using certain methods of biotechnology. So long as an
organic grower follows an approved organic method of production that seeks to avoid contact
"7 use §6501 etseq.
”7C.F.R. Part205, announced at 66 Fed, Reg. 80548(Dec, 21,2000).
"7U.S.C. 6503(a),
’VC.F.R. § 205.2
"w,
“See7C,F.R. Part 205, Subpl. E
See id. at 205.201; 65 Fed. Reg. at 80556 (discussing "genetic drift").
"7C.F.R, § 206.403.
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with these specific biotechnology-derived crops, if some residue of the biotechnology-derived
plant material is later found in the organic crop (or food produced from it), neither the crop (or
food) nor the organic farm is in danger of losing its organic status. No grower or seed producer
has lost organic certification due to inadvertent transmission of genetic material from a
genetically engineered crop.
In the context of the genetic drift discussion, in the preamble of the NOP regulations, USDA
emphasized that it is the use of excluded methods as a production method that is prohibited, not
the mere presence of a product of excluded method:
It Is particularly important to remember that organic standards are process based.
Certifying agents attest to the ability of organic operations to follow a set of production
standards and practices that meet the requirements of the Act and the regulations. This
regulation prohibits the use of excluded methods in organic operations. The presence
of a detectable residue of a product of excluded methods alone does not necessarily
constitute a violation of this regulation. As long as an organic operation has not used
excluded methods and takes reasonable steps to avoid contact with the products of
excluded methods as detailed in their approved organic system plan, the unintentional
presence of the products of excluded methods should not affect the status of an organic
product or operation.
The NOP calls for testing only if there is "reason to believe" that a grower has used excluded
methods.^” The preamble states that a "reason to believe" may be triggered by situations such
as a formal, written complaint to the certifying agent regarding the practices of a certified
organic operation; the proximity of a certified organic operation to a potential source of drift; or
the product from a certified organic operation being unaffected when neighboring fields or crops
are infested with pests.®’
This testing provision does not establish a zero tolerance standard for the presence of products
of excluded methods in organically labeled food. Rather, it serves as a warning that excluded
methods may have been used: "Any detectable residues of , , .a product produced using
excluded methods found in or on samples during analysis will serve as a warning indicator to
the certifying agent."®®
[Tlhese regulations do not establish a “zero tolerance" standard. . . [A]
positive detection of a product of excluded methods would trigger an
investigation by the certifying agent to determine if a violation of organic
production or handling standards occurred. The presence of a detectable
”*65 Fed. Reg. at 80558.
*7C.F,R. § 205.670(b).
®' See 65 Fed. Reg. at S0629.
®®/cf. at 80628.
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residue alone does not necessarily indicate use of a product of excluded
methods that would constitute a violation of the standards.”^
Only if the organic producer intentionally used excluded methods of crop production will that
producer be subject to suspension or revocation of organic certification. There is no evidence
that any organic grower has lost certification due to unintended presence of GE material.
1.5.1 Non-GMO Project Working Standard
The Non-GMO Project is a non-profit organization created by leading players in the organic
industry to “offer consumers a consistent non-GMO choice for organic and natural products that
are produced without genetic engineering or recombinant DNA technologies” (Non-GMO
Project, 2010a). The Non-GMO Project has created a working standard to implement its goal.
The standard sets action thresholds for “GMO" (GE) adventitious presence for certain products.
If these action thresholds are exceeded, the participant must investigate the cause of the
exceedance and take corrective action (Non-GMO Project, 2010, p. 13). The standard sets a
threshold of 0.25% for GE material for the presence of GE traits in non-GE seeds (p. 28), and a
0.9% threshold for non-GE food or feed (p.14).
1.5.2 Growth in organic and GE farming
Expansion of organic farming has succeeded at the same time as the growth of GE crops.
Consumer demand for organically produced goods “has shown double-digit growth for well over
a decade" and organic products "are now available in nearly 20,000 natural food stores and
three of four conventional grocery stores." Organic products “have shifted from being a lifestyle
choice for a small share of consumers to being consumed at least occasionally by a majority of
Americans” (USDA ERS, 2009c).
1 .6 COEXISTENCE IN US AGRICULTURE
1.6.1 Coexistence and biotechnology
Coexistence of different varieties of sexually compatible crops has long been a part of
agriculture, especially in seed production, where large investments are made in developing new
varieties and high seed purity levels are required by the Federal Seed Act implementing
regulations.^"* The aspect of coexistence most relevant to this document is that related to
specific methods of crop production. In this context, coexistence refers to the "concurrent
cultivation of conventional, organic, and genetically engineered (GE) crops consistent with
at 80632.
7 CFR § 201
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underlying consumer preferences and choices" (USDA Advisory Committee, 2008), The
differences among these crops that are particularly relevant to coexistence in this ER are in the
types of breeding methods (sometimes referred to as “genetic modifications") that are
associated with each of the three types of crops.
"Genetic engineering" is defined by APHIS regulations as “the genetic modification of
organisms by recombinant DNA techniques."® Recombinant DNA (rDNA) techniques are
discussed in Section 3.1.1 of this ER. While there are many ways to genetically modify a crop,
the APHIS definition of GE crops applies only to those developed using rDNA techniques, which
are among the more modern breeding methods.
Organic crops are those produced in accordance with the requirements of the NOP, discussed
in Section 1.5.
Conventional crops are simply those that are neither GE nor organic. They may be
commodity crops (mass produced), or they may be identity preserved, with some characteristic
tailored for a specific end user. Identity-preserved usually refers to a “specialty, high-value,
premium or niche market” (Massey, 2002). One type of identity preserved product that has
been produced since the introduction of GE crops is “non-GE;" however, there are no
mandatory standards governing the use and/or marketing of "non-GE" products (USDA
Advisory Committee, 2008).
Farmers who want to maximize their profitability must decide whether the higher prices
(premiums) they may receive for organic or identity-preserved crops are sufficient to offset the
added managerial costs of producing these crops. As researchers have noted, “Although yields
on organic farms are sometimes less than those of conventional systems, price premiums make
it an attractive option for growers looking for specialized markets and a higher-value product"
(Ronald and Fouche, 2006). There is such a niche market for organic red beets and organic
Swiss chard. However, no premium or niche market exists for either conventional or organic
sugar beets.
1.6.2 USDA position on coexistence and biotechnology
It is USDA’s position that all three methods of agricultural production described above can
provide benefits to the environment, consumers, and the agricultural economy (Smith, 2010b).
“7CFR §340.1
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1 .6.3 Coexistence in US crop production
Since the time GE crops were introduced in the US in the mid-1990s, organic markets have
grown and expanded (Smith, 2010b, p, 10).
The USDA Advisory Committee on Biotechnology and 21®' Century Agriculture who reported
that “coexistence among the three categories of crops is a distinguishing characteristic of U.S.
agriculture, and makes it different from some other parts of the world," expressed its belief that
US agriculture supports coexistence, and recommended continued government support of
coexistence (USDA Advisory Committee, 2008). Among the Committee’s findings:
• The U.S. is the largest producer of GE crops in the world.
• The U.S. is one of the largest producers of organic crops in the world.
• The U.S. is one of the largest exporters of conventionally-grown, identity preserved,
non-GE crops in the world.
• Some U.S. farmers currently are producing a combination of organic, conventional,
and GE crops on the same farm.
Among the coexistence-enabling factors the Committee identified are the existing “legal and
regulatory framework that has enabled different markets to develop” without foreclosing the
ability of “participants in the food and feed supply chain to establish standards and procedures
(e.g,, not setting specific mandatory adventitious presence (AP) thresholds and having process-
based rather than product-based organic standards).” At the same time, development of
practices and testing methods that allow for voluntary thresholds has also enabled coexistence
(USDA Advisory Committee, 2008),
As APHIS has previously observed, “studies of coexistence of major GE and non-GE crops in
North America and the European Union (E.U.) demonstrated that there has been no significant
gene flow from GE crops and that GE and non-GE crops are coexisting with minimal adverse
economic effects" (Smith, 2010b, pp. 11-12) (citing Gealy et. al, 2007; Brookes and Barfoot,
2003; Brookes and Barfoot, 2004(a) and (b), and Walz 2004)). In addition, “the agricultural
markets and local entities have addressed coexistence through contractual arrangements,
management measures, and marketing arrangements. This market-based approach to
coexistence has created economic opportunities for all kinds of producers of agricultural
products." {Id, p. 9). RRSB is one of fifteen glyphosate-tolerant events previously deregulated
by USDA. See APHIS, EPA, Petitions of Non-Regulated Status Granted or Pending by APHIS
as of February 2, 2010, http.7/www,aphis.usda.gov/brs/not_reg.htmi.
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1.7 ROLE OF THE NATIONAL ACADEMIES IN AGRICULTURAL
BIOTECHNOLOGY
The analyses in this ER are based on published, peer-reviewed scientific papers; federal
government assessments; assessments from international agencies; information from
specialists from many universities; data collected by Monsanto/KWS under controlled
conditions; and information from other relevant sources. One resource used for this ER is the
National Academies (NA), a private, non-profit institution that advises the nation on scientific
and technical matters. It consists of the National Academy of Sciences (NAS), the National
Academy of Engineering, the Institute of Medicine (IM) and the National Research Council
(NRC) (NA, 2010). Scientists, engineers and health professionals are elected by their peers to
the academy and serve pro bono. Reports are prepared by committees of members with
specialized expertise and reviewed by outside anonymous experts (Alberts, 1999).
The NA has been active in studies related to agricultural biotechnology since the 1970s, works
cooperatively with federal agencies, and its reports have provided guidance and
recommendations for process improvement to regulatory agencies (Alberts, 1999). The NRC
1989 guidelines for field testing of genetically engineered organisms were used as the basis for
agency procedures for field trials (Alberts, 1999; NRC, 1989). In studies in 1987 and 2000 the
NRC emphasized that the characteristics of the modified organism should be the object of a risk
assessment, and not the methods by which the modifications were accomplished; and that the
risks associated with recombinant DNA techniques are the same in kind as risks from other
types of genetic modification (NRC, 1987; NRC, 2000). This position was re-iterated in a 2004
study prepared jointly by the IM and the NRC. Whether such compositional changes result in
unintended health effects is dependent on the nature of the substances altered and the
biological consequences of the compounds. To date, "no adverse health effects attributed to
genetic engineering have been documented in the human population” (IM/NRC, 2004, p. 8). In
a 2002 report, the NRC "found that the current standards used by the federal government to
assure environmental safety of transgenic plants were higher than the standards used in
assuring safety of other agricultural practices and technologies” (NRC, 2002). The NRC reports
that, while biotechnology is not without risk, since the first commercial Introduction of transgenic
plants, "biotechnology has provided enormous benefits to agricultural crop production" (NRC,
2008). NRC's latest report on biotechnology in agriculture evaluates the impact of genetically
engineered crops on farm sustainability. The authors concluded that an understanding of
impacts on ail farmers will help ensure that GE technology contributes to sustainability and that
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commercialized GE traits to date, when used properly, ”have been effective at reducing pest
problems with economic and environmental benefit to farmers” (NRC, 2010).
1.8 ALTERNATIVES CONSIDERED
In addition to the alternative of partial deregulation or other administrative action implementing
the Interim conditions (Alternative 2), this ER considers the alternative of full regulation
(Alternative 1).
1.8.1 Alternative 1 - No Action (full regulation)
In conducting NEPA review, agencies consider a No Action alternative, which provides a
baseline against which action alternatives can be evaluated. This ER identifies the No Action
alternative as a return to full regulation - or the status quo existing when the petition for
deregulation of event H7-1 was initially submitted. Under this alternative, the introduction of
event H7-1 lines of glyphosate tolerant sugar beets would be fully regulated and would require
permits issued or notifications acknowledged by APHIS until APHIS completes its EIS and
issues a Record of Decision (ROD) regarding whether to deregulate H7-1 lines of glyphosate
tolerant sugar beets. For purposes of this analysis, we assume that Alternative 1 would not
involve widespread event H7-1 sugar beet cultivation, and instead would contemplate a return
to conventional sugar beet crops or to crops other than sugar beet. Note: As indicated above,
the status quo is event H7-1 sugar beets comprising 95 percent of the U.S. sugar beet crop.
1 .8.2 Alternative 2 - Partial Deregulation with Interim Conditions
Under this alternative, the introduction of event H7-1 lines of glyphosate tolerant sugar beets
would be allowed under interim conditions until APHIS completes its EiS,, issues a Record of
Decision, and that decision takes effect - currently anticipated for mid-2012 (Smith, 2010b, p,
8).
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AFFECTED ENVIRONMENT
This section describes the affected environment and provides other contextual information for
an understanding of the environmental consequences analyzed in Section 3.
2.1 SUGAR BEET CHARACTERISTICS AND USES
Sugar beet {Beta vulgaris L.) is a biennial plant that was developed in Europe in the 18th
century from white fodder (animal feed) beets. Sugar resen/es are stored in the sugar beet root
during the first growing season for an energy source during overwintering. The roots are
harvested for sugar at the end of the first growing season but plants that overwinter in a mild
climate will produce flowering stems and seed during the following summer and fall. Sugar beet
roots will not survive the winter in any of the growing regions except California (Cattanach et al,
1991).).
Pollination. The sugar beet is cross-pollinated (pollination occurs between plants rather than
within single plant) by wind (Cattahach et al, 1991).
Climate. Sugar beefs have adapted to a very wide range of climatic conditions. Sugar beets
primarily are a temperate zone crop produced in the Northern Hemisphere at latitudes of 30 to
60°N. The sugar beet plant grows until harvested or growth is stopped by a hard freeze. Sugar
beets primarily grow tops until the leaf canopy completely covers the soil surface in a field. This
normally takes 70 to 90 days from planting. Optimal daytime temperatures are 60 to 80°F for
the first 90 days of plant growth. Regions with long day length are most suitable for sugar beet
growth. The most favorable environment for producing a sugar beet crop from 90 days after
emergence to harvest is bright, sunny days with 65 to 80°F temperatures followed by nighttime
temperatures of 40 to 50°F. These environmental conditions maximize yield and quality in a
sugar beet crop. Sugar beets are successfully produced under irrigation in areas with very low
rainfall and in regions relying on natural rainfall (Cattanach et al, 1991).
Products. Sugar beets contain from 13 to 22 percent sucrose. Sugar beet pulp and molasses
are processing by-products used as feed supplements for livestock. These products provide
required fiber in rations and increase the palatability of feeds. Molasses by-products from sugar
beet processing are used in the alcohol, pharmaceuticals, and bakers' yeast industries
(Cattanach et al, 1991).
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2.2 ACCEPTANCE OF EVENT H7-1 SUGAR BEETS
Event H7-1 sugar beets were first available for cotnmerdal production in 2007 (Lilleboe, 2008),
In the 2009/10 crop year, event H7-1 varieties accounted for about 95 percent of planted area,
up from about 60 percent in 2008/09 (USDA ERS, 2009a). Since, as noted in Section 1, no
event H7-1 sugar beets have been grown in California and California represents approximately
3 percent of US sugar beet production (Table 2-1), 98 percent of the planted 2009/2010 sugar
beet crop in the remaining US sugar beet regions was event H7-1.
Table 2-1. US Sugar Beet Production, 2009/2010 Season
Region/State
1 ,000 short tons
Percent of US Total
Great Lakes
Michigan
3,318
Total
3,318
11
Upper Midwest
Minnesota
10,641
North Dakota
4,796
Total
15,437
52
Great Plains
Colorado
963
Montana
1,001
Nebraska
1,294
Wyoming
678
Total
3,936
13
Northwest
Idaho
5,591
Oregon
395
Total
5,986
20
Far West
California
886
Total
886
3
Source: USDA ERS. 2010a. Table 14
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2.3 SUGAR BEET ROOT PRODUCTION
2.3.1 US Production by regions
The US is among the world's largest sugar producers. Unlike most other producing countries,
the US has both large and well-developed sugarcane and sugar beet industries. Since the mid-
1990s, sugarcane has accounted for about 45 percent of the total sugar produced in the US,
and sugar beets for about 55 percent of production. Since 1961, planted sugar beet acreage
has fluctuated within the range of 1.1 million (low in 1982) to 1.6 million (high in 1975) (USDA
NASS 201 Oa). Annual cash receipts for sugar beets in the US in the past few years have
ranged up to $1.5 billion (USDA ERS, 2009b).
Figure 2-1 shows the five major US sugar beet producing regions, along with 2008 production
by county.
Great Lakes. Great Lakes sugar beet production, now entirely in Michigan, occurs in the flat
area around Saginaw Bay. Sugar beets grown in the Great Lakes region do not require
irrigation. The Great Lakes region also includes Ohio, where sugar beets were last produced in
2004.
Upper Midwest. The Upper Midwest is the largest sugar beet production region in the US, with
the majority of this production in the Red River Valley. The Red River flows north into Canada
and forms most of the North Dakota-Minnesota border. It flows through a broad, flat valley
formed by an ancient glacial lake. The Minnesota River Valley, another broad, flat glacial valley
that crosses southern Minnesota and is almost continuous with the Red River Valley, is also a
large production area. Irrigation is uncommon in the Red River/Minnesota River Valleys (Ali,
2004). There is another, much smaller Upper Midwest production area along the Montana
border of North Dakota, in the valley of the Yellowstone River and its tributaries.
Great Plains. The Northern Great Plains region includes production areas in northern
Wyoming and southern Montana. The major sugar beet growing areas in the Northern Great
Plains are the sandy loam soils along the Yellowstone River and its tributaries (Mikkelson and
Petrof, 1999, p. 2). The Southern Great Plains subregion includes growing areas in western
Nebraska, southeastern Wyoming and northeastern Colorado, primarily in the valley of the
Platte River and its tributaries. All Great Plains sugar beet production requires irrigation
(Thomas et al, 2000, p. 1; Mikkelson and Petrof, 1999, p. 3; McDonald et al, 2003, p. 2).
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The Great Plains region previously included New Mexico and Texas, where sugar beets were
last harvested in 1997.
Northwest. Most production in the Northwest region is in the sandy loam soil of the Snake
River Valley in Idaho. This area also requires irrigation (Traveller and Gallian, 2000, p. 1). In
addition, production occurs in southeast Washington state, east of the Cascade mountains.
Far West (California). The only sugar producing area in California is in the Imperial Valley in
the far southern end of the state, where the only remaining sugar processing plant in California
exists. Production occurred in the Central Valley (near the middle of the state) through 2008;
however, the last processing plant in this area closed in 2008. As recently as the 1990s, nearly
30 percent of sugar beet production was in the Central Valley; there were also small areas of
production in coastal counties (but production in those regions no longer exist) (California Beet
Growers Association, 1998, p,1).
US production for the 2009/2010 season (harvested in 2009 and processed in 2009/2010) is
shown in Table 2-1. In 2010, sugar beet was planted on 1.2 million acres (USDA ERS, 2010a,
Table 14). Sugar beet production by county from 2005 to 2008, including acres planted, acres
harvested, yield per acre, total yield and sucrose percent, is tabulated in Appendix D,
The distribution of planted acreage by state is shown in Figure 2-2.
■ MN
ta ND
a ID
B Ml
B ne
61! MT
i! WY
m CO
CA
OR
Figure 2-2. 201 0 distribution by state of acres planted in sugar beet
Source: USDA NASS, S010a
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2.3.2 Grower-processor relationships
Sugar beet production, more than most crops, requires close coordination between the grower
and the processor. The crop is of little value without a processor to extract the sugar, and a
sugar processing facility cannot stay in business without a reliable supply of beets (Kaffka and
Hills, 1994, p. 2). While a type of syrup can be made on a small scale, home garden production
of sugar would be impractical; processing cannot be duplicated successfully in a home kitchen
(California Beet Growers Association, 1998, p. 3). Sugar beets are 75 percent water and
expensive to transport long distances (Michigan Sugar Company, 2010a). For economic
reasons, sugar beets are typically grown within 60 miles of a processing facility, but may be
grown up to 100 miles away (Western Sugar Cooperative, 2006a). Locations of the 22
processing facilities in operation in 2010 are shown in Figure 2-2. While existing facilities have
been upgraded, no new currently operating processing facilities have been built in the US since
1 975. An estimated cost for an average-sized new facility in 1 991 was $1 00 million (Cattanach
et al, 1991, p. 16). The cost would be substantially higher today due to inflation and other
factors.
Sugar beet production and processing in the US is done almost entirely by grower-owned
cooperatives. The cooperatives own the processing facilities and the sugar beet farmers are
members of the cooperatives. The members own shares of stock that require them to grow a
specified acreage of beets in proportion to their stock ownership in the cooperative and
guarantee processing for their beets, US companies are summarized by regions below.
Cooperatives are owned by growers who are principally family farmers. According to the 2007
US Census of Agriculture, over 4,000 farms grow sugar beets (USDA ERS 2009b).
Great Lakes. Michigan Sugar Company, the third-largest sugar beet processor in the US,
processes all the sugar beets in the Great Lakes region, as well as beets from Ontario,
Canada.. The cooperative has over 1 ,000 grower-shareholders who grow sugar beets on
150,000 acres each year. The sugar beets are processed into sugar at factories in Bay City,
Sebewaing, Caro and Croswell. The cooperative employs 450 year-round and 1,200 seasonal
employees, generates nearly $400 million in direct economic activity annually in the local
communities in which it operate, and annually produces nearly one billion pounds of sugar
(Michigan Sugar Company, 2010b).
Upper Midwest. Three cooperatives operate in the Upper Midwest. American Crystal Sugar
Company, the largest sugar beet producer in the US, is owned by approximately 3,000
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shareholders who raise 500,000 acres of sugar beets in the Red River Valley of Minnesota and
North Dakota. The company operates five sugar processing facilities in the Red River Valley:
three in Minnesota (Crookston, East Grand Forks and Moorhead) and two in North Dakota
(Drayton and Hillsboro), American Crystal also operates a sugar beet processing facility in
eastern Montana at Sidney, under the name Sidney Sugars Incorporated. American Crystal's
fiscal year 2009 Red River Valley crop averaged 25.4 tons per acre with 17.6 percent sugar
content.. In 2009, the company produced approximately 3 billion tons of sugar and 681 ,000
tons of agri-products (molasses and pulp) (American Crystal Sugar Company, 2009), Minn-Dak
Farmers Cooperative, with 450 shareholders, operates a processing facility in Wahpeton, in the
far southeast comer of North Dakota. Minn-Dak also operates a yeast factory, which uses
molasses from sugar beet processing (Minn-Dak Farmers Cooperative, undated). The
Southern Minnesota Beet Sugar Cooperative has approximately 600 shareholders who farm
120,000 acres, and operates a processing facility near Renville, Minnesota (Southern
Minnesota Beet Sugar Cooperative, 2010).
Great Plains, The Western Sugar Cooperative, with 135,000 acres and five factories,
processes most of the Great Plains sugar beet. Processing facilities are in Fort Morgan,
Colorado; Billings, Montana; Scottsbiuff, Nebraska; and Loveil and Torrington, Wyoming.
Wyoming Sugar Beet Company, LLC is not a cooperative, but works through the Washakie
Farmers Cooperative to acquire beets for its plant in Worland, Wyoming (Boland, 2003).
Northwest. The Amalgamated Sugar Company LLC processes all the sugar beet in the
Northwest region. Amalgamated is owned by Snake River Sugar Company, a grower-owned
cooperative, and is headquartered in Boise, Idaho with processing plants in Paul, Twin Falls,
and Nampa, Idaho (Snake River Sugar Company, 2009),
Far West (California). Spreckels Sugar Company, a subsidiary of Southern Minnesota Beet
Sugar Cooperative, operates a sugar beet processing facility in Brawley, California, in the
Imperial Valley. Yields in the Imperial Valley are higher than anywhere else in the US,
averaging approximately 40 tons per acre (Spreckels Sugar, 2009).
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Tillage systems are derined
by the amount of crop residue
remaining on the soil.
Conventional tillage systems
leave less than 30 percent of
crop residue remaining on the
soil when planting another crop.
Conservation tillage leaves 30
percent dr. more of the previous
crop residue covering the soil
when planting another crop.
Reduced tillage leaves 15 to
30 percent of the previous crop
residue covering the soil when
planting another crop. .
Mulch tillage disturbs the soil
prior to planting, i Tillage tools
such as chisels, field cultivators,
disks or blades are used. Weed
control is accomplished with . ,
herbicides and/or cultivation.
No TUI leaves the soil
undisturbed.
With strip tillage, a specific
type of conservation tillage,
tillage is confined to narrow
strips where seeds will be
planted.: Strip tillage is usually
dorie in the fall, the loosened
soil creates a ridge, 3 to 4 inches
high, which improves soil
drainage and warrnmg. By
spring, it usually settles down to
1 or 2 inches high, and after
planting the field Is flat.
Sources: A!i, 2004. p. 32;
grown with less tillage (NRC, 2010, p.
2.3.3 Sugar beet cultivation practices
Seed bed preparation and tillage. The objectives of
seedbed preparation are to manage crop residue (the
leftover vegetative matter from the previous crop),
minimize erosion, improve soii structure, and eliminate
early season weeds. Tillage, which can be done in fall
and spring, can help improve soil structure and eliminate
early weeds, but tillage can also increase erosion. No-
till, strip tillage in previous crop residues, and other
conservation tillage systems (see definitions at left)
require more planning and better management
(Cattanach et ai, 1991). In addition to the reduced tillage
methods (noted at left), no-till productions systems do not
have any associated tillage where weed control is
entirely through chemical means, A survey conducted in
2000, before event H7-1 sugar beets were available,
found that use of conventional tillage for sugar beet
production varied by region from 64 percent of acreage in
the Red River Valley in the Upper Midwest to 96 percent
of acreage in the Northwest (California was not included
because there was too little data). Growers in the Red
River Valley reported using reduced tillage on 16 percent
of sugar beet acres and mulch tillage on 20 percent (Aii,
2004). Because weeds can be effectively controlled with
glyphosate applications, event H7-1 sugar beets may be
6; Duke and Cerdeira, 2007, p. 3; Wilson, 2009).
In the Idaho (Northwest), prior to glyphosate tolerant sugar beets conventional tillage was
essential for weed control, minimizing soil erosion and improving soil structure (Ali, 2004;
Traveller and Gallian, 2000, p. 1). Since the introduction of event H7-1, some farmers in the
Northwest have switched to strip tillage and have reported reduced fuel and labor costs and
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reduced wind erosion (Lilleboe, 2008). Researchers in Idaho found that while conventional
tillage was necessary for weed control with conventional beets, the practice has little to no
benefit with glyphosate-toierant sugar beets (Miller and Miller, 2008).
In much of the Great Plains region, conventional sugar beets were cultivated using conservation
tillage systems; however, deep tillage, which is used to improve drainage, was utilized to help
reduce the risk of soil borne diseases (mainly the beef necrotic yellow vein virus causing
rhizomania) (McDonald et al, 2003, p.2). Farmers in the Great Plains have reported that strip
tilling and event H7-1 have “been a great marriage," with strip tilling resulting in reduced wind
erosion, reduced irrigation requirements and fuel and time savings (Lilleboe, 2010).
Michigan Sugar Company recommends conservation tillage practices to help control erosion
resulting from strong early spring wind in the Great Lakes region (Michigan Sugar Company,
2009, p. 2). However, since the introduction of the event H7-1 this growing region has the
option of implementing varying methods of reduced tillage systems.
Recent studies by North Dakota State University have found that since the introduction of event
H7-1, strip tillage is a viable option for sugar beet production that reduces fuel and fertilizer
costs and susceptibility to wind erosion (Overstreet et al, 2009). A member of the Minn-Dak
Farmers Cooperative, who farms about 1,100 acres of sugar beets annually, has found that
instead of three post-emergence tillage trips across the fields, with event H7-1 he now needs
“little to no tillage post-emergence” (Mauch, 2010, p. 3),
Planting and harvesting times. In all regions except the Far West (California), sugar beet root
crops are planted in early spring (March through May, depending on latitude and location) and
harvested in fall (September through November, also varying with regions) (McDonald et al,
2003; Mikkelson and Petrof, 1999, p 3; Michigan Sugar Company, 2010b).
In the Imperial Valley in California, sugar beets are planted in September and October and
harvested from April to July (California Beet Growers Association, 1999, p. 1).
Crop rotations. Sugar beets tend to be grown with other crops in three- to five-year rotations,
although sometimes two years is used. The rotation results in improved soil fertility, fewer
problems with diseases, and improved yields and quality of beets. The impact of certain soil
borne diseases, nematodes (parasitic, microscopic worms) and weeds are minimized through
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crop rotations (Mikkelson and Petrof, 1999, p. 3; USOA ERS, 2009b, p. 2; Hirnyck et al, 2005, p.
13 ),
To assess the likelihood that the rotational crops planted after event H7-1 sugar beet would be
another glyphosate-folerant crop an analysis of rotations to other crops was conducted and
included in the petition (Schneider, 2003, Table VII-13). This rotational crop table has been
updated with crop information from the 2007 planting season and includes projected acreage for
recently commercialized glyphosate-tolerant crops (Table 2-2).
2.3.4 Sugar beet bolters and volunteers
Bolting. Sugar beet, if left to grow in a temperate climate, is a biennial plant that produces an
enlarged root the first year and flowers in the second year. Typically, the plant is induced to
flower through a process called vernalization that occurs during prolonged exposure to cooler
temperatures. Occasionally sugar beets will bolt (produce a seed stalk that may ultimately
flower) in their first year of production; however, with breeding, bolting tendency has been
reduced. Much effort has gone into producing sugar beets that resist bolting, and today’s
varieties show little bolting (OECD, 2001, p. 15). No difference in bolting characteristics would
be expected between conventional and event H7-1 sugar beets, as the introduction of the
glyphosate tolerant trait does not affect the bolting characteristics of the sugar beet. In the
2000-2001 variety field trials with lines containing event H7-1 reported in the petition, six of 12
event H7-1 sugar beet varieties had 0.00 percent bolters; for those varieties with bolters, the
percentages were 0.03 percent for three; 0.06 percent for two, and 0.19 percent for one. All
entries were established as six row plots forty feet in length with six replications at each location
in 2000, and four replications at each location in 2001 (Schneider, 2003, Table VI-9), Darmency
et al report bolting percents now as low as 0.01 percent (2009, p. 1090). While Darmency et al
were referring to conventional sugar beets, event H7-1 would not affect bolting characteristics,
and breeders continue to select for low rates of bolting.
For bolting to occur, the plants first require exposure to temperatures around 40 to 42 degrees F
(others report 34 to 39 degrees F in the 4 to 5 leaf stage; conditions are variety-dependent),
followed by exposure to increasing day length (12 hours or more). Varieties differ in their
sensitivity to bolting, with easy bolting lines requiring only a few to 1000 hours of exposure to
low temperatures, while bolting-resistant lines may require 2000 hours or more. Beets can de-
vernalize when exposed to high temperatures (OECD, 2001 , p. 15).
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Bolting depletes the root of simple sugars, translocating this stored energy into the above-
ground biomass, making the root woody and worthless as a source of sugar. Bolters are taller
than the rest of the crop. Thus, bolters are effectively weeds within a sugar beet field. The
woody roots that result from bolters can damage harvesting and processing equipment
(Ellstrand, 2003, p. 5-7). For these reasons, growers remove bolters. A bolter is evident in a
field weeks before the seed stalk would flower to produce pollen or seed. Thus, stewardship
can be 100% successful in eliminating any small probability of flowering.
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Table 2-2. Rotational crops following US sugar beet production and an estimation of rotational crops as Roundup Ready® cro
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Table 2-2. Rotational crops following US sugar beet production and an estimation of rotational crops as Roundup Ready® cro
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Table 2-2. Rotational crops following US sugar beet production and an estimation of rotational crops as Roundup Ready® cro
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In the Imperial Valley in California, sugar beets are planted in September, grow through the
winter months, and are harvested the following April through June. Vernalization occurs more
frequently In the Imperial Valley than in the other US regions, where sugar beet is planted in the
spring and harvested in the fall. If the winter in the Imperial Valley is unusually cold and
harvesting is delayed, some bolters can develop {California Beet Growers Association, 1998,
pp. 3-5; Bartsch et al, 2003).
Sugar beet volunteers. Volunteers are plants from a previous crop that are found in
subsequent crops. In most crops, volunteers grow from seeds. If sugar beet bolters are
allowed to go to seed in certain more temperate climates, the seed may sprout and cause
volunteers in later years, in other crops. Groundkeepers are a type of volunteer derived from
vegetative tissue (small roofs) left in the field after harvest, which can grow in the next season if
not controlled.
In most parts of the US where sugar beets are grown, beet roots would not be expected to
survive the winter, and therefore groundkeepers would be of little concern (Panella, 2003).
Cattanach et al., who focused on production in the northern plains and upper Midwest (including
North Dakota and Minnesota), reported that sugar beets could not survive the winter in these
areas (1991).
Sugar beets are not good competitors with other crops. Any that survive can be reservoirs for
beet diseases and good management practices dictate that they be removed (Kaffka, 1998).
2.4 GENE FLOW
Definition. Gene flow has been defined as the “incorporation of genes into the gene pool of
one population from one or more populations" (Futuyma, 1998). Gene flow is a basic biological
process in plant evolution and in plant breeding, and itself does not pose a risk (Bartsch et ai,
2003; Ellstrand, 2006, p. 116).
How gene flow is addressed in this document. In this section we provide some background
information on gene flow, which is included in several different discussions of impacts, as
follows:
• Potential for gene flow from event H7'1 sugar beet crops to conventional sugar beet
crops (Section 3,3)
• Potential for gene flow from event H7-1 sugar beet to crops to organic sugar beet crops
(Section 3.4)
• Potential for gene flow from event H7-1 sugar beet crops to other Beta crops (Section
3,5)
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• Potential for gene flow from event H7-1 sugar beet crops to other Beta seed production
areas (Section 3.6)
• Potential for gene flow from event H7-1 sugar beet crops to native beets (Section 3.7)
• Potential for gene flow from event H7-1 sugar beefs crops to weed beets (Section 3.8)
• Potential for gene flow from event H7-1 sugar beet to any of the above receptors, in
sugar beet seed production (Section 3.9)
Hybridization. In plant biology, when gene flow occurs between individuals from genetically
distinct populations and a new plant is formed, the new plant is called a hybrid (Ellstrand, 2003,
p. 1 0). Hybridization is usually thought of as the breeding of closely related species resulting in
the creation of a plant that has characteristics different from either parent. Usually this occurs
through deliberate human efforts; however, it can also occur indirectly from human intervention,
or in nature. For example, when plants are moved to a new environment (with or without human
intervention), they may hybridize with plants of a closely related species or subspecies in that
new location.
For natural hybridization to occur between two distinct populations, the plants from the two
populations must flower at the same time, they must be close enough so that the pollen can be
carried from the male parent to the female parent, fertilization must occur, and the resulting
embryo must be able to develop into a viable seed that can germinate and form a new plant
(Ellstrand, 2003, pp. 11-13).
Introgression. Hybridization may occur in one generation, but in most cases, does not
continue on its own. If it does, and stable new populations result, the process is called
introgression. For introgression to occur, hybridization of offspring back with the parent types
(backcrossing) must occur several times. Because hybrids of distantly related species may not
produce viable seed, introgression is much less common than hybridization. For example, in
studies done with canola and a weedy relative, backcrossing from the hybrids to the weeds
occurred at one-hundredth to one-thousandth the rate of the original hybridization (reported in
Stewart, 2008, p. 2). Nevertheless, when weed species are introduced to new areas, there is
the potential that those introduced plants may hybridize with other closely related species.
Novel hybrids therefore may be created. In addition, novel hybrids may be created through
back-crossing (i.e. introgression) with parent species which may change the native species with
non-native genetic material. Invasive weeds can result from hybridization events, which mix
genetic material potentially producing a wide array of genotypes. Some of these genotypes
may exhibit increased invasive properties (USDA ARS, 2008).
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Characteristics that favor natural hybridization between two populations when the above
requirements are met include (Mallory-Smith and Zapiola, 2008, p. 429):
• Presence of feral populations (domestic populations gone wild) and uncontrolled
volunteers
• Presence of a high number of highly compatible relatives
• Self-incompatibility
• Large pollen source
• Large amounts of pollen produced
• Lightweight pollen
• Strong winds (wind pollinated)
• Large insect populations (insect pollinated)
• Long pollen viability
Feral populations are discussed in Section 2.9.4, Volunteers, which are plants from a
previous crop that are found in a later crop, are common in agriculture and were discussed in
Section 3.2.3.
Highly compatible relatives of sugar beets present in the US include red table beets, spinach
(or leaf) beets, and Swiss chard (discussed in Sections 3.5, 3.6 and 3.9); and weed beets of the
same or closely related species (discussed in Section 3.8),
Sugar beets and other members of the species B. vulgaris are self-incompatible; that is,
fertilization does not occur between the male and female parts on the same plant. Self-
incompatible plants must outcross: for fertilization to occur, the pollen from the male part of one
plant must be caught by the sticky stigma within the flower of the female part of another plant.
Sugar beets are largely pollinated by wind (Mallory-Smith and Zapiola, 2008, Table 1; OECD,
2001, p. 21). The potential for longer-dislance gene flow increases with higher wind speeds
(Mallory-Smith and Zapiola, 2008, p. 3). Depending on wind conditions, wind-borne sugar beet
pollen can be distributed horizontally at least 4,500 meters (2.8 miles) (OECD, 2001, p. 22),
However, as discussed in Section 3,9, the vast majority of the pollen does not travel these great
distances, and the very small amount that does is unlikely to pollinate another plant.
Successful wind-pollinated flowering plants must produce large amounts of pollen: the
chances of any single wind-blown pollen grain landing on and being held by the stigma of
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another plant are very small. Pollen occurs in “clouds”; scientists have estimated sugar beet
pollen production at one billion pollen grains per plant (Schneider, 1942, as reported in OECD,
2001 , p. 22). There is great competition within this cloud for the limited available ovules (only
one each), and the stray pollen from another source has extremely limited opportunity for
success. In a large, densely planted area such as a seed production field, pollination is much
more likely from the pollen cloud within the field than from stray pollen from another field
(Westgate, 2010, p. 3; Hoffman, 2010a, p. 8)).
While pollen can be maintained for longer periods under laboratory conditions, scientists report
that sugar beet pollen viability under natural conditions is limited to 24 hours (OECD, 2001, p
22; Hoffman, 2010a, p. 8).
2.5 SUGAR BEET WEED MANAGEMENT
This section addresses weed management in sugar beets. Uncultivated wild beets, including
ferai beets and weed beets, are described in Section 2.9.
2.5.1 Weed characteristics and concerns
While a weed can be defined as any unwanted plant, problem weeds are those that are
competitive and persistent within a given cropping system.
Competition for light, water and nutrients. A grower tries to capture the plant resources -
primarily light, water, and plant essential nutrients; however, competitive weeds often secure
some of these resources for their grovrth, at the expense of the crop. Some common
characteristics of competitive weeds are rapid seedling establishment, high growth rates, prolific
root systems and large leaf areas.
Competition for light is probably the most important weed consideration for sugar beets,
particularly in irrigated fields, which promote improved growing conditions. Sugar beets
ultimately convert solar energy into sucrose, and reduction in light can have a dramatic impact
on yields. Thus, weeds that grow taller than sugar beets, especially those with broad leaves,
compete with available sunlight that the sugar beet would have used to make sucrose.
Barnyardgrass {Echinochloa crus-galli), for example, has broad, flat leaves and can grow up to
5 ft tall, as can Canada thistle {Cirsium arvense). Common lambsquarter {Chenopodium album)
and kochia {Kochia scoparia) are fast-growing weeds that can grow to six ft tail and quickly
shade sugar beet seedlings. Wild oat {Avena fatua) and green foxtail {Selaria viridis) grow to
heights ranging from approximately 26 to 41 inches. Sugar beet, by comparison, takes months
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fo reach its final height of approximately 22 inches (Tranel, 2003; McDonald et al, 2003, pp. 9-
12; Mesbah etal, 1994, p. 1).
A plant's ability to compete for water is determined largely by the volume of soil the roots
occupy. Weeds with large root systems are more likely to be detrimental to sugar beets during
periods of water stress. Some perennial weeds can store a multi-year food supply in their roots
(Tranel, 2003; McDonald et al, 2003, pp, -12; Mesbah et al, 1994, p. 1).
Plants that develop a root system early in the season have long roots relative to the part of the
plant above ground and have high uptake potential can compete successfully for nutrients.
Simply applying more fertilizer does not solve the problem and may exacerbate it by stimulating
weed growth; weeds often absorb nutrients faster and in greater amounts than sugar beets
(Mesbah et al, 1994, p. 1).
Weed persistence. Persistent weeds are able to survive year after year on a given piece of
land, in spite of a farmer’s efforts to control them. Some plants are both competitive and
persistent through the production of large numbers of seeds. The bushy wild proso millet
{Panicum miliaceum), for example, shatters upon contact when mature, and can produce 400 to
12,000 seeds per square foot. While high reproductive rates also contribute to a weed's
persistence, dormancy is the most important trait in persistence, Cultivated soils typically
contain thousands of seeds per square meter, waiting for the opportunity to germinate. Some
weed seeds, for example, velvetleaf (Abutilon theophrasti), can remain viable in the soil for up to
50 years (McDonald et al, 2003, p. 12). Many perennial weed species have the ability to
reproduce from root fragments. Canada thistle, for example, has a deep, spreading root system
that can continue to send up shoots after the surface plant has been removed multiple times.
Some weeds have the ability to alter their characteristic in response to stress; for example,
some weeds respond to drought by flowering and going to seed early (Tranel, 2003; McDonald
etal, 2003, pp. 9-12).
2.5.2 Sugar beets and weeds
The sugar beet plant is a poor competitor against weeds, especially from emergence until the
sugar beet leaves shade the ground. Emerging sugar beets are small, lack vigor, and take
approximately two months to shade the ground. Thus, weeds have a long period to become
established and compete. To avoid yield loss from weed competition, weeds need to be
controlled within four weeks after sugar beet emergence and weed control needs to be
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maintained throughout the season (Cattanach et a!, 1991 , p. 6; California Beet Growers
Association, 1999, p. 25; McDonald et al, 2003, p. 13; Mikkelson and Petrof, 1999, p 19).
Uncontrolled weeds that emerge with the crop may cause from 30 to 100 percent yield losses
(California Beet Growers Association, 1999; p. 25; Sprague, 2009), Increasing weed density
causes increasing magnitude of yield loss, although the relationship is not linear: a few weeds
may not affect yield, and at high weed populations the weeds begin competing with one
another. While yield losses are the major concern, weeds create other problems. Late-season
weeds can hinder harvesting operations. For example, infestations of wild mustard can cause
loss of small beets during harvesting. Many weed species host pathogens (curly top virus),
nematodes (sugar beet cyst nematode) and insects (aphids). High levels of weed control are
essential for profitable sugar beet production (California Beet Growers Association, 1999; p. 25;
Mikkelson and Petrof, 1999, p 19; Mesbah et al, 1994). Prior to adoption of event H7-1 sugar
beets, growers regularly used multiple chemical herbicides to attempt to control weeds. (Cole,
2010a, pp. 12-13; Cole, 2010b, pp. 10-14; Kniss, 2010, p. 5; Wilson, 2010a, p. 9; Hoffman,
2010, p. 12),
2.5.3 Problem weeds in sugar beet production
The USDA Agricultural Research Service (ARS) has identified the following weeds as problem
weeds in sugar beets that have previously prevented production of maximum yields to
conventional crops: kochia {Kochia scoparia), pigweed (Amaranthus spp.), common
lambsquarter (Chenopodium album), nightshade (Solanum spp.), common mallow (Malva
neglectaj, cocklebur (Xanthium strumanum), barnyardgrass {Enchinochloa cnis-galli), foxtail
(Setaiia), wild millet (Panicum miliaceum), wild oats (Avena fatua), sowthistle {Sonchus L),
Canada thistle (Cirsium arvense), nutsedge {Cirsium arvense), and dodder {Cuscuta L.) (USDA
ARS, 2008, p 61). Most of these weeds, and others, are present throughout ail the sugar beet
growing regions. Weeds are classified as annual or perennial. An annual is a plant that
completes its life cycle in one year or less and reproduces only by seed. Annuals are further
classified as broadleaf or grass. Perennials are plants that live for more than two years. They
may reproduce by seeds, rhizomes (underground creeping stems) or other underground parts.
Kochia (Kochia scoparia), an annual broadleaf plant, is a member of the Goosefoot family, the
same family as sugar beet. Weeds in the same family as a crop often thrive in the same
growing conditions,
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Pigweed {Amaranthus spp.) is a broadleaf annual that is a weed problem in many crops. There
are several species; redroot pigweed is most common (UC Integrated Pest Management [IPM]
2010 ).
Common lambsquarter (Chenopodium album Jis an annual broadleaf In the same family as
sugar beets. With its rapid growth and large size it quickly removes soil moisture (McDonald et
al, 2003).
Nightshade (Solanum spp.) is a broadleaf annual that grows 6-24 inches tall (McDonald et al,
2003).
Common mallow {Malva neglecia) and cocklebur (Xanthium strumarium) are widespread
broadleaf annuals.
Barnyardgrass {Enchinochloa crus-gaHi, foxtail (Setan'a), wild millet {Panicum miliaceum) and
wild oats {Avena fafua) are annual grasses.
Sowthistle {Sonchus L.) is a perennial plant that reaches a height of 3 to 7 feet and reproduces
by seed and underground roots.
Canada thistle {Cirsium arvense) is a perennial that reproduces by seeds and underground
roots and grows 2 to 5 feet tali. The roots extend several feet deep and some distance
horizontally. Canada thistle is the most prevalent and persistent non-grass weed in Minnesota,
and is the no. 1 noxious weed in Colorado. It is a problem weed in all growing regions.
(Durgan, 1998, p. 8; Colorado Department of Agriculture, undated; McDonald etal, 2003, p. 10).
Nutsedges (Cyparus spp.) are among the most problematic weeds of agriculture in temperate
to tropical zones worldwide. They are difficult to control, often form dense colonies, and can
greatly reduce crop yields. Nutsedges reproduce primarily by rhizomes (UC IPM 2010).
Dodder {Cuscuta L.) is an annual parasitic weed that grows only by penetrating tissues of host
plants to obtain water and nutrients. Each plant produces thousands of seeds that can remain
dormant in the soil for years (UC 1PM, 2010).
Veivetleaf (AbutUon theophrasti) is a broadleaf annual that grows 2-7 feet tall (McDonald et al,
p. 12; USDA 1999a, pp. 18-19).
Ragweed {Ambrosia spp.) are annual broadleaf weeds that can be very competitive with crops.
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2.5.4 Other non-herbicide weed managemerrt practices
In addition to crop rotation and tillage, discussed above, sugar beet growers of conventional
sugar beets have other non-herbicide means to manage weeds. Narrow row widths (22 - 24
inches) are commonly used by both conventional and sugar beet growers and those growing
glyphosate-tolerant sugar beets, for quicker canopy closure {Cattanach et al, 1991; McDonald et
al, 2003; Mikkelson and Petrof, 1999, p. 21). With respect to glyphosate-tolerant sugar beets in
particular, because these crops do not require cultivation (i.e., in-crop tillage), sugar beet
growers are switching to narrow-row production. With narrower rows, glyphoste-tolerant sugar
beets can achieve canopy closure earlier in the growing season, which deprives weeds of
sunlight and therefore retards late season weed growrth (Wilson, 2010b, p. 4). Growers also use
weed-free seed. Additionally, nearly all growers scout their fields for weeds (All, 2004),
2.5.5 Use of herbicides to control weeds
Herbicide use is regulated by EPA under FIFRA, rather than by APHIS, and EPA has granted
glyphosate reduced risk status (Schneider, 2008, p. 4). Herbicides are used by virtually all
sugar beet growers; in 2000 approximately 98 percent of planted acres received one or more
herbicide applications (Ail, 2004, Table 4). Herbicides may be used before the crop emerges
from the ground (pre-emergence) or after (post-emergence). Pre-plant incorporated (PPI)
herbicides are mixed in with the soil before planting. The application method, whether PPI, pre-
emergence or post-emergence, largely determines when the herbicide will contact plants and
the portion of the plant contacted. In selecting a herbicide, a grower must consider, among
other factors, the potential adverse effects on the crop, whether the herbicide is registered for
use on the crop, residual effects that may limit crops that can be grown in rotation, effectiveness
on expected weeds, and cost.
Herbicide mode of action. Herbicides are chemicals that move into a plant and disrupt a vital
process. They are classified according to their mode of action, which is the overall manner in
which the herbicide affects a plant at the tissue or cellular level. Most herbicides bind to, and
thereby block the action of, a specific enzyme.^®
2.5.6 Weed control with conventional sugar beets
Conventional sugar beet growers use the weed control measures discussed above, plus a
variety of herbicides. There are hundreds of commercial herbicides; only a fraction of that total
can be appropriate for use with conventional sugar beet (Table 2-3).
An enzyme is a biological catalyst and is usually a protein. Enzymes are discussed in more detail in Section 3,1.1.
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The Weed Science Society of America (WSSA) has classified herbicides by group number,
based on their mode of action. As shown in Table 2-3, herbicides commonly used with sugar
best include group numbers 1, 2, 3, 4, 5, 8. and 9 (Tranel, 2008, Dexter et al, 1994; Ross and
Childs, undated);
Group 1 herbicides inhibit the action of the enzyme ACCase
Group 2 herbicides inhibit the action of the enzyme ALS
Group 3 herbicides inhibit cell division (mitosis inhibitors)
Group 4 herbicides mimic the plant growth hormone auxin and cause uncontrolled cell growth
(synthetic auxins)
Group 5 herbicides inhibit photosynthesis
Group 8 herbicides inhibit a single key enzyme involved in fatty acid synthesis
Group 9 herbicides inhibit the action of the enzyme ESPSP
Table 2-4 summarizes the effectiveness of the herbicides in Table 2-3 on the important sugar
beet weeds identified by USDA ARS. As the table shows, no single herbicide Is effective on all
weeds. Some of these herbicides can be mixed together and applied at the same time (tank-
mixed). For conventional sugar beets, glyphosate can be applied only pre-emergence. Blank
cells indicate no data were available for that source.
Current practices for weed control in conventional sugar beets include tillage, pre-plant
incorporation of grass and broadleaf herbicides, and in-crop use of grass and broadleaf
herbicide tank mixtures (Dexter and Lueoke, 2003; Dexter and Zollinger, 2003; WSSA, 1994).
Each of these practices has limitations. Cultivation and pre-plant incorporation of herbicides are
associated with narrow windows of application, which is based on a specific weed size or crop
stage (Baker et al., 1982; Baker and Johnson, 1979; Campbell and Janzen, 1995; Fawcett,
1995), Additionally, herbicide performance and crop injury are influenced heavily by soil pH,
target weed size, crop size, air temperature, and irrigation practices. Morever, many of the
currently applied herbicides leave soil residues, whose persistence can impact crop rotation
options in subsequent seasons (Dexter and Zollinger, 2003; WSSA, 1994)
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Conventional weed control options are complex due to the need for several applications of
multiple tank-mixed herbicides to achieve long-term, broad-spectrum weed control. As an
example, a common practice in sugar beet production is to use ''micro-rates" of herbicides
(Dexter and Zollinger, 2003). This is accomplished by tank mixing multiple herbicides at
reduced rates in combination with an oil additive. The components of the tank mixture may
include Betanex (desmedipham), Betamix (phenmedipham + desmedipham), Nortron
(ethofumesate), Upbeet (triflusutfuron methyl), and Stinger (clopyralid); and Select (chlethodim),
if grasses are present. A minimum of three applications is recommended, beginning at the
cotyledon growth stage and followed by weekly applications of this herbicide mixture. The intent
of the micro-rate program is to lower overall herbicide costs and reduce the potential for crop
Injury.
A member of the MInn-Dak Farmers Cooperative, who farms about 1,100 acres of sugar beets
annually, described his conventional weed control system (Mauch, 2010, pp. 2-3):
Prior to planting Roundup Ready® sugar beet, my herbicide regimen for conventional beet
seed was very complicated and labor intensive. Pre-emergence, I used a combination of
Eptam (which is very toxic to the sugar beet) and RoNeet (which is very expensive).
Approximately two weeks after the beet plants emerge, I started spraying a mix of
BetaMix, Betanex, UpBeef, Nortron and Stinger and adjunctives to make the herbicides
stick better to the crops. This would be sprayed four times (approximately once a week).
Even after spraying several times, there were still weeds and I then needed to hire manual
labor to hoe and pull out the weeds.
This description of the complexity of conventional weed control is similar to that provided by
researchers evaluating weed management in sugar beets (Odero et al, 2008). Odero et al
evaluated 20 different weed treatment alternatives for conventional sugar beets and found that
the following treatment yielded the highest net economic return: PPI treatment with Nortron
(ethofumesate), followed by three micro-rate treatments of a tank mixture of Betamix
(phenmedipham + desmedipham) and Nortron (ethofumesate), followed by Outlook
(dimethenamid-P); with hand-hoeing following each herbicide application.
Other researchers have also found that a combination of herbicides plus hand hoeing is
required to effectively control weeds in conventional sugar beets (Dexter and Luecke, 2003).
Hand-weeding is necessary in many situations; however, it is cost-prohibitive as a replacement
for herbicides. USDA data shows that in 2000, conventional sugar beet growers spent an
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average of $94.28/acre for all chemicals (insecticides, herbicides, fungicides, etc.) (Ali, 2004, p.
7). Five-year studies of the cost of hand-weeding sugar beet at the University of California -
Davis, as reported by the California Beet Growers Association, found that the cost of hand
weeding was between $260 to over $650 per acre (California Beet Growers Association, 1999,
p. 29). Using the midyear of 1 996 as the base year, this is equivalent to approximately $373 to
$914 per acre in 2010 dollars, or approximately three to seven times what sugar beet growers
spent on all chemicals. More recently, scientists in Wyoming have found that net returns for
optimal herbicide application combined with hand weeding are more than twice the net returns
for hand weeding alone (Odero et al, 2008, Table 4).
2.5.7 Weed control with event H7-1
In-crop applications of glyphosate can be made from crop emergence up to 30 days prior to
harvest. This flexibility allows the grower a wider window of application, with the application
timing based on weed pressure, not on crop stage. Typically only 2-3 post-emergence
applications of glyphosate are applied with GE sugar beets (Mauch, 2010; Grant, 2010). The
broad spectrum of weed control offered by glyphosate (Table 2-4) reduces the need for tank
mixing with additional herbicides. However, the use of other herbicides in combination with or in
sequence with glyphosate is recommended as needed under specific conditions to address
select weed and/or weed resistance issues.
Monsanto's Technology Use Guide (TUG, 2010, Appendix E) provides specific weed control
recommendations for event H7-1 sugar beet. The TUG recommends the use of "mechanical
weed control/cultivation and/or residual herbicides” with event H7-1 sugar beets, where
appropriate, and “additional herbicide modes of action/residual herbicides and/or mechanical
weed control in other Roundup Ready® crops” rotated with event H7-1 (TUG, 2010, p. 40).
2.6 HERBICIDE RESISTANCE
Herbicide resistance is "the inherited ability of a plant to survive and reproduce following
exposure to a dose of herbicide normally lethal to the wild type” (WSSA, 1998).
Herbicide resistance is a result of natural selection. Plants of a given species are not all
identical; they are made up of “biotypes" with various genetic traits. Biotypes possess certain
traits or characteristics not common to the entire population. Herbicides, that suppress or kill
weeds, can exert selection pressure on weed populations. When a herbicide is applied, the
plants with resistance to it, which had no special survival qualities before the herbicide was
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introduced, become the survivors who are then able to reproduce and pass on their genes.
With repeated application of the same herbicide and no other herbicide or weed control practice,
the resistant biotype becomes the dominant biotype in that weed community. In the mid-1950s.
Harper (1957) theorized that annual, repeated use of any herbicide could lead to shifts in weed
species composition within a crop-weed community. Similarly, Bandeen et al. (1982) suggested
that a normal variability in response to herbicides exists among plant species and tolerance can
increase with repeated use of an herbicide. Indeed, as of June 27, 2010, 341 herbicide
resistant weed biotypes have been reported to be resistant to 19 different herbicide modes of
action (Heap, 2010). Glyphosate-resistant weeds account for S percent of the herbicide
resistant biotypes while weeds resistant to herbicides that inhibit acetolactate synthase (ALS),
such as Upbeet, account for 31 percent of the herbicide resistant biotypes. (Wilson, 2010a, p.
6).
Figure 2-3 shows the increase in herbicide resistant biotypes with time. Among the herbicides
commonly used in conventional sugar beet. Assure II, Poast, and Select are ACCase inhibitors:
Upbeet is an ALS inhibitor; Treflan HFP is a dinitroaniline; Stinger is a synthetic auxin, and
glyphosate is a glycine. Figure 2-3 shows only the number of confirmed resistant biotypes. The
total extent and distribution of resistant biotype varies widely. Details of herbicide resistant
weed in sugar beets are discussed in Section 3.12.
For as long as herbicide resistance has been a known phenomenon, public sector weed
scientist, private sector weed scientist and growers have been identifying methods to address
the problem. For instance, when a farmer uses multiple weed control tools to achieve weed
control, herbicide resistance biotypes will be controlled and the resistance biotype generally will
not become the dominant biotype within a population (Gunsolus, 2002; Cole, 2010a, p. 4). By
contrast, weed resistance is known to occur most rapidly in areas where there is a sole reliance
on a single herbicide used repeatedly over multiple crop generations for the management of a
specific weed spectrum.
When a grower encounters a biotype that is resistant to an herbicide he is using, the grower
must use an alternate method of weed control. Management practices that can be used to
retard the development of resistance, such as those routinely used by sugar beet growers,
include herbicide mixtures, herbicide rotation, crop rotation, and increased cultivation.
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Figure 2-3. Herbicide resistance woridwide
Management practices that can be used to retard the development of resistance, such as those
routinely used by sugar beet grow/ers, include herbicide mixtures, herbicide rotation, crop
rotation, and cultivation. The WSSA reports: “Weed scientists know that the best defense
against weed resistance is to proactively use a combination of agronomic practices, including
the judicious use of herbicides with alternative modes of action either concurrently or
sequentially" (WSSA, 2010b),
2.7 SUGAR BEET SEED PRODUCTION
2.7.1 Variety development
When developing plant varieties for commercial release, plant breeders select individual plants
with desirable characteristics, such as higher yields or pathogen resistance. This breeding
involves transferring pollen from one source plant to fertilize another plant. Once plants with the
desired traits have been selected, a population of those plants with similar characteristics are
classified as varieties.
Commercial sugar beet variety development has been done exclusively by private sugar and
seed companies in the US. Currently these are Crystal/ACH, Hilleshog (Syngenta), Seedex,
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Betaseed (KWS) and SESVanderhave/Holly. As plant breeders continue to develop new
germplasm, the identification of desirable traits (e.g., resistance to specific diseases, high sugar
content, etc.) is incorporated into the development of new varieties. Due to geographic
variability in weather, growing conditions, climate, insect and disease susceptibility vary from
region to region, different varieties are developed for different regions. Sugar beet company
selection committees in each region establish a list of approved varieties based on coded
variety trials, which are designed to give an unbiased evaluation of the genetic potential of all
sugar beet variety entries while other variables (stand, fertility, moisture levels, etc.) are kept
constant. Growers may grow only those varieties that appear on the sugar beet company
approved list for that region. Variety trials insure the use of the most productive varieties to
maximize returns to the growers and sugar companies. Trials last 2 to 3 years and involve
millions of plants each year.
2.7.2 Hybrids and cytoplasmic male sterility
To produce seed for commercial planting of the chosen variety, some crops, such as cotton and
soybeans, rely on the same individual plant to serve as the female (pollen acceptor) and male
(pollen donor) to produce seed. Other crops, such as corn and sugar beet, rely on two different
varieties, called inbreds, to produce hybrid seed that carries traits from both parent lines.
Hybrid varieties typically exhibit greater vigor than the parent lines on which they are based,
resulting in plants with higher yields, better resistance to stress, and other desirable traits.
Once a biotech plant such as event H7-1 has been developed, researchers will use that plant to
breed the biotech trait to other varieties. In breeding sugar beet varieties for future commercial
production, the biotech trait could be maintained on either the male or female plants. For
greater breeding flexibility and efficiency in producing new varieties, plant breeders may prefer
to breed additional varieties fay introducing the biotech trait on male pollinator population of
plants and use those plants to fertilize the same male-sterile female plants (Skaracis and De
Biaggi, 2005). If the biotech trait is only on the female (male sterile) plant with CMS, as
discussed below, that trait cannot be transferred to other plants in order to breed new inbreds.
In hybrid sugar beet seed production, although each plant flower contains both male (the
anther) and female (the stigma) parts, individual plants can be made female-only, or male
sterile. Male sterility results in the failure of plants to produce functional anther, pollen or male
gametes (Hovland, 2010, p. 2). In order for seed multiplication of the male sterile or female
plant to occur, plant breeders develop a partner line (“0-Type") which is genetically identical to
its equivalent male sterile or female line with the exception of its ability to produce pollen. This
Event H7-1
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identical 0-Type is then used as the pollinator (male plant) to pollinate the female plant,
resulting in offspring that will again be male sterile and not produce pollen. This seed, after
meeting quality criteria relative to any impurities, is then used as the male sterile or female basic
seed in the commercial seed production fields. This system is known .as Cytoplasmic Male
Sterility (CMS). It is the system used in many other crops to develop male sterile or female
basic seed lines that do not produce pollen. Using female-only plants in seed production
ensures that the hybrid seed harvested from those plants will be a cross between the two parent
lines. Male and female lines are planted in alternating strips in a sugar beet seed production
field, typically with two to four times as many female rows as male rows to maximize the amount
of seed collected (Hoffman, 2010a, p.5). Cften stecklings (small transplants) are used for the
male lines. After pollination occurs, the male plants are destroyed (Holly Hybrids, 2007). Only
very rarely would a CMS fertile plant produce pollen
and such plants can be identified and rogued.
One producer reports identifying only two pollen-
producing plants within a crop of over eleven million
total plants (Anfinrud deposition, 2010, 178).
In the Willamette Valley, 78.6% of the 2009-2010 seed
crop were grown with the glyphosate-tolerant trait on
the female inbred. These female inbreds are male
sterile because of the CMS trait and thus are bred not
to produce pollen, (Preliminary Injunction Hearing,
March 5, 2010, pgs. 17-18; 25). Therefore, the risk of
transferring the glyphosate-tolerant trait to other plants
from these seed production fields is negligible or zero.
2.7.3 Commercial sugar beet seed production
Willamette Valley
At least ninety-five percent of the Cregon sugar beet
seed production (equal to 70% or more of the total US
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Figure 2-4. Willamette Valley
Source: Givler and Wells, 2001
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Eugene.
1265
production), is in the Willamette Valley, located between the Coast Range and the Cascade
Range (Figure 2-4 at left) (Stankiewicz Gabel, 2010, p. 7). The valley is over 100 miles long.
The climate is cool enough for winter vernalization (prolonged exposure to a minimum cool
temperature for a prolonged period of time that enables the plant to flower) but warm enough for
the roots to live through the winter. Summers are very dry, producing ideal conditions for seed
harvesting. While sugar beet is normally a biennial plant, conditions in the valley are such that
seed can be produced in one year rather than two. Sugar beet seeds are planted in August or
September and vernalize over the winter. The following spring, the plant produces a seed stalk
(bolt). Seeds are harvested in late July to August. One seed company, Betaseed, grows the
basic and commercial seed for its varieties at the southern and southeastern fringes of the
Willamette Valley.. Syngenta develops its varieties elsewhere, and then ships the basic seed to
West Coast Beet Seed Company (WCBS) for the commercial production. SESVanderHave
develops its varieties both in the Willamette Valley and elsewhere, and ships basic seed
produced elsewhere to West Coast Beet Seed Company (WCBS) for seed production. WCBS
is jointly owned by a group of sugar beet seed and sugar companies.
With its unique growing conditions, the Willamette Valley is used for seed production for many
different kinds of seeds. In addition to seeds, many vegetables are also grown in the valley. It
is a major area for production of “most temperate vegetables, herbs and vegetable seeds"
(Wlansour, 1999), Because high quality and seed purity are important to many growers, and
because the valley is the site of varied seed production, sugar beet seed production companies
have worked cooperatively to develop and implement protocols to maintain seed purity and
quality. Most seed companies, including both WCBS and Betaseed, belong to the Willamette
Valley Specialty Seed Association (WVSSA) and follow the guidelines for isolation and minimum
separation distances between fields (Appendix A).
WCBS and Betaseed have developed explicit standard operating procedures and grower
guidelines that are intended to minimize and/or eliminate the possibility of inadvertent seed
mixing (Appendix B).
Maintaining the integrity of seeds
Currently, the WVSSA implements pinning procedures and isolation guidelines for seed
production within the Willamette Valley. Pinning procedures identify the geographic location of
production fields by placing pins and flags on a map. This is used to establish isolation
distances between seed production fields. Additionally, WCBS and Betaseed have instituted
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protocols and management practices to further maintain the integrity of seed which are
essentially the same as required by Item 4 of the interim measures (Section 1.1.3). Seed
production and quality control are a significant cost, to seed companies, and these companies
within the Willamette Valley and throughout seed production areas carefully control growing
conditions and production practices to ensure that seed is pure and of high quality - despite the
fact that quality control in seed production carries significant cost.
WCBS Seed Production. WCBS currently produces much of the sugar beet seed for some of
the sugar beet seed companies.. WCBS obtains basic seed from these sugar beet companies
to further increase these small seed volumes into larger commercial quantities. Management of
these fields and planting locations is controlled utilizing a tracking and tracing system
distinguishing seed lots from the moment of initial delivery of seed, designated for seed
production, to WCBS throughout the subsequent planting and harvest. This management
further continues until the delivery of the finished packaged seed to the customer. Some
companies further incorporate various computerized and digital tracking systems designed to
manage real-time seed batch movement and quality testing. Many of these companies have
sealed packaging and specified color coding designations to further identify seed batches/lots.
(Meier, 2010, p. 3). Similarly, other companies ship event H7-1 sugar beet seed in packages
accompanied by a declarations document that slates the event H7-1 status of the basic seed
(Anfinrud, 2010, p, 2).
WCBS contracts to individual growers for seed production. WCBS prohibits production of a red
beet or Swiss chard seed crop by any WCBS grower in a year in which that grower is producing
sugar beet seed, whether genetically engineered (GE) or conventional. WCBS also prohibits
the sharing of planting, cultivation and harvesting equipment for red beeVSwiss chard and sugar
beet seed, whether they are producing GE or conventional sugar beet seed (Loberg, 2010, p. 2;
also in Appendix B of this ER^^>. In addition, WCBS requires its growers, by contract, to adhere
to minimum isolation distance within a three mile radius of any GT field (Appendix B).
WCBS maintains control of all material, whether GE or conventional, from point of origin to
return of the seed to the seed company (Appendix B). This includes control of the disposal of
any excess GE steckiings that are not used for seed production. When those stecklings are not
used for seed production and remain in the nursery field, such stecklings are uprooted and
These requirements are in the Appendix B WCBS protocol, under the heading "GM Grower Guidelines." While the
title is “guidelines," the protocol is clear that these restrictions are included in WCBS contracts with growers.
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mixed into the soil during tillage for soil preparation for the next crop. Destruction occurs with
this tillage and is followed by chemical control in the subsequent crop. Stecklings that are
removed from the nursery, but are not used, are destroyed or securely disposed. The prevailing
method is returning unused stecklings to the nursery field of origin and subsequent destruction
through standard agricultural practices (physical destruction with tillage and chemical
destruction in the subsequent crop) (Loberg, 2010, p 2; and Appendix B of this ER).
Precleaning of seed at WCBS for shipment to the seed development company takes place in
the dedicated WCBS facility. This process removes sticks, chaff, weeds and the like that may
be contained in the seed when initially harvested. Because WCBS does not handle red beet or
Swiss chard seed, its seed precleaning operations present no opportunity for mechanical mixing
of sugar beet seed, whether conventional or GE, with red beet or Swiss chard seed. In years
when WCBS produces both GE and conventional sugar beet seed, physical separation
requirements and cleaning protocols protect against inadvertent mixing, in 2009, only two
growers produced conventional seed for WCBS. All of this conventional seed was pre-cleaned
at the end of the season, after completion of the pre-cleaning of the event H7-1 seed and after
complete cleaning of the equipment.
After the pre-cleaning, WCBS returns the seeds to the seed development company in sealed
containers with color-coded labeling and shipping documents, which are checked upon arrival at
seed processing facilities. Syngenta, for example, marks each container with a computer-
generated and tracked batch number (Meier, 2010). SESVanderHave labels its event H7-1
seed with an orange triangle. (Anfinrud, 2010, at p. 3).
Betaseed seed production. Betaseed performs its own basic seed production, and like
WCBS, it contracts commercial seed production to individual growers. Betaseed has adopted
standard operating procedures (SOPs) that require all materials to be adequately identified and
tracked through a computerized, bar-coded system from basic seed production to commercial
seed production to final processing and shipping. All Betaseed personnel involved in seed
production are trained in the SOPs and required to sign an acknowledgement that they have
read, understood, and will compiy with the SOPs (Lehner, 2010, p. 10).
Betaseed supervises its commercial seed growers’ practices for conformance with Betaseed's
stewardship requirements. Betaseed's grower contracts provide for such supervision, as well
as Betaseed's right to enter the grower’s fields and take remedial action if the grower does not
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comply with Betaseed's instructions. Betaseed pins all of its commercial seed fields in
compliance with the VWSSA's pinning rules to ensure that isolation distance guidelines are
followed. In addition, Betaseed requires its growers, by contract, to adhere to isolation
distances of four miles from other crops that may cross-poilinate with sugar beets.. Betaseed
also requires growers to clean their equipment before and after harvesting a sugar beet variety,
and to monitor for and eliminate volunteer sugar beets. According to the SOPs, Betaseed
personnel are present for the beginning of every harvest by a commercial grower. Betaseed
provides bar-coded tote boxes into which the harvested seed is placed for transport to
Betaseed's processing facility (Lehner, 2010, pp. 3-5).
Betaseed performs “grow-outs" each year in which it plants samples of its commercial seed lots
to ensure that the seed produces the expected variety of plant. Betaseed’s grow-ouf
observation plot did not produce any off-types this year (Lehner, 2010, p. 3).
Syngenta seed processing. Syngenta processes sugar beet seed in its facility in Longmont,
Colorado that is used only for sugar beet processing; a small percentage of the seed is
processed by third party seed vendors in separate facilities dedicated to sugar beet processing
(facilities where no red beets or Swiss chard seeds are processed). Processing of seed
requires seven months and involves polishing, sorting by size, pelleting, treatment with
fungicides and insecticides required by certain customers, coloring, packaging and shipping to
growers in sealed packages, Syngenta maintains an extensive tracking and tracing system for
every seed lot. This system includes a visual color identification of all RRSB material; a
computerized, real-time record of seed batch movement, periodic germination and genetic
identity testing; and extensive employee training. Syngenta also uses cleaning protocols to
prevent any inadvertent mixing of RRSB and conventional sugar beet seed during processing.
The cleaning process requires the removal of all RRSB seeds from the equipment and the plant
floor. “Chase” seed is used to ensure that all GT seed has been removed from the equipment
(Meier, 2010). with color-coded labels (Meier, 2010).
SESVanderHave seed processing, storage, treating, packaging, warehousing,
transportation and distribution. Neither SESVanderHave, its growers nor its contractors are
involved in any respect in chard or red beet breeding, production or processing.
SESVanderHave's GE protocols require that conventional seed and event H7-1 seed are never
handled or processed at the same time. For example, SESVanderHave does not allow its
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processing contractors to process conventional seed at the same time that they are processing
event H7-1 seed. (Anfinrud, 2010, p. 3),
SESVanderHave receiving/storage of unprocessed seed protocols. SESVanderHave has
additional GE protocols that apply to unprocessed seed shipped from West Coast Beet Seed.
All event H7-1 seed products are identified upon arrival at bulk storage facilities. Shipping
documents from West Coast Beet Seed are used to double check the seeds that arrive in
Sheridan, Wyoming facilities. Also, proper disposal of reject or spilled seed is established by
variety, lot and size. Product is unloaded only after insuring that storage bins and label bins
have appropriate markings (event H7-1 products are labeled with an orange triangle).
(Anfinrud, 2010, p. 3).
SESVanderHave seed processing/storage protocols. Seed processed on behalf of
SESVanderHave by third parties are subject to contractual arrangements that require
compliance by processing contractors with SESVanderHave's GE protocols designed to prevent
mixing of event H7-1 seed with other seeds during the various processing, treating, packaging,
warehousing, transportation and distribution stages. Before dumping seed into the seed
processing line, necessary equipment (conveyors, legs, distributors, storage bins) is cleaned.
Product is unloaded only after insuring that storage bins have appropriate markings (event H7-1
products are labeled with an orange triangle). A key lock and appropriate label is placed on
each bin discharge slide. Once product is in storage bins, the tops of bins are sealed by tinning
pipe. If necessary, unloading equipment is cleaned and seed is disposed of in proper manner
followed by a documented inspection. Bins with event H7-1 products are labeled with an
orange triangle. Processed seed is placed into properly labeled storage totes and clean-down
procedures are followed between seed lots. Rejected seed is disposed in a local landfill. All
event H7-1 seed totes are labeled with an orange triangle. Totes are then transferred to the
warehouse and put in inventory by variety, lot number, warehouse and slot. (Anfinrud, 2010, p.
.3).
SESVanderHave treating and packaging protocols. Product to be primed, pelleted, treated
and packaged is identified. When event H7-1 seed enters any facility under contract with
SESVanderHave, the necessary equipment (legs, distributors, blending system. Delta screen,
treater, conveyors, aspirators, and bagging scale) is thoroughly cleaned before the product is
introduced. All processes require documentation of weights introduced and weights after
contract processing is complete. All contractors have been audited by SESVanderHave
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personnel to assure compliance with GE protocols. Final packaging of event H7-1 seed is done
in approved packages with proper labels. Packaged seed is transferred to the warehouse and
put on inventory by variety, lot, treatment, warehouse, and slot. When treating of event H7-1
seed is completed, if necessary, all treating/packaging equipment is cleaned following clean-
down procedures. Reject seed is disposed of in an appropriate manner. (Anfmrud, 2010, p. 4).
SESVanderHave warehousing, transportation and distribution protocols. Seed to be
shipped is identified by printing delivery orders that identify event H7-1 seed. Warehouse crews
stage loads. Each pallet of event H7-1 seed is identified with a cover sheet. Any broken bags
during transportation are recovered and returned to the originator for proper repair or disposal.
Drivers are informed that event H7-1 seed is present on loads. Sales and marketing personnel
confirm that event H7-1 seed shipments are to approved customer locations {Anfinrud, 2010, p.
4).
SESVanderHave Auditing of Compliance with GE Protocols. SESVanderHave audits its
contractors' compliance with its GE protocols as well as its own compliance to assure that
SESVanderHave's standards of stewardship are maintained. SESVanderHave employees as
well as outside consultants have worked on the audits, which have covered production, storage,
processing, priming, pelleting, coating, packaging, handling, shipping and distribution of event
H7-1 sugar beet seed. (Anfinrud, 2010, p. 4).
Betaseed seed processing. Betaseed processes and packages its own seed for distribution.
Betaseed does not produce or process seed of any Beta species other than sugar beets, so
there is no potential for mixing of GE seed with seed of any other Beta species in Betaseed's
processing facility (Peters, 2010, p. 2).
Betaseed employs a computerized tracking system to ensure that all of its varieties of seed are
kept separate as they are processed. All processing steps are recorded and auditable. Every
box of seed that is processed is accompanied by both a human readable label and a bar-code
containing information about the seed, including whether it is GE or conventional. Seed cannot
be loaded into Betaseed's processing equipment until the bar-code accompanying the seed has
been scanned and the seed is determined to be of the intended variety. In the last two seasons,
Betaseed has only processed one variety of conventional seed (and only a single lot of this
variety in the last season). To avoid the possibility of any mixing of GE seed with the
conventional variety, Betaseed processed its conventional seed before processing any of its GE
seed. Betaseed thoroughly cleans its entire processing system before and after processing
conventional seed (Peters, 2010, pp, 2-4).
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Befaseed also conducts faioassay tests on each lot of seed at least twice as the seed is
processed through its plant to ensure that lots of GM varieties are glyphosate resistant and that
conventional varieties do not contain GM seeds (Peters, 2010, p. 4),
2.8 RED TABLE BEET, SWISS CHARD, AND SPINACH BEET PRODUCTION
2,8.1 Vegetable beet production
In the USDA database, “beets" include red table beets, Swiss chard, and spinach beets (grown
for the leaves). In the following discussion, these products are referred to as “vegetable beets."
In 2007, the most recent year for which published data are available, 8,412 acres of beets were
harvested in the US, on 2,744 farms, for an average of three acres per farm. Approximately 63
percent of the acreage was for processed beets, and the rest for the fresh market (USDA
NASS, 2010b). The total value of vegetable beet production in 1999, the most recent year for
which USDA has data available, was approximately $7 million. Based on the most recent year
for which USDA has both harvested acreage and production value data (1997), the average
value of vegetable beet production per acre was approximately $720, which would be roughly
$1,000 in 2010, adjusted for inflation (USDA NASS, 2010b),
There is little overlap between areas of major vegetable beet production and sugar beet root
production. Over half the 2007 acreage of vegetable beets (59 percent) was in two states, New
York and Wisconsin, where sugar beets are not grown. California harvested 979 acres of
vegetable beets in 2007. All California counties with five or more harvested acres reported are
coastal. Sugar beets are grown only Imperial County in California. Oregon harvested 425
acres of vegetable beets, but no vegetable beet production was reported in the two Oregon
counties with sugar beet roof crops; however, some vegetable beet crops are grown in the
Willamette Valley. One county in Colorado (Larimer), and one county in Michigan (Lapeer),
reported both sugar beet and vegetable beet harvests. No more than 7 acres of vegetable
beets were harvested in any single Minnesota county. Harvested vegetable beet acreage for all
other sugar beet producing states in 2007 was ten acres or less each (Montana, Idaho,
Nebraska, North Dakota, and Wyoming) (USDA NASS, 2010b). Although there is little overlap
in major production areas, based on USDA FSA (Farm Service Agency) data, vegetable beet
crops and sugar beet crops can sometimes be found growing in adjacent fields (Stankiewicz
Gabel, 2010, p. 8).
® These results, which don't distinguish between organic and conventional, are not completely consistent «rlth the
State of California organic results discussed in Section 2.4.3, probably because of variations in the database of
growers repotting.
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2.8.2 Red table beet and Swiss chard seed production
The most comprehensive data currently available for red table beet and Swiss chard seed
production is from the FSA, however, the FSA does not distinguish between organic and
conventional. Also, FSA does not include leaf beet seed production, which is apparently minor.
According to data from the USDA FSA, red table beet seed in 2009 was grown on
approximately 1 ,130 acres, with 92% grown in Washington State, 7% in Oregon and 1% in
California; and Swiss chard seed in 2009 was grown on approximately 186 acres, with 51%
grown in Washington State and 49% in California. Based on FSA data, there are no counties
where both Swiss chard and table beet seed are grown, and only one county, in the Willamette
Valley, where both sugar beet seed and table beet seed are grown, in that county the FSA data
lists only two table beet seed fields. The total FSA-reported red table beet seed production in
Oregon is approximately 79 acres (Stankiewicz Gabel, 2010, p. 7). There is also minor Swiss
chard seed production in Oregon.
Based on older USDA published data, ninety-five percent of US red table beet seed production
(650 to 700 acres) occurs within the small-seeded vegetable seed production area of western
Washington State that includes Skagit, Island and Snohomish counties (See Figure 2-1 for
locations) (Foss, 2007). These data do not exactly match the FSA data because they are for
different years, and planting practices change from year to year.
Neither sugar beet root crops nor sugar beet seed crops are grown in the part of western
Washington where the majority of the US red table beet and Swiss chard seed production
occurs. Very little sugar beet root crop is produced in Washington State; the nearest processing
facility is far to the south, in southern Idaho. In 2008, only one county, Benton reported sugar
beet production (1,600 acres) (USDA NASS, 2010b). Benton County is in the Columbia Basin
on the east side of the Cascade Range. There is no reported production of Beta seeds other
than minor sugar beet in the Columbia Basin.
Due the extreme distance of this sugar beet production area from the Idaho processing facility, it
is very unlikely that anyone would consider growing west of the Cascade range, in the area of
other Beta production. As set forth in Section 2.3.2, transportation costs and proximity to a
processing facility are key limiting factors in where to grow sugar beets.
The locations of red table beet and Swiss chard seed production in California are not known, but
sugar beet root crops are grown only in the Imperial Valley, and these are conventional sugar
beets.
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As discussed in Section 2,7,3, the majority of the US sugar beet seed production occurs in the
Willamette Valley where seed production for the various beet products (sugar beet, table beet
and chard) is divided along geographical lines. Sugar beet seed is grown in the southern and
central portions of the valley, table beet seed is grown in the northern region, and Swiss chard
seed is grown at the margins.^® The total estimated red table beet and Swiss chard seed
production in the Willamette Valley in 2010 is 100 to 120 acres (McReynolds, 2010). Based on
the FSA data, this appears to be all or virtually all of red table beet and Swiss chard seed
production in Oregon.
Commercial seed production for red table beet is similar to that for sugar beet. Seed companies
retain ownership of the seed, the growing crop, and the harvested seed. Growers produce and
harvest the crop, and are then paid the contract price if the resulting seed meets contract quality
criteria, typically an 85 percent seed germination rate and 99 percent purity (Foss, 2007).
Typically, the red table beet crop is planted in seed beds in mid-June. Plants not displaying true
varietal characteristics are removed by hand. In October, the beets are topped mechanically,
dug, placed in windrows, and covered with about one foot of soil to protect the roots against
freezing during the winter. In March or early April, the over-wintered roots (stecklings), are
removed from the windrows and brought to Skagit County for transplanting into production
fields. Exposure of the roots to the winter season in windrows, followed by transplanting into
fields in the spring, vernalizes the stecklings. Seed harvest occurs in late summer and early fall
(August to September). The crop is cut, placed in windrows, dried 10 to 14 days in the field,
and then threshed mechanically to capture the seed (Foss, 2007).
No information for Swiss chard seed production practices was found.
Morton, 2010, p. 149:24-150:20,
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2.8.3 Organic Red Table Beet and Swiss Chard Production
California is the only state for which organic red table beet and Swiss chard production data are
publicly available. In USDA’s reports, red table beets and Swiss chard are included in the “other
vegetable” organic category, California accounts for 76 percent of "other” organic vegetable
production within the sugar-beet producing states, and there is very little or no organic
production of red table beets, Swiss chard, or leaf beets in the four major sugar beet production
states (MN. ND, Ml and ID) (Figure 2-5) (USDA, 2010c). The 2007 acreage and dollar value of
organic red table beets and Swiss chard in California are shown in Figures 2-6 through 2-9. No
data were found for organic seed production of red table beets, Swiss chard or spinach beets.
Source: USDA, 2010c
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Figure 2-6. California acreage of organic beets (non-sugar), 2007
Source: California Department of Food and Agriculture, 2010
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C3REGON:
Legend
□ Less than $1,000
[T] $1,000 to $10,000
$10,000 lo $100,000
H $100,000 lo $165,000
:Si!>iLay(
Figure 2-7. California gross sales of organic beets (non-sugar), 2007
Source: California Department of Food and Agriculture, 2010
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I ^4 a Ja W * ^ da *4a **a a*^ '^a l^a *
|»,!’aii;!*»r'.r t -iVa'* ^.\5X i,t.’*i »
,.5',". .' ’fa'wg
p#il
!sr^i,'^&V!'k£
OREGuK
Less than 1
more than 100
Sisti Rmwjtii
Figure 2-8. California acreage of organic Swiss chard, 2007
Source: California Department of Food ar)d Agriculture, 2010
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Legend
j j Less than SI ,000
[Tj SI ,000 to $10,000
g S10,000 to $100,000
Figure 2-9. California gross sales of organic Swiss chard, 2007
Source: California Department of Food and Agriculture, 2010
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2.9 NATIVE AND UNCULTIVATED NON-NATIVE BEETS
Plants that are native to a particular area or ecosystem are those that are not introduced fay
humans, but occur at those locations without human intervention.
Non-native beets fall into one of three categories; wild plants, weeds and feral beets. Non-
native wild beets are those that that were never cultivated, and grow on their own outside of an
agricuitural/horticultural setting. Weeds, discussed in Section 2.5, included unwanted plants in
an agricultural/horticultural setting. Feral beets are those that were originally domesticated, but
have escaped cultivation and grow on their own.
2.9.1 Native beets
No native members of the genus Beta are found in North America (USDA, 2010a; Mansfeld,
1 986, as reported in OECD, 2001 , Table 3). Thus, all of the Beta species in North America,
both cultivated and uncultivated, were introduced through human intervention from outside the
continent,
2.9.2 Uncultivated wild beets in the US
Beta species in the US and potential for hybridization with sugar beet
The USDA reports two Beta species in the US: Beta procumbens and Beta vulgaris. Some
researchers (e.g., Bartsch and Ellstrand, 1999; Bartsch et al, 2003) consider Beta macrocarpa
as a separate species: however, USDA ARS reports that the designation was changed in 2000
to 6. vulgaris ssp. macrocarpa (USDA/ARS, 2010a). B. procumbens can be artificially crossed
with sugar beet {a B. vulgaris subspecies), but the plants usually die at the seedling stage
(OECD, 2001 , p. 25), In any case, B. procumbus in the US has been identified only in
Pennsylvania, where sugar beet is not grown (USDA ARS, 2010a). Sugar beet hybridizes with
all B. vulgaris subspecies, including B. vulgaris ssp. macrocarpa. The hybrids are all annuals,
flowering in the first year and producing little or no root or sugar yield (Messean et al, 2009, p.
49),
B. macrocarpa (or B. vulgaris ssp. macrocarpa). There is some scientific disagreement
about the compatibility of sugar beet and S. vulgaris ssp. macrocarpa (referred to hereafter as
B. macrocarpa, the terminology in all sources except USDA/ARS 2010a). OECD reports that 8.
vulgaris and B. macrocarpa are fully compatible and the resulting hybrids are vigorous and
fertile (OECD, 2001, p. 24). In contrast. Dr. R.T. Lewellen, a USDA, ARS geneticist who has
worked with sugar beet at the USDA/ARS Salinas Research Station for many years has done
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research on 6. macrocarpa and has concluded that it does not outcross readily to sugar beet.
This is because 6, macrocarpa usually bolts and flowers too early to cause a risk of
hybridization with sugar beet. Additionally, any hybrid of sugar beet and B. macrocarpa would
possess several genetic factors that pose a challenge to the plants' survival in nature. For
example, the hybrid would be mostly pollen sterile and would have disturbed genetic ratios and
growth habit. Finally, because B. macrocarpa is self-fertile, a cross could only be made with
sugar beet by using self-sterile or male sterile sugar beet plants - something which is unlikely to
occur in nature (Panella, 2003),
Other researchers have also found that hybridization between B. macrocarpa and sugar beet is
relatively rare because the flowering times usually do not overlap (Bartsch et al, 2003, p. 108;
McFarlane, 1975 as reported in OECD, 2001, p. 24). In addition, based on genetic studies,
Bartsch and Elistrand (1999) report a “strong genetic differentiation between B. vulgaris and B.
macrocarpa, which supports the notion that the latter is a separate species" and find it
“remarkable" that hybridization between the two “is still possible" (pp. 1126 and 1129).
Sugar beets have been grown in the Imperial Valley since 1932 (Spreckeis Sugar, 2009), As
noted above, the earliest dated collected Beta specimen is from 1938; however, Bartch and
Elistrand reference observations of uncultivated wild beets in the Imperial Valley from 1928
(Bartsch and Elistrand, 1999, p. 1126). When Bartsch and Elistrand did their research in 1998
and found evidence of introgression between B. macrocarpa and S. vulgaris in two percent of
the B. macrocarpa tested, sugar beets had been grown in the Imperial Valley for 66 years.
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Uncultivated wild beets in California
The USDA/ARS has 13 S. vulgaris van
marttima^° and 7 8, vulgaris ssp. macrocarpa
collected specimens in its National Plant
Germoplasm System, all donated in 1985 by
J.S. McFarlane of the USDA ARS Salinas,
California office. The two 8. vulgaris ssp.
macrocarpa samples with collection
information included were both from the
Imperial Valley; one was collected from a
sugar beet field in 1968; collection information
for the other was not noted (USDA/ARS,
2010a). The Consortium of California, which
keeps a database of 16 herbaria (collections
of plant specimens) throughout the state,
documents 172 Beta accessions from 15
counties, collected between 189S and 2006
(counties show in Figure 2-10 at left)
(Consortium of California Herbaria, 2008),
Forty of the specimens are designated 8.
macrocarpa, 1 9 as 8. vulgaris ssp. marilima,
one simply as Beta, and the rest are
designated 8 . vulgaris. Seventeen of the
accessions are from Imperial County: 14 of
these are designated 8 . macrocarpa, one is designated 8. vulgaris, and one was originally
identified as vulgaris and later corrected to macrocarpa. Imperial County collection dates
ranged from 1938 to 1998 (Consortium of California Herberia, 2008). Calflora’s database
includes herberbia records, plus other documented or recorded observations. California
counties with records of 8 . vulgaris or B. macrocarpa are shown in Figure 2-12, along with
sugar beet production areas (shown as blue dots).
Specimens were originally identified as Beta vutgaris ssp. manlima
Figure 2-10. All CA counties with beta
records
Sourea.' Consortium of California Herbaria, 2006
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There have been a number of hypotheses regarding the origin of the California uncultivated wild
beets, including that at least some of them are wild (feral) sugar beefs (Johnson and Burtch,
1959, as referenced in Bartsch and Ellstrand, 1999, p. 1120). However, based on genetic
analysis, Bartsch and Ellstrand (1999) concluded that the uncultivated wild beets in California
have two independent and primary genetic origins, one from European B. macrocarpa (the
uncultivated wild beets found in the Imperial Valley and on the Channel Islands) and one from
European B. vulgaris (beets from all other areas in California where uncultivated wild beets are
found). They found that what they termed the S. macrocarpa of the Imperial Valley and the
Channel Islands were, with the exception of one population, “genetically identical with a Spanish
B. macrocarpa from the Mediterranean area of Cartagena" (Bartsch and Ellstrand, 1999, p.
1126). The singe exception was a population in the Imperial Valley of B. macrocarpa that
showed genetic similarities with B. vulgaris, which led them to conclude that the sugar beet (a
subspecies of B. vulgaris) had introgressed with B. macrocarpa (Bartsch and Ellstrand, p.
1126). Bartsch and Ellstrand concluded that the other uncultivated wild beets in California are
descended from cultivated Swiss chard and red table beets, European sea beets, and
hybridized populations among these (Bartsch and Ellstrand, 1999, p. 1128).
Uncultivated beets in other sugar beet seed or root production regions
One record for uncultivated S. vulgaris was found for Oregon: a specimen collected in 1998
from Corvallis in Benton County, by Andrew A. Duncan (Rice, 2010). Two records for
uncultivated B. vulgaris were found in Michigan, one of which was in Tuscola County, which is in
the Great Lakes Region of sugar beet production (USDA 2010a). USDA shows five counties in
western Montana with B. vulgaris records (Madison, Gallatin, Ravilli, Missoula, Pondera and
Cascade), based on Booth and Wright’s 1996 Flora of Montana (USDA 2010a). None of these
counties are in that part of Montana included in the Great Plains Region of sugar beet
production (Figure 2-2). In addition. Rice (2010), a more updated source, shows no Beta
records for Montana (2010), While there is widespread information about uncultivated beets in
California, no other information was found other than that summarized here for uncultivated
beets in any other sugar beet seed or root production areas. Since these records indicate only
"B. vulgaris" it is not possible to determine from the information whether these plants are sugar
beets or some other subspecies,
in addition, USDA has previously concluded that BetaB. vulgaris only poses a weed issue for
sugar beet crops in the Imperial Valley of California (USDA APHIS, 2005),
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DEFINITIONS
Ecosystem - the complex of a
community of organisms and its
environment
Species - group of organisms all of
which have a high degree of physical
and genetic similarity, generally
interbreed only among themselves,
and show persistent differences from
members of allied groups of
organisms. .
Introduction - intentional or
unintentional escape, release,
dissemination, or placement of a
species into an ecosystem as a result
of human activity.
Native species - with respect to a
particuiar ecosystem, a species that,
other than as a result of an
introduction, historically occurred or
occurs.in that ecosystem.
Alien species - with respect to a
particular ecosystem, any species,
including its seeds, eggs, spores or
other. biological material capable of
propagating that species, that is not
native to that ecosystem.
Invasive species - alien species
whose Introduction does or is likely
to cause . economic damage or
environmental harm or harm to
human health.
Invasive plants - introduced species
that can thrive in areas beyond their
natural range of dispersal. These
plants are characteristically
adoptoble, aggressive, and have d
high reproductive capacity. Their
vigor combined with a lock of natural
enemies often leads to outbreak
problems.
Sources: Executive Order 13112 -
Invasive Species (1999); USDA
National AgrlcuHural Library, 2010.
2.9.3 Weed beets
Beets (genus Beta) generally are not weeds; there are
no Beta species included in the Weed Science Society of
America’s (WSSA) list of 3,488 weeds (2010a). No Beta
species are included among the 1,553 weeds in the
USDA database of invasive and noxious weeds (USDA,
2010b).
Weed beets in European sugar beet production
We discuss the problem of weed beets in European
production fields because it is a concern in Europe and
may raise questions about whether the same issues may
occur in the US, and, if so, what impact the use of event
H7-1 sugar beet would have. Weed beets have been a
serious problem in European sugar beet production since
the 1970s (May, 2001; Desplanque et al, 2002; Ellstrand,
2003). In 2000, some sugar beet fields In the EU were
growing more weeds than beets (Ellstrand, 2003).
Weeds of the same or closely related species as the crop
can present special problems. Their seeds and young
plants may be indistinguishable, and they will have very
similar responses to herbicides. Unlike sugar beefs, the
weed beets flower in the first year, and produce many
seeds. Because they are the same species, any
herbicide that is effective on the weed beet will also
damage or destroy the sugar beet. Thus, the weed
beets must be manually removed, and the grower often
does not find that the weed beets are not sugar beets
until they bolt. The weed beets form a seed bank that
can persist for years. While weed beets and native sea
beets grow in many parts of Europe, the weed beets in
the production fields apparently do not originate from
weeds near the production fields. In the 1 990s, the
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problem was traced to hybridization of weed beets with the sugar beets grown in seed
production areas (Ellstrand, 2003, p. 70-73). Sugar beet and sea beet {S. vulgaris ssp.
maritima) hybridize freely and the resulting progeny are fully fertile. Sugar beet and sea beet
also share a common flowering period. Sugar beets are grown in many parts of Europe, but
seed production occurs mainly in the temperate climate regions of southwest France and
northeast Italy, where weed beefs are also present (Barfsch et al, 2003).
While the sugar beefs and weed beets introgress with each other, and the weed beets and the
native sea beets that grow along much of the Atlantic European and the Mediterranean also
introgress with each other, in a century of sugar beet production, gene flow from sugar beets
has not altered the genetic diversity of wild sea beets in the region, including in the seed
production areas (Barfsch ef al, 2003).
fVeecI beets in the Imperial Valley
In the US, the only reports of weed beets as a problem have been in sugar beet production in
the imperial Valley (Lewellen et al, 2003; Barfsch et al, 2003; Lilleboe, 2009). The weed beet
situation in the Imperial Valley is very different from that in Europe. The weed beets in Europe
originated from seed production fields, where the sugar beet plants and nearby wild beets all
flower at the same time, and the resulting hybrids apparently contaminated the seed supply.
Thus, the European weed beets in sugar beet root production fields originated from the
inadvertent planting of the weed beet seeds along with the sugar beet seeds. In the imperial
Valley, the weed beefs are B. macrocarpa, which were present in the Imperial Valley before the
introduction of sugar beets, and have coexisted with sugar beets since 1 938 with very little
hybridization (Bartsoh and Ellstrand, 1999; Bartsch etal, 2003).
2.9.4 Feral crops
Based on available data, de-domestication has occurred in only a few crops. These feral crops
are of minor importance compared with other weeds (Gressel, 2005). In North America, the
feral plants that cause much of the economic damage are imported horticultural plants; for
example, Japanese privet {Ligustrum japonicum), Japanese honeysuckle {Lonicera Japonica)
and kudzu {Pueraria lobata) (Gressel, 2005).
Scientists from Oregon State University report that there are no feral sugar beet crops in the US
(Mallory-Smith and Zapiola, 2008, Table 1). As discussed in Section 2.5.3, in California, the
only sugar beet growing state with documented beet populations (as opposed to the isolated
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reports from a few other locations), genetic assessment of uncultivated wild beets has not
supported the conclusion that any of these beets are feral crops.
Based on this information, and the poor competitive characteristics of sugar beets, we have
concluded that the existence of feral sugar beet crops in the US is unlikely, and any that might
exist are negligible.
2.1 0 FOOD AND FEED USES OF SUGAR BEET
in addition to producing granulated sugar, sugar beet processing facilities produce a co-product
known as dried beet pulp. Pulp is the dried fiber residue left after most of the sugar has been
extracted from the sliced beets. Dried beet pulp is typically sold as either a shred (with or
without molasses added) or in pellet form for animal feed. Beet molasses is produced in
quantities ranging from 4 percent to 5 percent of the weight of the beets and contains about 50
percent sugar. Beet molasses is used for production of yeast, chemicals and pharmaceuticals,
as well as in the production of mixed cattle feeds (Southern Minnesota Beet Sugar Cooperative.
2010a).
Multiple countries that regulate the importation of biotechnology-derived crops and derived
products have granted regulatory approval to event H7-1 sugar beets for food and feed uses,
including Japan, Canada, Mexico, European Union, South Korea, Australia, New Zealand,
China, Colombia, Russian Federation, Singapore, and the Philippines (FSANZ, 2005;
Monsanto/KWS 2007; Berg 2010). Canada and Japan have also approved event H7-1 sugar
beets for cultivation in those countries (Sato, 2008; CFIA, 2005).
2.1 1 PHYSICAL AND BIOLOGICAL ISSUES
The affected environment for land use, air quality, water qualify, ecology, threatened and
endangered species, and other sensitive wildlife is the area in the sugar beet root producing
areas (shown in Figure 2-1) and in the seed producing region in the Willamette Valley, the seed
producing region (Figure 2-4). The affected environment for climate is global, as impacts on
climate change are global issue.
2.12 SOCIOECONOMICS AND HEALTH
The affected environment for socioeconomic issues includes those individuals or groups who
could be economically impacted if their food, feed, or agricultural products are adversely
affected by event H7-1 . It also includes those who would be economically impacted if event H7-
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1 becomes a regulated article; growers of event H7-1 sugar beets, sugar processors, seed
companies, and sugar marketers and sugar buyers. Potential impacts to the first group are
discussed primarily in Section 3.1 1 and impacts to the second group are discussed in Section
3,16. The potential for health impacts to individuals who may come into contact with
glyphosate-toierant sugar beets or beet seeds, or sugar or other products derived from
glyphosate-tolerant sugar beets is discussed in Sections 3.11 and 3.15. Health effects of
potential exposure to herbicides are discussed in Section 3.15.
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ENVIRONMENTAL CONSEQUENCES
Section 3 of this ER examines the possible impacts of a partial deregulation of H7-1 or similar
administrative action.
3.1 PLANT PEST PROPERTIES AND UNINTENDED EFFECTS
APHIS previously determined, based on scientific analysis and in accordance with its
obligations under the Plant Protection Act, that sugar beet event H7-1 is not a plant pest and
does not exhibit plant pathogenic properties (USDA APHIS, 2005).
APHIS considered the potential for the transformation process, the introduced DNA sequences,
or their expression products to cause or aggravate disease symptoms in sugar beet event H7-1
and its progeny or in other plants. APHIS also addressed the potential for event H7-1 to
become a weed or make other plants that it breeds with into weeds.
APHIS also considered whether data indicate that unintended effects would arise from
engineering of these plants, APHIS considered information from the scientific literature as well
as laboratory and field data collected during the trials with event H7-1 that was provided by
Monsanto/KWS in its petition (included in Schneider, 2003).
Based on the analysis summarized below, there are no impacts resulting from plant pest
properties, introduced or aggravated disease symptoms, or unintended effects under any of the
alternatives. Details of the Monsanto/KWS studies are included in the petition (Schneider,
2003).
3.1.1 Background
Plant genetic modification
Plant genetic modification by humans ranges from the simple approach of selection - where
seeds of plants with desired traits are saved and replanted - to complex methods such as the
use of recombinant DNA (rDNA; see definitions on next page). Crossing (and then recrossing)
two sexually compatible plants by taking the pollen from one plant and brushing it onto the pistil
of another is still the mainstay of modern plant breeding (IM/NRC, 2004). Both conventional
breeding and rDNA methods can involve changes in the sequence, order, and regulation of
genes in a plant and can use many of the same enzymes. However, with conventional breeding
all the tens of thousands of genes in the plant are involved, and with the rDNA method only a
few genes are involved. In classical breeding, crosses can be accomplished only between
closely related species, and therefore only traits that are already present in those species can
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be targeted. In contrast, the rDNA approach can use
genes from any living organism, thus opening the door to
vast potential in trait development (Lemaux, 2008, p, 774;
AM A, 2000).
Other examples of plant genetic modification include cell
fusion (the protective ceil wall is stripped and cells are
fused by some external force) and induced mutagenesis
(inducing mutations in seeds by ionizing radiation or
carcinogenic chemicals) (Ronald and Adamchak p. 88).
Mutagenic techniques, vuhich have been in use since the
late 19205, create random mutations and are limited by
their inability to target a desired trait (FDA, 1992;
Lundqvist, 2009, p. 39).
Agrobacterium
Agrobacterium tumefaciens (Agrobacterium) is a soil
microbe that has been called “nature’s own genetic
engineer” because of its ability to transfer a fragment of its
own DNA into a host plant (AMA, 2000). (See definitions
at right.) The transferred DNA is stably integrated into the
plant DNA, and the plant incorporates and expresses the
transferred genes. The transferred DNA (T-DNA)
reprograms the host plant cells to grow into callus tissue
and produce certain amino acid derivatives that are a food
source for the Agrobacterium. On a macro scale, the
callus tissue growth is called crown gall disease. In the
early 1980s scientists developed strains of Agrobacterium
with T-DNA that lacked the disease-carrying genes
(“disarmed" Agrobacterium). Agrobacterium
transformation system has been utilized in the
development of a large number of genetically engineered
plants in commercial production (IM/NRG, 2004, pp. 28-
29). The method uses a DNA molecule called a vector
DEFINITIONS
nucleotide - basic building block of
nucleic acids such as DNA. Each
nucleotide is made up of a nitrogen-
containing group, a sugar, and a
phosphate group.
Nucleic acid - a chain of
nucleotides.
DNA - deoxyribonucleic acid - a
type of nucleic acid that acts as the
genetic material In most living
things.
Chromosome - a DNA molecule
containing aii or parts of the
genome of an organism, which has
the ability to replicate.
Genome - the complete set of genes
in an organism.
Gene ~ the basic unit of heredity; it
is a segment of DNA on a specific
site on a chromosome.
Amino acid - one of 20 chemical
building blocks for proteins; there
are also nonprptein amino acids.
Catalyst - a chemical that speeds
up a chemical reaction but is not : : :
changed by Che chemical reaction. ■ f
Enzyme - a biological catalyst:
usually a protein.
Recombinant DNA (cDNA)
techniques - procedures used to
join together DNA segments. Under
appropriate conditions, a rDNA
molecule can enter a celt and
replicate there.
Mutation - any change in the base
sequence of DNA.
Diploid - containing two secs of
chromosomes [one from each
parentO.
Sources: Sadava, 2008; II4/NRC,
200'1; biology online; GMO Safely,
2010a.
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that serves as a carrier to insert T-DNA that contains specific genetic elements. These genetic
elements are organized into a gene cassette, which consists of a gene encoding for a single
biological function plus other genetic elements necessary for the expression of that gene when
introduced into the plant. Other elements in the gene cassette include a promoter, which can
be thought of as the "on switch" for the gene encoding for the desired trait; and a targeting
sequence, which makes sure the gene product, typically a protein, ends up in the right location
within the cell (such as the chloroplast).
Unintended effects from breeding
Most crops naturally produce allergens, toxins or other antinutritional substances; these often
serve the plant as natural defense compounds against pests or pathogens (FDA, 1992), Plant
breeders typically monitor the levels of antinutritional substances relevant to their crop. For
example, solanine is a naturally-occurring toxin produced by potatoes and is part of the plant's
defense against insects and fungus. Potato breeders typically monitor solanine levels and
reject lines that generate too much of it (IM/NRC, 2004).
Scientists from the Institute of Medicine (IM) and the National Research Council (NRC) ranked
breeding methods according to their relative likelihood of producing unintended effects, which
they hypothesized would correspond to the degree of genetic disruption associated with the
method. Selection from a homogeneous population was ranked at one end of the spectrum
(less likely to produce unintended effects) and induced mutagenesis (from chemicals or
radiation) was ranked at the other end (more likely). Agrobacterium transfer of rDNA was
among the methods ranked in between (IM/NRC, 2004, Figure ES-1), Recent studies in Europe
comparing transgenic and conventional barley suggest that conventional breeding may cause
more unintended effects than rDNA methods, likely because of the very large number of genes
that are affected in conventional breeding techniques (Sonnewald, 2010). These results are
consistent with those observed by APHIS with event H7-1 and many other plants produced
through rDNA methods: except for the intended trait, the GE plant is found to be substantially
equivalent to its non-GE counterpart.
Giyphosate tolerance
As discussed in Section 2, giyphosate acts by inhibiting the action of the enzyme 5-
enolpyruvylshikimate-3-phosphate synthase, EPSPS, in plants, EPSPS is a catalyst for a
reaction necessary for the production of certain amino acids essential for plant growth. When
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plants are treated with glyphosate the EPSPS enzyme is inhibited, they cannot produce the
amino acids needed for continued growth and eventually die. The EPSPS protein and the
reaction if catalyzes are present in all plants and microbes. There are variations in the amino
acid sequence of EPSPS among different plants and bacteria. Glyphosate tolerance is
achieved by introducing an EPSPS enzyme, termed CP4 EPSPS, that is not inhibited in the
presence of glyphosate. An Agrobacterium strain (designated CP4) was the source of the cp4
epsps gene that encodes for the CP4 EPSPS enzyme (Schneider, 2003). The CP4 EPSPS
enzyme carries out the same enzymatic reaction in the plant as the native EPSPS; however,
when plants that contain the CP4 EPSPS are sprayed with glyphosate, they are able to continue
to produce the essential amino acids needed for plant growth. The objective of the genetic
modification in event H7-1 was to simplify and improve weed management practices in sugar
beet by conferring tolerance to glyphosate.
Transformation system
Event H7-1 was developed using a disarmed Agrobacterium-med'mted transformation of a sugar
beet variety used in plant breeding. Cotyledons (part of the seed embryo) derived from sterile
seedlings of the diploid sugar beet line 3S0057 were used as the explant source. An explant is
any portion of a plant that is to be used to initiate culture. These cotyledons were immersed in
an Agrobacterium suspension and co-cultured for two to four days. The explants were then
transferred to selective media containing 500 mg/I carbenicillin to eliminate the Agrobacteria.
Glyphosate was used for selection of glyphosate-tolerant tissue, with tissue containing a genetic
insertion to confer glyphosate tolerance assigned a unique number, such as event H7-1. After
approximately seven weeks, the developed plantlets were transferred to rooting media and
placed in a greenhouse. All subsequently developed event H7-1 sugar beet breeding lines and
variety candidates were derived by traditional plant-breeding methods (Schneider, 2003, pp, 20-
21).
DNA sequences inserted into sugar beet event H7-1
Data supplied in the petition and reviewed by APHIS (Section V.A,, pp 29-44) support the
conclusion that event H7-1 contains the following gene cassette:
1) a promoter from a modified figwort mosaic virus,
2) targeting sequence from the plant Arabidopsis thaliana,
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3) the EPSPS gene from Agrobacterium sp. strain CP4, and
4) a portion of a gene from pea that directs genetic processing
This same gene cassette is present in other Roundup Ready® cotton and canola, which have
previously been deregulated by USDA (Schneider, 2003, p. 24), The non-coding promoter is
from the plant pathogen figwort mosaic virus. The promoter cannot cause plant disease and
serves a purely regulatory function for the EPSPS gene. The CP4 EPSPS gene does not cause
disease and has a history of safe use in a number of genetically engineered plants (e.g,, corn,
cotton and soybean varieties).
3.1.2 Evaluation of intended effects
Analysis of inheritance
Data was provided and reviewed by APHIS that demonstrates stable integration and inheritance
of the EPSPS gene cassette over several breeding generations. Statistical analyses show that
glyphosate tolerance is inherited as a dominant trait in a typical Mendelian manner (Schneider,
2003, Table V-2, pp. 45-46).
Analysis of gene expression
The level of CP4 EPSPS protein was determined from tissues collected from field trials with
event H7-1 conducted at several locations. Using standard laboratory techniques, protein
concentrations from H7-1 beet leaves and processed roots (brei) were determined (Schneider,
2003, Table V-3, p. 50), EPSPS proteins are ubiquitous in plants and microorganisms and have
not been associated with hazards from consumption or to the environment. Crops that contain
the CP4 EPSPS protein have been granted non-regulated status have included corn, soybean,
cotton, rapeseed and sugar beet (USDA APHIS, 2010a), In 2009, significant acreages of corn
(59 million acres or 68% of the total corn acres), upland cotton (6.3 million acres or 71% of the
total cotton acres) and soybean (70.5 million acres or 91% of the total soybean acres) grown in
the US were planted with herbicide tolerant varieties (USDA NASS, 2010c). Although the data
include all herbicide tolerant varieties, glyphosate tolerant ones (containing CP4 EPSPS)
predominate. All have also undergone FDA review (FDA, 2010).
Analysis of the intended trait
Numerous field trials were conducted in the US (Schneider, 2003, Tables VI-4 to Vl-6} and in
Europe (Schneider, 2003, Table VI-7) to evaluate event H7-1 in different genetic backgrounds
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and in different environments. Standard field trials evaluated 1) agronomic performance, 2)
disease and pest resistance performance, 3) steckling (seedling) production and 4) seed
multiplication. Standard industry farming practices for the various locales was used in these
trials. These practices would typically include control measures for weeds, diseases and
insects. Where glyphosate was used in trials, no negative impacts from application glyphosate
were noted.
3.1.3 Evaluation of possible unintended effects
Disease and pest susceptibUify
In trials conducted from 1998 to 2002, qualitative and quantitative data addressing disease
susceptibility and overall agronomic performance of event H7-1 were collected to assess
possible effects from introduction of the CP4 EPSPS gene cassette. As summarized below,
information collected from these trials indicate that event H7-1 does not alter sugar beet's
susceptibility to diseases and pests. Experience in production fields since 2007 supports this
conclusion.
Nursery trials in US. During the 2000 and 2001 growing seasons, quantitative data was
collected from variety trials at Betaseed nurseries for comparison of varieties with event H7-1 to
conventional varieties for relative resistance to four common sugar beet diseases: Cervaspora
leaf spot, Aphanomyces root rot, Rhizoctonia root rot, and curly top virus. In these trials, results
of season-long testing for disease susceptibility from one to three varieties with the H7-1 event
were compared with four conventional varieties. The results indicated that the disease
susceptibility of the H7-1 varieties was within the range of the conventional varieties (Schneider,
2003, Section A.1),
Field trials in US. A total of 98 separate Monsanto/KWS field trials were conducted in the US
from 1 998 to 2002 included comparative evaluation of susceptibility to the four diseases
evaluated in the nursery trials, plus several fungal seedling diseases and Rhizomania
(Schneider, 2003, Section VI.A.2), Together, these are the major diseases of economic
importance affecting sugar beet production in the US (Schneider, 2003, p. 60). At all but six trial
locations there were no differences observed between the event H7-1 varieties and the
conventional comparators. At one trial site increased susceptibility to powdery mildew was
noted while at three other sites decreased susceptibility was noted. At two trial sites increased
susceptibility to Cercospara leaf spot was also noted. Given the interactions between the
environment, the genetic backgrounds of the cultivars used and some inherent genetic
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variability within sugar beet varieties, these results are not unexpected and do not indicate an
increased pest risk. A similar likefy insignificant difference was noted in a greenhouse trial using
different Fusarium fungus isolates. Other researchers have suggested that it may be difficult to
predict field results from greenhouse/ laboratory experiments control lines or differences outside
the range of conventional sugar beet norms.
Field trials in Europe. Additional field trials were conducted with event H7-1 in Europe in 1998
and 1999 and monitored for several diseases and nematode worms. No diseases or nematode
symptoms were reported in any of the trials for either event H7-1 or conventional control sugar
beets (Schneider, 2003, Section A,3).
Gene silencing
In evolutionary biology, a homologous trait is one derived from a common ancestor that appears
in multiple species. Homology may be manifested on a macro scale, for example, in the
similarity in mammal forelimbs, and on a genetic scale, in DNA sequences. Al-Kaff, et al.(1998)
have noted gene silencing effects when transgenic plants have been infected by a virus with
DNA sequence homology to a portion of the introduced genes. The only virus-derived DNA in
the event H7-1 gene cassette is the promoter, which is from the figwort mosaic virus. None of
the viral diseases of beet is related to figwort mosaic virus (Whitney and Duffus, 1986) so
silencing of the EPSPS gene would not be expected, and has not been observed.
Compositional evaluation
Monsanto/KWS compared the composition of event H7-1 sugar beets with conventional sugar
beets derived from the same parent line (“near isogenic control line”). To eliminate the influence
of normal genetic variation between different hereditary lines and varieties, isogenic lines are
usually used as a standard for comparison (GMO Safety, 2010a). The analysis of H7-1 sugar
beets for compositional changes was included in Section VI. C of the petition (Schneider, 2003)
and was also part of the Monsanto/KWS submission to FDA in the consultation process (See
Section 3. 1 1 for a discussion of the FDA consultation process and results). While FOA uses
these data as indicators of possible nutritional changes, APHIS views them as a general
indicator of possible unintended changes.
Compositional analyses evaluating carbohydrates, proteins, fiber, fat, sugars, the anfinutrient
saponin, and eighteen amino acids (a total of 55 statistical comparisons) in tops (leaves) and
roots (brei) identified seven statistically different values compared with the near isogenic control
line. All analyses fell within the range of values observed for both the near isogenic control line
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and conventional sugar beet varieties, providing additional evidence that event H7-1 sugar beet
does not exhibit unexpected or unintended effects (Schneider, 2003).
3.2 WEEDINESS PROPERTIES. VOLUNTEERS AND FERAL CROPS
This section addresses two questions'.
1 . What are the weediness properties of sugar beet?
2, Is the event H7-1 sugar beet more likely to become a weed than a conventional sugar
beet?
3.2.1 Weediness properties of sugar beet
As discussed in Section 2.5, sugar beets (8. vulgaris) are poor competitors with both weeds and
other crops (i.e., beet can compete only with members of their own species). This is discussed
in Section 3.8.
3.2.2 Event H7-1 sugar beet and weediness
Some scientists, for example, Ellstrand, 2006, have raised the question of “unintended crop
descendents from transgenic crops." Ellstrand states (p. 116): “The possibility of unintended
reproduction by transgenic crops has raised questions about whether their descendents might
cause problems. These problems have fallen into two broad categories: first, the direct feral
descendents of the crops may prove to be new weeds or invasive plants, and second, that
unintended hybrids between transgenic crops and other plants could lead to certain problems."
This section discusses the weediness properties of H7-1 sugar beet, and addresses the
concern of direct descendents of the crop that “may prove to be new weeds or invasive plants.”
Hybridization is addressed in several later sections.
Event H7-1 was field tested in North America from 1998 to 2003 and in Europe from 1998 to
1999. In these trials, no differences were observed between H7-1 lines and non-transgenic
lines with respect to the plants' ability to persist or compete as a weed (Schneider, 2003; USDA
APHIS, 2005). In these evaluations, APHIS considered data relating to plant vigor, bolting,
seedling emergence, seed germination, seed dormancy and other characteristics (USDA
APHIS, 2005).
In a separate evaluation, the Canadian Food Inspection Agency (CFIA), whose responsibilities
include regulation of the introduction of animal food and plants (including crops) to Canada,
reached the same conclusion about the weediness potential of event H7-1 compared with non-
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transgenic sugar beet. In 2005, the CFtA authorized fine “unconfined release Into the
environment and livestock feed use of the sugar beet event H7-1’' (CFIA, 2005). In its
evaluation of event H7-1 . CFIA "determined that germination, flowering, root yield, susceptibility
to plant pests and diseases typical to sugar beet and bolting percentage were within the normal
range of expression of these traits currently displayed by commercial sugar beet hybrids” (CFIA,
2005). The CFIA reached the following conclusions (CFIA, 2005):
No competitive advantage was conferred to these plants, other than that
conferred by tolerance to glyphosate herbicide. Resistance to Roundup®
agricultural herbicides will not, in itself, render sugar beet weedy or invasive of
natural habitats since none of the reproductive or growth characteristics were
modified.
The above considerations, together with the fact that the novel traits have no
intended effects on weediness or invasiveness, led the CFIA to conclude that the
H7-1 sugar beet event has no altered weed or invasiveness potential compared
to currently commercialized sugar beet.
Thus, the potential for event H7-1 to become a weed or invasive plant was determined to
to be no greater than conventional sugar beets. Neither sugar beefs or other beta
species plants are considered a weed issue in any state other than California.
3.2.3 Sugar beet volunteers
Volunteers, which are plants from a previous crop that are found in a later crop, may result from
bolters or groundkeepers. Refer to Section 2.3.4 for a detailed discussion.
Root production
While several scientists have reported that volunteer glyphosate tolerant plants could in theory
become a problem in rotational crops when both rotational crops are glyphosate tolerant, none
provided specific information or data relevant to sugar beets (e.g., Cerdeira and Duke, 2006;
Owen and Zelaya, 2005; York et al, 204; NRC, 2010). Since sugar beet is grown for the
vegetable and not the seed, volunteers in a root crop could occur only from the rare plant that
has bolted, if it is allowed to go to seed. Groundkeepers are cold sensitive and only rarely
survive winter conditions in most sugar beef production areas (Grant, 2010, p. 7; Cattanach et al,
1991; Panella, 2003).
As discussed in Section 2.3.4, bolters deplete the sugar content of the root and cause problems
with harvesting. Thus, good management practices and the grower’s own interest dictate
removal of bolters. Sugar beet varieties are specifically bred to make bolters rare. Volunteers
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are unlikely even if bolters are not removed because a series of unlikely events must each
coincide to produce volunteers. If a bolter is not removed, it must be pollinated by another
bolter, and be allowed to go to seed; the seed must then survive the winter freeze and
germinate. And even if this does occur, the resulting volunteer would need to successfully
compete with the next year's crop, and could be controlled by mechanical means or by several
registered herbicides other than glyphosate that can be used on sugar beef volunteers (Meister,
2009). Depending on the rotation crops chosen to follow sugar beet (in the normal 3-4 year
rotation), growers can use tillage and/or herbicides. Examples of some herbicides are
methylsulfuron methyl, 2,4-dichlorophenoxyacetic acid (2,4 D) and 3,6-dichtoro-o-anisic acid
(dicamba) for the control of any volunteers prior to planting and after crop emergence.
Seed production
Control of volunteers is more of a concern with seed production, for both conventional and event
H7-1 sugar beef, to maintain seed purity. As discussed in Section 2.7.3, WCBS and Betaseed
control all seed production in the Willamette Valley. WCBS has detailed requirements in it
protocol (in Appendix B of this ER) for post- harvest field management. After harvesting, the
fields are shallow tilled and irrigated to promote sprouting of shattered seeds (unless sufficient
rainfall to promote sprouting has occurred). Fall plowing is not allowed. After the seed is
allowed to sprout, it is controlled by herbicides or other means. All equipment is cleaned
according to WCBS procedures before it leave the fields. Fields used for growing event H7-1
are inspected by WCBS “for a minimum of five years or until no volunteers are noted (Appendix
B). Betaseed has similar requirements.
3.2.4 Impact summary
Alternative 1
Under Alternative 1 , there would be no impact from event H7-1 1 on weediness or volunteers.
Alternative 2
Weediness properties. Based on the information summarized in the subsection, APHIS has
concluded that sugar beet does not exhibit weediness properties, and that event H7-1 does not
exhibit any altered weediness properties when compared with conventional sugar beet.
Therefore, Aiternative 2 would not impact the weediness characteristics of sugar beet.
Feral crops. As explained in Section 2.9, the existence of feral sugar beet crops in the US is
highly unlikely, and any population that may exist would be negligible. Because there are no
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known or suspected feral crops of sugar beets in the US, Alternative 2 would not impact feral
sugar beet crops.
Volunteers in root crop fields. Volunteers resulting from root crops are generally not a
concern because the crop is harvested in the vegetative stage, bolters are generally rogued
(removed), and the occasional volunteer would be unlikely to survive the winter freeze and
could be controlled by other means than glyphosate. The interim measures further reduce the
potential for any volunteers resulting from a root crop by requiring complete control of bolters.
Under the proposed interim measures, all event H7-1 root crop growers will have measures in
place that require them to survey, identify, and eliminate any bolters in their root crop fields
before they produce pollen or set seed (Item 5). Therefore, no or negligible impacts from event
H7-1 volunteers in root crop fields would be expected under Alternative 2.
Volunteers in seed production fields. Managing volunteers in seed production fields is an
important part of seed growers' efforts to maintain seed purity. WCBS and Betaseed have
protocols in place to force same-year sprouting of seed left behind in the production field, plus
long-term monitoring (five years for WCBS) of production fields to identify and remove any
volunteers. The interim measures contain a universal requirement to force same-year
sprouting, of any event H7-1 seed left behind in the production field, and subsequent removal
and destruction of plants (Item 4.j): 3-year monitoring of fields for volunteers along with removal
and destruction (Item 41); employee training (Item 4k); recordkeeping to document compliance
(Item 4m); and third-party audits for compliance (Item 7), Given the existing industry standards
coupled with the mandates of the interim measures to control volunteers, no or negligible
impacts from event H7-1 volunteers in seed production fields would be expected under
Alternative 2.
3.3 IMPACTS OF EVENT H7-1 SUGAR BEET ROOT CROPS ON
CONVENTIONAL SUGAR BEET CROPS
This section considers the possibility of impacts from event H7-1 sugar beet crops on
conventional sugar beet crops through gene flow (refer to Section 2.4 for a general discussion
of gene flow), or by mixing in harvesting, transportation, stockpiling, or processing.
3.3.1 Pollen sources in production fields
As discussed throughout this document, in production fields sugar beets are grown for their
roots and are harvested before they flower. The only sources of event H7-1 pollen in production
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fields would be from uncontrolled bolters. Refer to Section 2.3.4 for a detailed discussion of
bolting.
3.3.2 Potential for gene flow in root production fields
Because sugar beets are harvested in the vegetative stage, before they flower, there is little
potential for cross-pollination between root production fields. Cross-pollination, if it occurred
could potentially result in adventitious Cmadvertent) presence of genetic material from the crop in
one field into a nearby crop’s field. Scientists from Oregon State University report that for sugar
beet "gene flow via pollen or seed in root production fields is generally not an issue* (Mallory-
Smith and Zapiola, 2008, p. 433). Messban et al concur; "the potential for adventitious
presence of GM material in non-GM sugar beet production is low through cross-pollination since
the hanrest is vegetative" (2009, p. 49). The European Commission (the executive body of the
European Union [EU]) Scientific Committee on Plants (2001) also assessed the potential for
adventitious presence of event H7-1 sugar beet at various stages of farm production. The
Committee identified seed production as the major potential source of adventitious presence,
with other sources, including planting, cultivation, cross-pollination, volunteers, harvesting and
production ail with no or minor potential contributions (p. 8).
Because pollen dispersal is a concern with sugar beet seed production, it is discussed in detail
in the analysis of impacts in seed production (Section 3.9). The Section 3.9 discussion
evaluates distances over which cross pollination may occur; this is an issue with little relevance
to root production.
3.3.3 Potential for mixing of event H7-1 and conventional sugar beets
As discussed in Section 2,2, 95 percent of sugar beet seeds planted in the US in 2010 were
glyphosate-tolerant. Except in California, where only conventional sugar beet has been grown
to date, production, processing and marketing within the industry no longer distinguishes
between event H7-1 and conventional sugar beet crops — ^they are processed and marketed
together. The 22 sugar beet processing facilities in the US process a combination of event H7-1
and conventional sugar beets. As discussed in Section 2.3, no currently operating sugar beet
processing facilities have been built in the US since 1975. Because a processing facility is
required for sugar production, the 22 processing facilities account for all the beet sugar
produced in the US. Markets have been available for the sugar, beet pulp, molasses and other
products (Kaffka and Hills, 1994, p. 2; California Beet Growers Association, 1998; Western
Sugar Cooperative, 2006a; Michigan Sugar Company, 2010b; American Crystal Sugar
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Company, 2009; Minn-Dak Farmers Cooperative, undated; Snake River Sugar Company,
2009).
3.3.4 Consequences of gene flow in production fields
We have found no reports of cross-pollination between event H7-1 sugar beet root production
fields and conventional sugar beet crops since event H7-1 sugar beets were first grown in
production fields in limited quantities the US in 2006. As discussed above, because sugar beets
are harvested in the vegetative stage, bolters are uncommon, and it is good management
practice to remove bolters, pollen movement, or gene flow between event H7-1 and
conventional crops is expected to be minimal.
If bolters occurred in two nearby fields, one with event H7-1 and one with conventional sugar
beets, and the bolters were not controlled and were allowed to flower, a conventional plant
could potentially become fertilized with event H7-1 pollen, and the resulting seeds may contain
the event H7-1 trait. This occurrence would not affect the conventional sugar beet crop
because it would be harvested before these new resulting seeds grew into sugar beet plants, if
they did. If the seeds germinated and the resulting plants survived the winter, which is unlikely
in most sugar beet production areas, the volunteer plants would appear in the conventional
sugar beet farmer’s next rotational crop, and (if they survived) would be treated as weeds, as
described in Section 3.3, and would be eliminated.
There is evidence that growers pay close attention to bolters. All growers that submitted
declarations in the sugar beet litigation declared that bolters are easy to spot in their fields and if
seen they would destroy them. There is no evidence that we have seen to the contrary. Any
conventional sugar beet grower concerned about this occurrence could prevent it by controlling
bolters in his sugar beet crop, which is normally stewardship for any sugar beet crop.
3.3.5 Potential consequences from mechanical mixing
With the exception of the Imperial Valley where only conventional sugar beets have been
grown, grown, commingling of harvested beets from H7-1 seed and conventional seed has
occurred since 2007, with no consequences.
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3.3.6 Impact Summary
Alternative 1
Under Alternative 1 , there would be no gene flow impact from event H7-1 root crop production
to conventional sugar beet crops.
Alternative 2
Gene flow. Even without the interim measures, impacts from event H7-1 sugar beet root crops
to conventional sugar beet root crops have not occurred and would not be expected because: 1)
sugar beets are harvested in the vegetative stage, before they flower; 2) if bolting and cross-
poliination occurred in nearby fieids, the root crop would not be affected; 3) any conventional
grower who wanted to be certain of preventing cross pollination couid do so by controlling
bolters in his own root production fields; 4) a volunteer event H7-1 hybrid appearing in a
subsequent crop resulting from cross pollination in root production fieids can be controlied using
standard weed control practices and would not likely sun/ive the winter in most growing areas in
any event.
The interim measures further reduce the potential for gene flow from event H7-1 root crops to
conventional roof crops by requiring complete control of bolters. Under the proposed interim
measures, commercial event H7-1 root crop growers will have measures in place that require
them to survey, identify, and eliminate any bolters in their root crop fields before they produce
pollen or set seed (Item 5). Item 6 of the interim measures requires event H7-1 processors or
cooperatives to survey, identify, and eliminate any bolters in outdoor storage before they
produce pollen or set seed. Therefore, no or negligible impacts from gene flow from event H7-1
sugar beet root crops to conventional sugar beet root crops would be expected under
Alternative 2.
Mixing of harvested beets. Currently, by mutual agreement among growers, cooperatives,
processors and marketers, event H7-1 sugar beets and conventional sugar beets are harvested,
transported, stockpiled, processed and marketed without distinction in all areas except
California, where event H7-1 sugar beet has not been grown. No impacts have occurred and
none are expected. Through the interim measure (Item 1) prohibiting planting of event H7-1 in
California, this status quo will be maintained. Therefore, under Alternative 2, no impacts are
expected resulting from mechanical mixing of event H7-1 and conventional sugar beets.
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3.4 IMPACTS OFOF EVENT H7-1 ROOT CROPS ON ORGANIC SUGAR BEET
CROPS
Based on all available information, we have concluded that there is essentially no organic sugar
beet production in the US, The only reference to organic sugar beet production we found was
from the State of California, where 0.02 to 0.03 acre of sugar beet production in Los Angeles
County was reported from 2002 to 2007, with most recent annual sales of five dollars (California
Department of Food and Agriculture, 2010). California is by far the largest producer of organic
commodities in the US, accounting for approximately one-third of sales in 2008 (USDA, 201 Oc,
Table 1). USDA tracks production of a number of organic crops, but not organic sugar beets.
Although no other information was found, similar production may be occurring in other states.
We have found no other information about organic sugar beet production in the US. As
discussed in Section 2.3, all the commercial sugar beet grown in the US is processed into sugar
at one of the 22 processing facilities, none of which process organic sugar beets,
3.4.1 Impact summary
Based on the above discussion, neither alternative would be expected to result in impacts to
organic sugar beet production, because there is essentially zero organic sugar beet production
in the US.
There is a substantial European organic sugar beet business, and American organic farmers
may in the future decide to grow organic sugar beets. This would most likely be small-scale
production, as no processing facility would be available. The presence of event H7-1 sugar
beet would not inhibit the development of an organic sugar beet industry. As discussed in
Section 3.4, a grower of organic sugar beets could ensure no cross-pollination from event H7-1
fields by controlling any bolters in his sugar beet crop. As discussed in Section 3.9, organic
sugar beet seed is available from European suppliers. Therefore, Alternative 2 is not expected
to result in impacts to organic farmers who may choose to grow sugar beets in the future.
3.5 IMPACTS OFOF EVENT H7-1 ROOT CROPS ON OTHER BETA (NON-
SEED) CROPS
The cultivated forms of B. vulgaris, including sugar beet, red table beet, Swiss chard, and
spinach (leaf) beets are all varietal members of the subspecies vulgaris {B. vulgaris ssp.
vulgaris) (OECD, 2001, Table 2). They are all biennial and all are sexually compatible with
sugar beets (OECD, 2001). Whether grown for leaves or roots, beet crops are all harvested in
their first year before they produce seed. In addition, as discussed in Section 2.8.1, there is
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virtually no overlap between sugar beet root production areas and major areas of production of
other Beta crops.
Most growers purchase seed for their table beet crops; however, a few organic gardeners may
allow part of their crop to vernalize then to go to seed and then save the seed for replanting. If a
sugar beet production root crop was grown close to a table beet crop that was allowed to go to
seed and the sugar beet crop had uncontrolled bolters that flowered at the same time as the
other beet crop, there would be some very small potential for hybridization between the sugar
beet and other beet. Based on the discussion in Section 3,3, this occurrence would be
expected to be exceedingly rare and unlikely to occur. The situation would be no different for
event H7-1 or conventional sugar beet. There is no indication that this has occurred since wide
scale H7-1 beef root production began in 2008.
3.S.1 Impact summary
Alternative 1
Under Alternative 1 , there would be no impacts from event H7-1 root crop production on other
Beta crops.
Alternative 2
Assuming no interim measure provisions, impacts from event H7-1 sugar beet root crops to
conventional sugar beet root crops have not occurred and would not be expected because: 1)
sugar beets are harvested in the vegetative stage, before they flower; 2) if bolting and cross-
pollination occurred between event H7-1 and other Beta vegetable crops, the harvested crop
would not be affected; 3) any grower of Beta vegetable crops who wanted to be certain of
preventing cross pollination could do so by controlling bolters in her own vegetable crop fields;
4) a volunteer event H7-1 hybrid appearing in a subsequent crop resulting from cross pollination
can be controlled using standard weed control practices and 5) major production of sugar beet
root crops and other Beta vegetable crops do not coincide. In addition, among the sugar beet
production areas, organic Beta vegetable growers, who may sometimes save their own seed,
are concentrated in California, where only conventional sugar beet is grown.
The interim measures further reduce the potential for gene flow from event H7-1 root crops to
other Beta vegetable crops by requiring complete control of bolters. Under the proposed interim
measures, all event H7-1 roof crop growers will have measures in place that require them to
survey, identify, and eliminate any bolters in their root crop fields before they produce pollen or
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set seed (Item 5). Item 6 of the interim measures requires event H7-1 processors or
cooperatives to survey, identify, and eliminate any bolters in outdoor storage before they
produce pollen or set seed. Therefore, no or negligible impacts from gene flow from event H7-1
sugar beet root crops to other Beta vegetable crops would be expected under Alternative 2.
The prohibition on growing event H7-1 in California (interim measure Item 1), where the majority
of the organic Beta vegetable crops in sugar beet production areas is grown, will further reduce
the potential for any impact.
In the multiple years of cultivation to date of GT sugar beet on a wide scale, there are no
indications that gene flow has occurred.^’
3,6 IMPACTS OF EVENT H7-1 SUGAR BEET ROOT CROPS ON OTHER BETA
SEED PRODUCTION AREAS
As discussed in Section 2.8, nearly all red table beet and Swiss chard seed production occurs in
western Washington State and in California, where event H7-1 sugar beet root crops are not
grown. A small amount of red table beet and Swiss chard seed production occurs in the
Wllamette Valley, where sugar beet root crops are not grown. Spinach beet seed production, if
it exists separately from red table beet and Swiss chard production, is apparently very small.
3.6.1 Impact summary
Alternative 1
Under Alternative 1 , there would be no impacts from event H7-1 production on other Beta crops.
Alternative 2
Even without the interim measures, impacts from event H7-1 sugar beet root crops to seed
production areas for red table beets and Swiss chard (other Beta seed crops) have not occurred
and would not be expected because: 1) sugar beets are harvested in the vegetative stage,
before they flower; 2) seed production for red table beets and Swiss chard does not occur in or
near the same geographic areas as event H7-7 sugar beet root production.
Even if the unlikely event there were isolated areas of other Beta seed crops outside the main
production areas (seed savers) and near sugar beet root crops, the interim measures further
reduce the potential for gene flow from event H7-1 root crops to other Beta seed crops by
requiring complete control of bolters. Under the proposed interim measures, all event H7-1 root
^’HoferDed. (Okl #48)f 14; Berg DecI, (Okt. #39) H 15; Grant Decl. {Dkt #45) H 18; Lehner Deol. (Dkt #252)11
6 .
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crop growers will have measures in place that require them to survey, identify, and eliminate
any bolters in their root crop fields before they produce pollen or set seed (Item 5). Item 6 of the
interim measures requires event H7-1 processors or cooperatives to survey, identify, and
eliminate any bolters in outdoor storage before they produce pollen or set seed. Therefore, no
or negligible impacts from gene flow from event H7-1 sugar beet root crops to other Beta seed
crops would be expected under Alternative 2. The prohibition on growing event H7-1 in
California and the Western Washington counties where the majority of the US red table beet
and Swiss chard seed production occurs (interim measure Item 1), will further reduce the
potential for any impact. In the multiple years of wide scale cultivation of H7-1 sugar beets,
there have been no indications that that any gene flow has occurred “
3.7 IMPACTS OF EVENT H7-1 ROOT CROPS ON NATIVE BEETS
As discussed in Section 2,9, no native members of the genus Beta are found in North America.
Therefore, gene flow to native beets will not occur under either alternative.
The absence of native Beta plants in North American is an important difference for sugar beet
production concerns (both event H7-1 and conventional) from other regions of the world, in
particular, the EU, where "[i]t is considered essential to preserve the diversity of sea beet [wild
B. vulgaris ssp. man'tima] for any long term plant breeding strategy, and for conservation and
study in its own right" (MessSan et ai, 2009, p. 40).
3.7.1 Impact summary
Because there are no native beet populations in the US, there would be no impact with either
alternative.
3.8 IMPACTS OF EVENT H7-1 CROPS ON NON-NATIVE WILD AND
WEEDBEETS
Non-native wild and weed beets are described in detail in Section 2,9. Except for isolated
reports in Michigan and Oregon, all the known populations of non-native wild and weed beefs in
sugar beet root production states occur in California, where event H7-1 sugar beets are not
grown. As discussed in Section 2.9, S. macrocarpa weed beets are a weed issue in the
Imperial Valley, the only major sugar beet production area in California. Even so, research in
1998 found only minor introgression between the sugar beets and B. macrocarpa after 66 years
of coexistence in the Imperial Valley (Bartsch and Ellstrand, 1999).
Hofer Decl. . {Dkt , #48) I1 14; Berg Decl. . (Dkt. . #39) H 15; Grant Deal. . (Dkt. . #45) H 18; Lehner Decl. . (DkL
. #252)116.
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3.8.1 Impact summary
Alternative 1
Under Alternative 1 , there vsrould be no effect of gene flow from event H7-1 to non-native wild or
weed beets.
Alternative 2
APHIS has previously concluded that there are no issues with weed beet populations in the U.S.
outside California, Within the states where event H7-1 root crops are grown, there are reports
of non-native wild beets from Montana, Oregon and Michigan. The reports from Montana are
dated; more recent data do not indicate the presence of non-native wild or weed beets in
Montana. Also, the report was from a part of Montana where sugar beets root crops are not
grown. The single report from Oregon is from an area where sugar beet roof crops are not
grown. One of the Michigan reports was from a county where sugar beet crops are produced.
No additional information was found, and weed beets are not reported as a weed problem in
sugar beet root production in Michigan (Michigan Sugar Company, 2009). Based on the
absence of any information about any uncultivated beet populations in Michigan (and the
challenges in surviving winter) non-native wild or weed beet populations are expected to be
nonexistent or minor. The only potential for impact from a sugar beet root crop would be by
gene flow from an uncontrolled bolter, assuming any non-native wild or weed beet is close
enough to the bolter and flowering at the same time, so that it might be pollinated. Based on
this information, the potential for impact from sugar beet root production crops on non-native
wild or weed beets appears to be negligible. It would be non-existent with the proposed interim
measures. Under the proposed interim measures, all event H7-1 root crop growers will have
measures in place that require them to survey, identify, and eliminate any bolters In their root
crop fields before they produce pollen or set seed (Item 5). Item 6 of the interim measures
requires event H7-1 processors or cooperatives to survey, identify, and eliminate any bolters in
outdoor storage before they produce pollen or set seed In the multiple years of H7-1 cultivation
to date, there have been no issues identified with wild or weed beets.
Non-native wild and weed beet populations exist in California. However, no event H7-1
commercial crops have been grown in California, and Item 1 of the interim measures prohibits
growing event H7-1 crops in California.
Therefore, under Alternative 2, no impacts to non-native wild or weed beets would be expected.
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3.9 IMPACTS OF EVENT H7-1 SEED PRODUCTION ON CONVENTIONAL
SUGAR BEET AND OTHER BETA SEED CROPS
It is possible, without proper stewardship, for cross-pollination and gene flow between crop
types during seed production, because that is where pollination happens. Also, absent
appropriate stewardship measures, physical mixing of seeds is possible during harvesting, seed
cleaning, packaging and transport.
3.9.1 Maintaining seed purity, identify and quality
The Federal Seed Act and its implementing regulations’^ establish basic standards for
certification of seed, which are carried out by state seed certifying agencies. A state seed
certifying agency is created by state law, has authority to certify seed, and has standards and
procedures approved by USDA "to assure the genetic purity and identity of the seed certified."
Seed certifying agencies' standards and procedures must meet or exceed those specified in the
USDA regulations.’''
However, sugar beet seed is generally not certified, and seed companies have established their
own standards, as described in Section 2. There are certified wheat, soybean and corn seed
growers who produce their seed to sell to farmers for planting their commercial crops. This
issue is not relevant in sugar beets, because none of the sugar beet root growers hamest any
sugar beet seed. All sugar beet seed producers sell all of their seed to seed companies to be
sold to farmers. Even if sugar beet root growers could save some seed, they have no means
for processing it (so if would work in a planter) and providing the appropriate seed treatments
and would never take the risk of trying to plant it because of the uncertainty of what they have.
While sugar beet seed is generally not certified, the Oregon Seed Certification Service (OSCS)
standards for certified seed and the corresponding isolation distances are reported here, as
additional data points on what to expect in seed purity from a given isolation distance. The
OSCS has set the following standards for those items for certified sugar beet seed (OSCS,
1993):
• Pure seed, minimum: 99,00%
• Other crops, maximum; 0.10%
• Inert matter, maximum; 1.00%
’’7C.F.R. §CFR 201
“7 U.S.C. §USC 1551(a)(25) and 7 C.F.R. §CFR 201.67
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• Weed seed, maximum: 0.10%
Minimum isolation distances required for certified seed are as foilows (OSCS, 1993):
• From sugar beet pollen of similar ploidy or between fields where male sterility is not used
- 2,600 ft (0.49 mile)
• From other pollinator or genus Beta that is not a sugar beet - 8,000 ft (1 .5 mile)
The maximum specified OSCS required isolation distance for sugar beet seed production is
10,200 ft (1 .9 miles, from other, non-sugar beet Beta species) for “stock” seed which has a
maximum allowable concentration of “other crop" seed of 0.00% (OSCS, 1993).
3.9.2 Summary of practices for sugar beet seed production
All of the sugar beet seed in the Willamette Valley is produced by either West Coast Beet Seed
Company (WCBSC) or by Betaseed (see Section 2.7 of this ER). WCBSC has developed
explicit standard operating procedures and grower guidelines that are intended to minimize
and/or eliminate the possibility of pollen-flow between fields of related Beta species (See
Section 2.7 and Appendix B). Both WCBS and Betaseed belong to the Willamette Valley
Specialty Seed Association (WVSSA) and follow the guidelines for isolation and minimum
separation distances between fields (Appendix A). The minimum isolation distance from event
H7-1 (“GMO”) sugar beet and all other open pollinated Beta crops, in both the WCBS protocol
and the WVSSA guidelines is four miles. All growers of commercial specialty seed In the
Willamette Valley are members of the WVSSA (Loberg, 2010). This includes all commercial
companies raising Beta species. The isolation distances required by WVSSA between Event
H7-1 sugar beets and other Beta species such as chard or table beets is 2.1 miles further than
the maximum required OCCS isolation distance for stock seed discussed above.
Principles of quality assurance for sugar beet seed production have been set forth in an
industry-endorsed Code of Conduct (Appendix C). The Sugar Beet Code of Conduct adopted
by the beet group of the International Seed Federation (ISF) describes the measures the sugar
beet seed industry has taken to deliver high quality varieties, including measures to minimize
adventitious presence of transgenic sugar beet seed in non-transgenic Beta seed. The Code of
Conduct document has been agreed on by Syngenta Seeds, SESVanderHave, Danisco Seed,
Fr. Strube Saatzucht KG, A. Dieckmann-Heimburg, KWS (owns Betaseed), and affiliated
companies.
3.9.3 Sugar beet seed production since 2007
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Commercial H7-1 sugar beet seed has been produced since 2005, with the first major seed
production year in 2006, The total acreage of H7-1 sugar beet in the Willamette Valley since
2008 has been between 4000 and 5000 aaes (Gabel, 2010, p. 7; Pierson, 2010, p.10). Only
one grower who sells organic beet or chard seed has been identified in the Wllamette Valley.
That grower produced chard seed on approximately 1-3 acres at the Western margin of the
Willamette Valley. He has tested his organic chard seed using a PCR test capable of detecting
0.01% GE content during this period (Morton, 2010, 61:15-62:6). That seed has been tested
each year since 2007 and to date has not detected the presence of any H7-1 sugar beet.
(Hoffman, 2010a, p. 15; Morton, 2010, 36:8-17, 75:19-77:13, 99:6-21, 112:10-14; Stearns,
2010, 40:4-15, 49:6-16),
In May 2009, an incident was reported involving event H7-1 steckling disposal that raised
questions regarding one sugar beet seed company's stewardship and disposal requirements for
those materials (Roseboro, 2009), Stecklings are sugar beet roots that may be transplanted
into hybrid sugar beet fields. In or around May 2009, the Pro Bark garden store in Corvalis,
Oregon procured a quantify of peat moss from Betaseed. Betaseed had used the peat moss to
transport a shipment of sugar beet stecklings, and after the shipment had been transplanted,
some quantity of stecklings remained in the peat moss. After Pro Bark obtained the peat moss
Pro Bark mixed it with potting soil and offered it tor sale as a fertile soil mixture. Betaseed
learned that the mix was being sold and that it contained some stecklings, and at that point, Pro
Bark’s records indicated that It had sold portions of the mixture to thirty customers located in the
Corvalis and Albany area. Betaseed repossessed the portion of the mixture that had not been
sold. Betaseed personnel visited twenty of the thirty customers who had purchased portions of
the mixture and removed any stecklings or steckling fragments found in the mixture. The
owner of Pro Bark contacted seven additional purchasers and requested that they inspect for
and destroy any stecklings they had purchased (Lehner 2010, pp 7-10.)
Betaseed reported that the stecklings found in the mixture after repossessing it were not likely to
survive and produce pollen. Most of the stecklings were fragmented, rotting or dead. Also,
because a large percentage of Betaseed hybrid sugar beet fields in the Willamette Valley in
2009 had the event H7-1 gene only on the non-pollinating female plant (see Section 2.7), the
shipment of stecklings that Betaseed had transported in the peat moss was composed of less
than 5% H7-1 male pollinators. Therefore, according to Betaseed, the chances that any
steckling in the peat moss was intact, alive and a male H7-1 pollinator were remote. In addition,
given the time of year when the fertile mixture was sold, cross-pollination would have been very
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unlikely even if the stecklings had been able to produce pollen, and there were no subsequent
reports of any cross-pollination from the stecklings. Betaseed subsequently revised its
Standard Operating Procedures to provide for proper disposal of the peat moss in which it
transports stecklings (Lehner, 2010, pp. 7-10).
3.9.4 Measured sugar beet pollen dispersal
Many studies have been done to measure distances over which cross-pollination may occur in
Beta species, with a range of results (e.g., Bartsch et al, 2003; Chamberlain, 1967; Darmency et
al, 2009; Darmency et al, 2007; Fenart et al. 2007). Darmency et al (2009) summarized a
literature review of studies on pollen flow in sugar beet (values reported in meters converted to
feet):
Authors
Maximum dispersal
Alibert et al (2005)
2.1% at 700 ft
Archimowitsch (1949)
0.3% at 2,000 ft
Bateman (1947)
0.07% at 62 ft
Brants et al (1992)
8% at 250 ft
Dark (1971)
0.1% at 100 ft
Dark (1971)
3,900 ft max (using a pollen trap, not hybrid seed
production)
Darmency et al (2007)
1.3% at 920 ft
Jensen and Bogh (1942)
2,600 ft max (using a pollen trap, not hybrid seed
production)
Madsen (1994)
0,31% at 250 ft
Saeglitz et al (2000)
40% at 660 ft
Scott and Longden (1970)
26 ft max (using a pollen trap, not hybrid seed
production)
Stewart and Cambell (1952)
10% at 50 ft
ViQouroux et al (1999)
1.2% at 50 ft
Note: The maximum dispersal was “the highest rate at the farthest distance to which pollen or hybrids
were found in the study”.
Darmency et al (2009, p. 1085) note that the experiments "were hardly comparable because the
experimental design varied widely.” The researchers also found that nearly all fertilization from
pollen source occurs near the field (within about 0.3 miles). The summary table does not make
distinction between mere pollen presence and actual hybridization, which, as discussed
previously, can be very different. Darmency et al did not report how many, if any, of these
studies used isolated bait plants rather than groups of receptor plants that would be producing
their own pollen cloud, which, as discussed above, could make a substantial difference (i.e., the
percentages of pollination by an outside source are much smaller with competition), Also, in
their own experiments, even when the pollen reached the target plant and hybridization did
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occur, Darmency et al found a large drop in germination rates in seeds produced by plants
removed from the source, with approximately 40 percent at the source dropping to one percent
at around 1 ,000 feet from the source (2009, p. 1087).
3.9.5 Modeled sugar beet pollen dispersal
Research scientists specializing in modeling pollen dispersal have modeled the sugar beet
pollen dispersal for outcrossing to the organic Beta production field of a Plaintiffs declarant who
believed his fields would be cross-pollinated by event H7-1. The nearest event H7-1 field was
6,9 miles distant. Using conservative assumptions and modeling conditions for the three days
during the "pollen shed” period when wind conditions were most likely to result in cross-
pollination (June 22, 23, and 27), the modelers obtained the following results for likelihood of
outcrossing; June 22, 1 in 4.9 million; June 23, one in 1.1 billion; and June 27, 1 in 222 million.
The risk of any successful pollination in these circumstances is highly remote.
3.9.6 Site-specific assessment of cross-pollination potential in the Willamette Valley
This discussion focuses on the Willamette Valley because it is the only known location where
event H7-1 commercial seed production and commercial seed production of Swiss chard and
red table beet coexist. At least three qualified scientists have evaluated the potential for gene
flow from event H7-1 to other Beta seed crops in the Willamette Valley; Mark Westgate, PhD,
whose results are summarized above; Neil Hoffman, Ph.D. and Leonard Panella, Ph.D,
Westgate is a professor of crop production and physiology at Iowa State University, whose
“scientific research focuses on understanding environmental factors that affect pollination and
seed formation” (Westgate, 2010, p. 1). Hoffman is a plant physiologist who is currently an
APHIS official. Among his previous positions were professor of plant biology at the Carnegie
Institution and Stanford University (Hoffman 2010a, p. 1), Panella, a plant geneticist, is
research leader of the sugar beet research unit at the USDA ARS Crop Research Laboratory in
Fort Collins, Colorado (Panella, 2010, p. 1).
Westgate explains that most pollen falls within the “immediately surrounding” area of the source
field. In addition, many other factors affect the possibility of cross pollination in two Beta seed
production fields, including receptiveness of the female, wind and humidity conditions, viability
of the pollen, and competition (see Section 2.4 for a general discussion of these factors). For
example, Swiss chard and table beets that are grown for seed are primarily open pollinated (all
plants produce pollen) rather than hybrids using male sterile females, as is used in the
production of most sugar beet seed (discussed in Section 2.7). The pollen cloud in an open
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pollinated field is “typically four times more dense than the local pollen cloud for a standard
hybrid field" with “billions" of pollen grains per square meter making it much more difficult for a
small amount of the stray pollen that might be carried on the wind from another field to compete
in the open pollinated fields (Westgate, p. . 5). Westgate concludes, in general, "when all the
principal factors affecting pollination are considered, the probability of pollination of table beet or
chard fields by sugar beet pollen in the Willamette Valley is infinitesimally small” (Westgate,
2010, p. 6).
Hoffman indicates that nearly all fertilization from a pollen source (99.9%) occurs within the first
500 m (about 0.3 miles), and that any pollen that might reach another downwind field would
have to compete with pollen from that field. Based on his assessment of conditions in the
Willamette Valley, Hoffman concluded that the 4-mile isolation distance (as articulated in Interim
measure No. 2) "to isolate unlike sexually compatible crops such as Swiss chard, table beets
and sugar beets is more than 12 times the distance needed to reduce cross-pollination between
RRSB and Swiss chard to 0.1% (1 seed in 1000) in a worst case scenario without competition
from a local pollen source” (Hoffman, 201Qa, p. 14). Hoffman expects the level of gene flow to
be less than one seed in 10,000 (0.01%) with a four mile isolation distance. Panella concurred
with Hoffman’s analysis and conclusion (Panella, 2010, p. 5). Carol Mailory-Smith, PhD,
professor in the Department of Agriculture at Oregon State University in the Willamette Valley,
concluded that the “proposed restrictions [interim measure including a 4 mile isolation distance]
will provide significant safeguards to protect Beta species seed producers while the EIS is being
conducted" and that the risk of geneflow would be “extremely low.” (Mailory-Smith, 2010, pp. 1-
2 ).
3.9.7 Use of event H7-1 trait on male-sterile female
Seed production companies use a hybrid seed production system in which the event H7-1 trait
is on the female (male sterile plants) in a large proportion of commercial seed production fields.
In the Willamette Valley at least two seed companies use this system exclusively (Anfinrud,
2010, pp. 1-2; Lehner, 2010, pp. 5-6; Meier, 2010, p. 8). Essentially zero event H7-1 pollen is
produced by these “female side” seed production fields. As a result of these methods, 78.6% of
the currently growing GE sugar beet seed crop in the Wllamette Valley is male-sterile female.
Because these plants produce virtually zero pollen, they eliminate any realistic risk for
unintentional spread of the GE trait.
3.9.8 Red table beet offtypes
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Seed companies growing sugar beets in the VWIIamette Valley occasionally find a very small
percentage of off-types from red table beet crops. Seed companies have indicated a very low
level of off-types in sugar beet crops, and one seed company reports that its latest "observation
plots did not produce any off-types" (Lehner, 2010, p. 3). Customers (i.e., growers of
commercial sugar beet root crops) have likewise indicated that after inspecting the millions of
plants grown in variety trials conducted over several years, "the number of chard or red beet off-
types were so small as to be, for all intents and purposes, not quantifiable." (Grant, 2010, p,6;
Berg, 2010, p, 5; Hofer, 2010, p.4). Seed companies regularly perform grow out tests to
determine if there are any issues with off-types (Lehner, 2010, p.3; Hovland, 2010, pp. 2-3).
Red table beet offtypes in sugar beet fields could occur due to nearby backyard gardeners
growing red table beets, or might occur from open pollinated red table beet fields upwind from
sugar beet fields. (Anfinrud, 2010, 109:13-17). In an open pollinated field, every plant sheds
pollen (Stander, 2010, p. 2). Thus an acre of open pollinated red table beets would produce far
more pollen than an acre of hybrid sugar beet fields, where the only one-fourth to one-third of
the plants produce pollen (Wesfgate, 2010, p. 5), The Willamette Valley Specialty Seed
Association pinning guidelines and isolation distances require 4 mile isolation distances
between open pollinated red beet and sugar beet fields, in order to limit red beet off types in
sugar beet fields (Stander, 2010, p. 2). The potential for sugar beet gene transmission to open
pollinated red beet fields is very low, because as indicated, a greater volume of pollen per acre
are shed by the open pollinated field (Wesfgate, 2010, p. 5) (indicating "billions" of pollen grains
per square meter shed by an open pollinated red beet field).).
3.9.9 No sensitivity to event H7-1 by conventional sugar beet growers; Stewardship
regarding mechanical mixing
There is no indication of sensitivity by customers for conventional sugar beet seed to the
possibility of an inadvertent presence of event H7-1 genetic material in the conventional seed
(Pierson, 2010, p. 17). First, there is currently no market in the U.S. for organic sugar beets
(Pierson, 2010, p. 17). Second, in most areas where both event H7-1 and conventional sugar
beets are grown, both types of beefs would be combined and processed together, with no effort
to differentiate between sugar from H7-1 and conventional beefs (Pierson, 2010, pp. 16-17).
The sugar from conventional beets does not differ chemically or in any other way from the sugar
from H7-1 beets (Hoffman, 2010, p. 16).
As set forth in Section 2.7.3, each of the seed companies producing H7-1 seed utilizes detailed
measures to address the possibility of mechanical mixing of H7-1 and conventional sugar beet
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seed. These measures would be subject to audit under the interim measures to ensure that
they continue to be utilized and are successful.
Because seed production for red beet and chard seed crops is completely separate from sugar
beet seed production, there is virtually no risk of mechanical mixing. As discussed in Section
2.8, the two types of production employ different growers, different equipment and different
faciities. Accordingly, there is no significant risk of mixing.
3,9.10 Question of zero tolerance
We have identified one organic seed producer who has chosen to produce organic chard seed
(among several other organic crops) in the Willamette Valley. This organic producer has
approximately one to three acres of production on the Western margin of the Valley. He has
indicated that he faces a risk of genetic transfer from event H7-1 seed fields, and that he sells to
customers for his organic chard with zero tolerance for any level of outcrossing with event H7-
1. That producer has tested his chard seeds since 2007 with a PGR genetic test and found no
indications of event H7-1 traits in his crops. To date, he has not lost sales due to a risk of cross
pollination from Event H7-1 . He reports that the costs of the PCR testing for multiple years
since 2007 have totaled roughly $700, and that a positive test for event H7-1 for his crop could
negatively affect the reputation that producer has with his customers. That seed producer has
also indicated in public statements through the media that he is not concerned about a risk of
cross-pollination from event H7-1 seed fields where the GE trait is on the female non-pollinator
(Morton, 2009, 9:12-19). A seed retailer who buys from that producer has reported that he has
multiple sources for chard seed outside the Willamette Valley, including in California, but
continues to purchase from that producer nevertheless.
In addition, both that seed producer and the seed retailer have participated in the development
of a consensus standard setting a threshold for the presence of GE traits in organic food
products and in seed. The Non-GMO Project Working Standard, sponsored by leading players
in the organic industry (including Whole Foods), specifically permits crops to be verified "non-
GMO" despite the presence of a low level of biotech content — 0.25% for GE sugar beet seed
and other Beta seed crops (Non-GMO Project, 2010, pp. 25, 34) and 0.9% in organic food and
feed. Section 2,4.3 of the Working Standard explains that its product content standards apply to
the crops listed on Appendix B, plus “close relatives of these crops that are subject to cross
pollination” (Non-GMO Project, 2010, p. 12). Appendix B specifically lists “sugar beets" as one
of those crops “with GMO Risk” subject to the standard, and also expressly identifies “chard"
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and “table beets" as close relatives for which cross-pollination is possible (Non-GMO Project,
2010, p. 34). Section 2.6 explains that “[t]he Non-GMO Project has established" a 0.1% GMO
content threshold for “seed and other propagation materials" for all crops listed in Appendix B,
but the standards include a specific variance of 0.25% for sugar beet seeds and other crops
identified (Non-GMO Project, 2010, pp. 14, 34). This 0,25% level is thus the Working
Standard’s current threshold for “non-GWIO” sugar beet seed and other Beta seed crops.
Other commercial producers of sugar beet, red beet or chard seed in the Willamette Valley have
all consented to and abide by the Willamette Valley Specialty Seed Association standards,
discussed in Section 2.7 and Appendix A.
3.9.11 Seed availability
As discussed in Section 2,7, sugar beet variety development is competitive, technological, and
expensive multi-year activity. Seed companies develop varieties with traits they expect growers
to want, and the sugar beet companies seed selection committees chose the varieties they wish
to grow. It is a market-driven process, where the grower cooperatives themselves determine
what is available for planting. Every year, each sugar beet company has a number of varieties
that growers may choose from. As the popularity of event H7-1 sugar beet among growers has
grown, there have been fewer available conventional varieties and more event H7-1 varieties;
however, conventional varieties have been available. There is no organic sugar beet seed
production in the sugar beet seed production areas.
Conventional and/or organic sugar beet seeds are available from some US seed suppliers
(conventional), and from European seed companies (conventional and organic).
(SESVaderHave, 2010; Millington Seed Company, 2010). KWS has some 250 varieties of
sugar beet seeds available, including organic (KWS, Grain, 2008). Organic sugar beet is a
noteworthy crop in the EU (Eurostat, 2010). Not all organic beets are processed into sugar;
some are used to produce a syrup that is integrated into organic food preparations (Ceddia and
Cerezo, 2008).
3.9.12 Impact Summary
Alternative 1
Under Alternative 1 , there would be no gene flow impacts to growers of organic or conventional
Beta seed from the production of event H7-1 sugar beet seed.
Alternative 2
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Under Alternative 2, no or negligible impacts from event H7-1 seed production on growers of
organic or conventional Beta seed are expected for the following reasons:
• The large majority of red beet and chard seed crops are grown in different geographic
areas than are Event H7-1 sugarbeets.
• Even in the Willamette Valley (where most sugarbeet seed crops and a limited acreage
of other beta species seed crops are grown), there have been no reported impacts since
H7-1 commercial seed production began in 2006, and with the proposed interim
measures, the potential for impacts would be further reduced.
• Based on 1) the use in the majority of the event H7-1 seed production of the trait on the
male-sterile female; 2) results of sugar beet pollination outcrossing data in the published
scientific literature; 3) site-specific modeling; 4) the relationship between expected seed
purity levels and isolation distances determined by the OSCS; 5) the results of
experience and testing in the Willamette Valley seed production area since 2007 and, 6)
the analysis and conclusions of qualified scientists who specifically addressed this issue,
the 4-miIe isolation distance (Interim measure Item 2) is expected to result in eliminating
any significant risk that cross-pollination of organic or conventional red beet or chard
crops will occur, and if it happens, make the rate of outcrossing very low if not
undetectable - likely at rates of less than 1 in 10,000 (less than one seed in 10,000 with
the event H7-1 trait). This is, for example, far less than the non-GMO Project proposed
tolerance levels for sugar beet and other Beta seed (0,25%) (Non-GMO Project, 2010),
• The use of hybrids with the event H7-1 trait on the female, in combination with the
disclosure requirements regarding male fertile event H7-1 seed crops (interim measure
Item 3) will drastically reduce the potential for cross-pollination. For the large majority of
H7-1 seed fields (with the trait on the female), there is essentially zero risk of crossing
with a red beet or chard seed crop. For those fields with the H7-1 gene on the male
pollinator, the Isolation distances will reduce any risk significantly, and producers of red
beet and chard can ascertain what those distances are and take appropriate measures
(to position their fields, scout for off-types, conduct genetic testing, or through other
means discussed herein) if they are concerned about any level of risk,
• The interim measure to prevent seed mixing (Interim measure Item 4), which makes
current seed and steckling production and handling practices mandatory (described in
Section 2), will make the potentially low level presence of event H7-1 in conventional
sugar beet seed negligible and will eliminate adventitious presence of event H7-1 in
other Beta seeds.
Conventional sugar beet seed will continue to be available as long as growers continue to
choose it in the variety triais. Growers who purchase seed purchase a specific variety, which is
labeled as such.
In addition, in the event unwanted transmission of H7-1 traits to a red beet or chard crop did
occur, there are multiple means for a seed producer to address it. First, because a seed
producer of red beet or chard growing beta species typically will inspect each plant remove any
off-types from his production fields, any preexisting unwanted cross between a sugar beet and
red beet or chard plant can be addressed before seed is produced with an unwanted trait
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(Stander, 2010, pp, 3 - 4). Second, once seed is produced, a grower typically will perform grow-
out tests on a sample of the seed to confirm that the seed is producing plants without undesired
off-types. This can also identify any issues. Third, multiple types of genetic testing can be
conducted to confirm the lack of any H7-1 trait (Hoviand, 2010, pp. 2 - 3). While PCR testing is
available with a very high level of sensitivity (to 0.01%), inexpensive genetic strip tests capable
of identifying H7-1 are also available for $2 to $4 per test, with a sensitivity of approximately
0.1% (Stander, 2010, pp. 4 - 5). Such testing may be utilized in a manner that employs
samples from multiple seed plants and reduces the number of tests required per field. In the
event of a positive test, the seed producer may use additional testing to isolate the source of the
portion of his field producing that result (Id). Further, retailers of seed with sensitivity to H7-1
content may also conduct grow out tests, or utilize the same genetic testing methods to address
any concerns they may have {Id)
As discussed in Section 3.17, in light of the above factors, the socioeconomic impacts on
farmers growing red table beet and Swiss chard seed are negligible,
3.10 LIVESTOCK PRODUCTION SYSTEMS
The only impacts to livestock production systems would be related to animal feed, which is
discussed in Section 3.11.
3.11 FOOD AND FEED
Both food (sugar and molasses derivatives) and animal feed (molasses and beet pulp) are
derived from sugar beets. In this section we summarize the large body of scientific evidence
that has been developed that supports the conclusion that food and feed derived from event H7-
1 sugar beets are as safe and healthy as food and feed derived from conventional sugar beets.
While the evidence has largely been developed by Monsanto and/or KWS and the contract
research organizations supported by Monsanto and/or KWS, it has been evaluated and peer
reviewed by panels of government scientists from the US, Canada, the European Union (EU),
Japan, Australia, New Zealand, Mexico, South Korea, the Russian Federation, China,
Singapore, Colombia and the Philippines, all of whom have approved, or recommended for
approval, the use of products from event H7-1 in their countries (FSANZ, 2005; Monsanto/KWS
2007; Berg 2010),
We begin with a summary of FDA's authority and policy under the federal Food, Drug and
Cosmetic Act (FFDCA) with regard to ensuring the safety of food and feed derived from new
plant varieties developed using rDNA methods. We then document each element FDA
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evaluated in its consultation process. Then we summarize the evaluations and conclusions of
several other international scientific oversight groups.
3.11.1 FDA authority and policy
FDA policy statement, in 1992, the FDA issued a policy statement clarifying its interpretation
of the FFDCA, regarding foods {including animal feed) derived from new plant varieties,
including plants developed by the newer methods of genetic modification, including rDNA. The
purpose of the policy is “to ensure that relevant scientific, safety, and regulatory issues are
resolved prior to the introduction of such products into the marketplace” (FDA, 1992). FDA is
the “primary federal agency responsible for ensuring the safety of commercial food and food
additives, except meat and poultry products” and "FDA has ample authority under the act's
[FFDCA] safety provisions to regulate and ensure the safety of foods derived from new plant
varieties, including plants developed by new techniques. This includes authority to require,
where necessary, a premarket safety review by FDA prior to marketing of the food” (FDA,
1992). Under section 402(a)(1 ) of the FFDCA, a food is adulterated and thus unlawful “if it
bears or contains an added poisonous or deleterious substance that may render the food
injurious to health or a naturally occurring substance that is ordinarily injurious” (FDA, 1992).
FDA has the authority to ensure safety of new foods. FDA considers its existing statutory
authority under the FFDCA and its implementing regulations “to be fully adequate to ensure the
safety of new food ingredients and foods derived from new varieties of plants, regardless of the
process by which such foods and ingredients are produced" (FDA, 1992). “The existing tools
provide this assurance because they impose a clear legal duty on producers to assure the
safety of foods they offer to consumers; this legal duly is backed up by strong enforcement
powers; and FDA has authority to require premarket review and approval in cases where such
review is required to protect public health" (FDA, 1992).
Developers have the responsibility to evaluate the safety of new foods. “It is the
responsibility of the producer of a new food to evaluate the safety of the food and assure that
the safety requirement of section 402(a)(1) of the act is met. FDA provides guidance to the
industry regarding prudent, scientific approaches to evaluating the safety of foods derived from
new plant varieties, including the safety of the added substances that are subject to section
402(a)(1) of the act. FDA encourages informal consultation between producers and FDA
scientists to ensure that safety concerns are resolved” (FDA, 1992).
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Foods developed by new methods do not present greater safety concerns. TDA believes
that the new techniques are extensions at the molecular level of traditional methods and will be
used to achieve the same goals as pursued with traditional plant breeding. The agency is not
aware of any information showing that foods derived by these new methods differ from other
foods in any meaningful or uniform way, or that, as a class, foods developed by the new
techniques present any different or greater safety concern than foods developed by traditional
plant breeding" (FDA, 1992).
FDA’s goal is to ensure the safety of all food and feed. “The goal of the FDA's evaluation of
information on new plant varieties provided by developers during the consultation process is to
ensure that human food and animal feed safety issues or other regulatory issues (e.g. labeling)
are resolved prior to commercial distribution" (FDA, 1997).
3.11.2 FDA biotechnology consultation note to the file BNF 000090
FDA makes the contents of Its biotechnology notification files (BNFs) available on the internet
(see reference FDA, 2004; event H7-1 is BNF 000090)“. FDA documented its consultation with
Monsanto/KWS on event H7-1 in a note to the file dated August 7, 2004 (Bonette, 2004). That
information is summarized below.
Characterization, inheritance, and stability of the introduced DNA
Using standard analytical techniques, Monsanto/KWS verified that event H7-1 contained a
single copy of the EPSPS cassette, and that all components were intact (Bonnette, 2004;
Schneider, 2003, p. 43).
Monsanto/KWS conducted crosses using conventional breeding techniques resulting in 27
breeding experiments over four generations. These studies indicate that the introduced trait
(giyphosate tolerance) was stably inherited as a dominant trait (Bonette, 2004; Schneider, 2003,
p. 44).
Using standard analytical techniques, Monsanto/KWS demonstrated the stable integration of the
T-DNA over three generations (Bonette, 2004; Schneider, 2003, p. 47).
Introduced substance - CP4 EPSPS enzyme
As discussed in Section 3.1.1, EPSPS is a catalyst for a reaction necessary for the production
of certain aromatic amino acids essential for plant growth and has a similar function in bacteria
httD://www.accessdata.fda.QQv/scriDt5/fcn/fcnDelailNavioaliDn.cfm?rpt-bioListina&id=19
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and fungi (for example, baker’s yeast). While EPSPS is present in plants, bacteria and fungi, it
is not present in animals; animals do not make their own aromatic amino acids, but rather obtain
them from the foods they consume. Thus, EPSPS is normally present in food and feeds derived
from plant and microbial sources (Harrison et al, 1996). There are variations in the genetic
makeup (amino acid sequences) of EPSPS among different plants and bacteria. The EPSPS
from Agrobacterium sp. strain CP4 is just one variant of EPSPS. A unique characteristic of the
CP4 EPSPS is that, unlike EPSPS enzymes commonly found in plants, it retains its catalytic
activity in the presence of glyphosate (Bonnette, 2004; Schneider, 2003, pp 50-51; Padgette et
al, 1995).
Concentrations in sugar beet. In 1999, field trials were conducted at six distinct field locations
distributed across Europe in the major sugar beet production areas. The event H7-1 sugar
beets were treated with a Roundup agricultural herbicide. Samples of brei (root tissue
processed using standard sugar beet industry methods) and top (leaf) tissues were collected
and analyzed for levels of the CP4 EPSPS protein. On average, concentrations of the CP4
EPSPS protein, on a fresh weight basis, were similar in the leaf tissue (161 pg/g) and in the root
tissue (181 pg/g). The range of mean levels of theCP4 EPSPS protein in top (leaf) tissue was
1 1 2 to 201 pg/g and in root (brei) were 1 45 to 202 pg/g across the sites (Schneider, 2003).
Toxicity of CP4 EPSPS. Studies were conducted on mice, using CP4 EPSPS doses of 400,
100 and 40 milligrams (mg) of CP4 EPSPS per kilogram of body weight per day (mg/kg body wt
-d). For a typical 0.03-kg mouse, the 400 mg/kg body wt/d dose equated to 12 mg CP4 EPSPS
per mouse per day. The study was designed to reflect a 1 ,000-fold factor of safety on the
highest possible human exposure to CP4-EPSPS, based on assumed exposures to soybean,
potato, tomato and corn at the time the study was done (Harrison et al, 1996)^®. The daily CP4
EPSPS content in the maximum mouse exposure was equivalent to the amount in
approximately 160 pounds of H7-1 sugar beets. No treatment-related adverse effects were
observed, and there were no significant difference in any measured endpoints between the CP4
EPSPS treated mice and the control group (Harrison, et al, 1996, p. 735).
Monsanto/KWS also compared the amino acid sequence of CP4 EPSPS to protein sequences
in the public domain ALLPEPTIDES database using the FASTA algorithm, and reported no
biologically relevant sequence similarities between CP4 EPSPS protein and known protein
® Note that this was a theoretical exercise as no glyphosate tolerant potatoes or tomatoes are commercially grown.
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toxins were observed (Bonnette, 2004). A peptide is a molecule consisting of several linked
amino acids (GMO Safety, 2010a),
Allergenicity. Allergens can be derived from many sources: in animal bair, pollen, insect bites,
dust mites, plants, pharmaceuticals, and food. Approximately 20,000 allergens have been
identified. Most allergens in food are high molecular weight proteins and are rather resistant to
gastric acid and digestive enzymes (GMO Safety, 2010a).
Monsanto/KWS searched a comprehensive database of allergens (Hileman et al, 2002)
containing sequences of known allergens, for amino acid homology to the CP4-EPSPS protein,
and concluded that there was no immunologically significant amino acid sequence homology
between the GP4 EPSPS protein and amino acid sequences of allergens in the database
(Bonnette, 2004).
Monsanto/KWS discussed two studies relevant to the mammalian digestibility of CP4 EPSPS.
In the first study, the CP4 EPSPS protein was exposed to simulated gastric (stomach) and
intestinal fluids that were prepared according to the US Pharmacopoeia (1990). The half-life of
the CP4 EPSPS protein was reported to be less than 15 seconds in the gastric fluid, greatly
minimizing any potential for the protein to be absorbed in the intestine. The half-life was less
than ten minutes In the simulated intestinal fluid (Harrison et al, 1996, p 738). The second study
reported similar results (Bonnette, 2004).
Food and feed uses of sugar beet
The main food use of sugar beet is for the extraction of sucrose from sugar beet roots through a
process involving hot water extraction, followed by purification, evaporation, and centrifuge
separation of sucrose crystals (granular sugar). Refined sucrose does not contain protein or
other genetic material. This process also yields sugar beet molasses and sugar beet pulp,
which are often pelleted and used in animal feed. The leafy sugar beet "tops" are usually left in
the field, but they may occasionally be fed to ruminant animals (Bonnette, 2004).
Compositional analysis
To assess whether sugar beet event H7-1 is as safe and nutritious as conventional sugar beet
varieties, Monsanto/KWS compared the composition of the hybrid lines containing event H7-1,
produced through conventional breeding, to the composition of the corresponding non-
transgenic, control. Tops (leaves) and brei (processed roots) were analyzed using standard
methods or other suitable methods (Bonnette, 2004).
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These analyses included proximate values (crude ash, crude fiber, crude fat, crude protein and
dry matter), carbohydrates, qualify parameters, saporsins (naturally-occurring antinutrients that
have a bitter taste and can act as a deterrent to foraging), and eighteen amino acids. Quality
parameters measured in root samples included percent sucrose, invert sugar, sodium,
potassium and alpha-amino nitrogen. All analyses were conducted as a single analysis for the
root (brei) and top (leaf) samples collected as three replica samples from each of five field trials
sited. Fifty-five statistical comparisons were made with the control line, of which seven were
found to be statistically different (p<0.05). Based on the statistical methods, three of these
seven would have been expected based on chance. In all seven cases, the ranges for the
statistically different components in event H7-1 significantly overlapped or fell completely within
the range of values observed for the control, the conventional reference varieties and for
available published values from conventional sugar beet varieties (Schneider, 2003, Section C).
Conclusion
Based on the data submitted, the FDA considered the consultation process to be complete, and
acknowledged this in a note to the file and a letter to Monsanto (Bonnette, 2004; Tarantino,
2004).
3.11.3 Health Canada approval 2005
Health Canada's Food Directorate has legislated responsibility for premailret assessment of
“novel foods." Under Canadian regulations, sugar derived from event H7-1 sugar beet is a
novel food because it is derived from a plant that has been genetically modified to exhibit
characteristics that were not previously observed in the plant (Health Canada, 2005).
Health Canada “conducted a comprehensive assessment of this sugar beet according to its
Guidelines for the Safety Assessment of Novel Foods," reviewing the same information
Monsanto/KWS provided to FDA in its consultation, and made the following conclusion (Health
Canada, 2005:
Health Canada's review of the information presented in support of the food use of sugar
from glyptiosate tolerant sugar beet lines containing event H7-1 concluded that the food
use of sugar from sugar beet lines containing this event does not raise concerns related to
safety. Health Canada is of the opinion that sugar from sugar beet lines containing event
H7-1 is as safe and nutritious as sugar from current commercial sugar beet varieties.
3.11.4 Canadian Food Inspection Agency (CFIA) approval 2005
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The CFIA evaluated event H7-1 both as a crop to be potentially grown in Canada, and as
livestock feed, and approved both uses in 2005. Based its evaluation of data provided by
Monsanto/KWS, and as summarized in its Decision Document DD2005-54, the CFIA
"determined that this plant with a novel trait (PNT) and novel feed does not present altered
environmental risk nor does it present livestock feed safety concerns when compared to
currently commercialized sugar beet varieties in Canada" (CFIA, 2005).
3.11.5 EFSA risk assessment and EC authorization
The European Food Safety Authority (EFSA) is an independent European agency funded by the
EU budget for the purpose of assessing risks associated with the food chain. Risk assessment
is a specialized field of applied science that involves reviewing scientific data and studies to
evaluate risks associated with certain hazards (EFSA 2010). EFSA conducts risk assessment,
but does not have authority to authorize use. The European Commission (EC), which is the
executive body of the EU, determines whether or not a genetically modified item will be
authorized for use in the EU.
Scope and process. The scope of the Monsanto/KWS application to the EFSA was for food
and feed, and not as a crop intended for cultivation in the EU (EFSA, 2006, p. 1). The EFSA
used the same data Monsanto/KWS provided to the FDA, Health Canada, and the CFIA, and
also requested additional information. The Scientific Panel on Genetically Modified Organisms
(GMO Panel) developed an opinion that was then adopted by the EFSA. Subsequently, in
2007, the EC authorized “the placing on the market of food and feed produced from genetically
modified sugar beet H7-1" (EC, 2007). During the EFSA risk assessment process, Member
states comment on the draft decisions and can request further analysis; the GMO Panel also
can request additional information from the applicant.
Detectable presence of CP4 EPSPS. The GMO Panel reported that if the CP4 EPSPS protein
was present in the sugar, which was unlikely, it was below the detection limit of 0.004 parts per
million (ppm). No DNA was detected in the sugar and the molasses is also "free from DNA and
protein (limit of detection 0.002 ppm).” The CP4 EPSPS protein is present in pulp at levels
around 500 ppm on a dry weight basis (EFSA, 2006. p. 9),
Safety of the CP4 EPSPS protein. The GMO Panel noted the “long history of dietary exposure
to EPSPS proteins" for humans and animals the fact that “previous applications for glyphosate
tolerant crops containing the CP4 EPSPS protein have been evaluated and found to be safe for
human and/or animal consumption in previous [EFSA] opinions." The GMO Panel concluded
that “a toxicological assessment of new constituents is not applicable" (EFSA, 2006, p 10).
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Additional toxicity study. In response to EFSA information requests, Monsanto/KWs
conducted a 90-day toxicity study, feeding processed pulp to rats, which did not indicate any
adverse effects. The GMO Panel reported additional studies of sugar beet pulp to sheep, also
with no adverse effects (EFSA, 2006)”.
Allergenicity. In addition to evaluating the potential allergenicity of the CP4 EPSPS protein,
the GMO Panel considered whether the insertion of the transgene could result in modifications
of the pattern of expression of other potentially allergenic proteins within the sugar beet plant
The Panel did not consider the issue to be relevant, as sugar beet is not a major allergenic food,
and overexpression of an existing protein “would be unlikely to alter the overall allergenicity of
the whole plant (EFSA, 2006, p. 12).^®
No need for post-market monitoring. The GMO Panel noted “No risks to human and animal
health were identified in studies of the CP4 EPSPS protein expressed in sugar beet H7-1, and
in studies of the genetically modified sugar beet itself. Thus, foods and feeds produced from
sugar beet H7-1 Is as safe and nutritious as foods and feeds derived from conventional sugar
beefs." The Panel recommended no post-market monitoring (EFSA, 2006, p. 13).
Conclusions. The GMO Panel stated the following in its conclusions (EFSA, 2006, p. 13):
• Sugar and molasses have been shown to be free from DNA and protein
• Animals fed with pulp will be exposed to the CP4 EPSPS protein
• The CP4 EPSPS protein has been evaluated and found to be safe for human and/or
animal consumption
• The molecular characterization and the comparative compositional analysis did not
indicate the occurrence of any unintended effects due to the genetic modification
• Products from sugar beet H7-1 are safe as food and feed
• The nutritional value of the sugar beet H7-1 and the derived sugar beet products is
comparable to that of the analogous products from conventional sugar beet
• The risk of allergenicity is of no concern with this product
3.11.6 Other approvals
Japan approved the use of event H7-1 in feed 2003, in food in 2005, and the environmental in
2007 (Sato, 2008). Studies by the Japanese National Food Research Institute have confirmed
that there is no detectable DNA in sugar from sugar beets, with the conclusions that “sugar beet
” http://ias.fass.ora/cafcontent/full/83/2/400
httD://ias.fass.ora/coifeontentffull/83/2/400
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DNA was degraded at an eariy stage of sugar processing" (Oguchi et at, 2009) , Event H7-1 has
also been approved for food and feed use in Mexico, South Korea, Australia, New Zealand,
China, Colombia, the Russian Federation, Singapore and the Philippines (FSANZ, 2005;
Monsanto/KWS 2007; Berg 2010).
3.11.7 Willingness of the buyer to accept sugar from event H7-1
Market concerns about willingness of buyers to accept sugar, molasses, and/or pulp derived
from event H7-1 have not resulted in any perceptible change in the demand for US-produced
beet sugar or other fractions. Based on the regulatory approvals obtained in domestic and
international markets, sugar, molasses, and pulp derived from event H7-1 is being successfully
marketed.
As summarized above, there is a large body of scientific evidence that has been reviewed and
validated by several international scientific panels that supports the safety of the sugar and
other fractions derived from event H7-1 for food and feed use. If there are consumers who do
not wish to purchase sugar made from event H7-1 for reasons other than safety and health,
they have the option of buying sugar made from sugarcane, which is not currently produced
using lines that were developed using modern biotechnology. However, the majority of food
products containing beet sugar, such as cakes, candy, ice cream and other sweets, are likely to
contain sugar derived from sugar beet varieties containing event H7-1. Most commercial food
and beverage products are also likely to contain corn or soy products derived from biotech
crops (Goldsbrough, 2000).
3.11.8 Impacts
Based on the scientific evidence summarized in this section, impacts on food and feed are not
expected with either alternative. Food and feed derived from event H7-1 is equivalent to food
and feed derived from conventional sugar beets. Because both conventional and event H7-1
sugar beets are processed in the same facilities, there is no distinction in the US between food
and feed derived from conventional and event H7-1 sugar beets. Markets are available for all
the food and feed produced. Because there is no commercial organic sugar beet industry in the
US, organic sugar beet production is not impacted in any way.
Aside from sugar, the other products from sugar beets (molasses and pulp) are not major
consumer items and can easily be avoided by consumers who do not wish to be exposed to GE
products. As discussed above, there is no detectable DNA in processed sugar; however,
consumers who wish to avoid all products derived from GE crops can purchase cane sugar
rather than beet sugar. While processed foods, the situation is similar to that for corn and soy
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products: even without event H7-1 , it wouid be very difficult for a consumer to avoid products
derived from GE crops.
3.1 2 WEED CONTROL AND GLYPHOSATE RESISTANCE
As indicted in Section 1, EPA is responsible for regulation of glyphosate and thus for issues of
weed resistance to glyphosate (EPA, 2003),. This report nevertheless analyzes those issues.
APHIS’S 2005 EA did so as well, and the court did not find a deflcienoy in that analysis. APHIS
has performed other herbicide resistance analyses in many E As conducted as part of the
petition review process (see http.7/www.aphis.usda.gov/biotechnolDgy/not_reg.html).
3.12.1 Herbicide-resistant weeds
As explained in Section 2.5, not all weed species respond the same to every herbicide mode of
action. Instead, a weed species can have a natural resistance to a particular mode of action,
and if a grower employs only that mode of action, over time, the naturally resistant species will
overtake other weed species in that area. This is often referred to as a shift in the weed
population. It is for this reason that growers may need to use multiple products to control the full
spectrum of weeds in a field.
Sugar beet weed management, including major weeds in sugar beets, herbicides used,
herbicide mode of action and herbicide resistance, was discussed in Section 2.4. Table 3-1
summarizes the major sugar beet weeds in terms of resistance to herbicide groups used in
sugar beets for the states where sugar beets are grown commercially. A weed is listed for a
state when herbicide resistance has been confirmed. The table does not show the extent of the
weeds with the noted resistance; this would vary widely. References for the table are included
at the bottom of the table.
As of June 27, 2010, 194 herbicide-resistant weed species (341 herbicide resistant weed
biotypes) have been documented worldwide (Heap, 2010). These species have been reported
to be resistant to 19 different herbicide modes of action (Heap, 2010). Approximately five
Table 3-1 Major sugar beet weeds with resistance to herbicides groups used in
sugar beets’
California
Species Common Name Year~ Herbicide Mode of Action
1 . Echinochha crus-gaUi Bamyardgrass 2000 ACCase inhibitor
2, Ecliinocitloa crus-gaUi Bamyardgrass 2000 fatty acid synthesis inhibitor.
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Colorado
Soecies
Common Name
Year"
Herbicide Mode of Action
1 . .4ramanfhiis retrojhxus
Redroot pigweed
1982
photosystems II inhibitors
2. Kochia scoparia
Kochia
1982
photosystems II inhibitoi^
3. Kochia scoparia
Kochia
1989
ALS inhibitors
4. Avenafatua
Wild Oat
1997
ACCase inhibitors
Idaho
Snecies
Common Name
Year^
Herbicide Mode of Action
1 . Kochia scoparia
Kochia
1989
ALS inhibitors
2. Avenafatua
Wild Oat
1992
ACCase inhibitors
3. Avenafatua
Wild Oat
1993
fatty acid synthesis inhibitor.
A. Kochia scoparia
Kochia
1997
synthetic auxins
5. Aramaniiis retroflexus
Redroot pigweed
2005
photosystems 11 inhibitors
Michigan
Year
Snecies
Common Name
Herbicide Mode of Action
1 . Cbenopodium album
Lambsquarters
1975
photosystems 11 inhibitors.
1. Amaranthus tuberculatus
Tail waterhemp
2000
ALS inhibitors
3. Amaranthus poweilis
Powell Amaranth
2001
photosystem 11 inhibitors
4. Amaranthus poweilis
Powell Amaranth
2001
ureas and amides
5. Amai-anthus reirqfJexus
Redroot Pigweed
2001
photosystems T1 inhibitors.
6. Chenopodium album
Lambsquarters
2001
ALS inhibitors
7. Amaranthus hybridus
Smooth Pigweed
2002
AJLS inhibitors
8. Abutihn theophrasli
Veivetleaf
2004
photosystems 11 inhibitors
9. Solamau ptycanihum
East. Black nightshade
2004
photosystems II inhibitors
10. Solanum ptycanthum
Bast. Black nightshade
2004
photosystems II inhibitors.
1 1 . Kochia scoparia
Kochia
2005
ALS inhibitors
12. Setariafaberi
Giant Foxtail
2006
ALS inhibitors
Minnesota
Snecies
Common Name
Year
Herbicide Mode of Action
1 . Cbenopodium album
Lambsquarters
1982
photosystems 11 inhibitors. (PI)
2. Abutiion theophrasli
Veivetleaf
1991
PI
3. Amaranthus retroflexus
Redroot Pigweed
1991
PI
4. Avenafatua
Wildcat
1991
ACCase inhibitors
5. Amaranthus tuburculatus
Tall Waterhemp
2007
glycine, ALS, PI
6. Ambrosia trifida
Giant ragweed
2006
glycine, ALS inhibitors, PI
7. Kochia scoparia
Kochia
1994
ALS inhibitors
8. Xanthium stnimarium
Common cocklebur
1994
ALS inhibitors
7. Setariafaberi
Giant Foxtail
1996
ALS inhibitors
9. Seiaria viridis
Robust White Foxtail 1996
(var. robusla-alba Schreiber)
ALS inhibitors
1 0. Setaria lufescens
Yellow Foxtail
1997
ALS inhibitors
1 1 . Ambrosia trifida
Giant ragweed
2006
glycines
12. Amaranthus tiiberculafus
Tall waterhemp
2007
glycines
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Montana
Soecies
Common Name
Year"
Herbicide Mode of Action
I. Kochia scoparia
Kochia
1984
photosystems II inhibitors
2. Kochia scoparia
Kochia
1989
ALS inhibitors
3. AvenafaWa
Wild Oat
1990
fatty acid synthesis inhibitor.
4. Avenafatua
Wild Oat
1990
ACCase inhibitors
5. Kochia scoparia
Kochia
1995
synthetic auxins
6. Avena fatua
Wild Oat
1996
ALS inhibitors
7. Awnafaiua
Wild Oat
2002
ACCase inhibitors
Nebraska
Soecies
Common Name
Year-
Herbicide Mode of Action
1 . Amaranthus tubercuialus
Tall waterliemp
1996
photosystem 11 inhibitors
North Dakota
Soecies
Common Name
Year
Herbicide Mode of Action
1. Kochia scoparia
Kochia
1987
ALS inhibitors
2. Setaria viridis
Green Foxtail
1989
mitois inhibitors
3. Avenafatua
Wild Oat
1991
ACCase inhibitors
4. Kochia scoparia
Kochia
1995
synthetic auxins
5. Avenafatua
Wild Oat
1996
ALS inhibitors
6. Kochia scopcuia
Kochia
1998
photosystems 11 inhibitors
7. Amaranthus retrofexus
Redroot Pigweed
1999
ALS inhibitors
8. Solanum ptycanthuni
Eastern Blk.Nightshade
1999
ALS inhibitors
Oregon
Soecies
Common Name
Year
Herbicide Mode of Action
1. Avenafatua
Wild Oat
1190
ACCase inhibitors
1. Avenafatua
Wild Oat
1990
mitosis inhibitors
3. Kochia scoparia
Koclila
1993
ALS inhibitors
4. Aniarantlnts retrof exits
Redroot Pigweed
1994
photosystems U inhibitor.
Washington
Soecies
Cnmmoo Name
Year"
Herbicide Mode of Action
L Kochia scoparia
Kochia
1989
ALS inhibitors
2. Avenafatua
Wild Oat
1991
ACCase inhibitors
3. Amaranthus powelUs
Powell Amaranth
1992
photosystem IT inhibitors
4. Sonchiis asper
Spiny Sowthistle
2000
ALS inhibitors
Wyoming
Soecies
Common Name
Year"
Herbicide Mode of Action
1 . Kochia scoparia
Kochia
1984
photosystems 11 inhibitors
2. Kochia scoparia
Kochia
1996
ALS inhibitors
Legend:
' Source: Heap, I. The International Survey of Herbicide-resisfanI Weeds. Online. Internet. Accessed on June
21, 2010 at; mm. weadscience. com .
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^ Year resistance was first reported.
percent of resistant species have resistance to EPSPS inhibitors (glycines, wrhich include
glyphosafe). Refer to Figure 2-3 for the distribution by herbicide mode of action.
Measures to reduce the development of herbicide resistance are discussed in Section 2.5.
3.12.2 Glyphosate-resistant weeds
As discussed in Section 2.5, herbicide resistance is not a unique or new phenomenon. The
development of weeds resistant to a particular herbicide mode of action is an issue that growers
have faced for decades. As with other herbicide modes of action, not all weeds respond the
same to glyphosate, and some species naturally vary in their tolerance to the herbicide.
Because of the nature of glyphosate and its high degree of specificity, generally speaking, there
is a reduced potential that there will be a selection for weed resistance, Glyphosate is a
nonselective, foliar-applied, broad spectrum, post-emergent herbicide compared to many other
herbicide groups, it operates by binding to a specific enzyme in plants thereby interfering with
the plant's required metabolic process. Glyphosate is the only herbicide that binds with this
enzyme, and therefore it is highly specific (Cole, 2010a, p5).
Currently in the U.S., there are two known mechanisms of glyphosate resistance. The first is
the exclusion mechanism in which glyphosate is either prevented from moving to growing cells
or from reaching the target protein. Mechanisms that confer this form of resistance are
relatively rare and are not common across plant species. The second mechanism, gene
amplification, results from an increase in enzyme gene copies in the plant which leads to higher
levels of resistance to glyphosate (Cole, 2010a, p.5).
Accordingly, while glyphosate has been used extensively for over three decades, there have
been relatively few cases of resistance development, as compared to many other herbicides
and when considering the substantial glyphosate-treated acreage worldwide (approximately 1
billion acres) and the total number of weeds that the herbicide can control. In the U.S., there
are ten weed species where glyphosate-resistant biotypes are known to exist in certain areas of
the country (19 weeds have been reported to have developed glyphosate resistance at some
location worldwide). These resistant weeds represent a relatively small minority of the overall
weed population. For example, in 2009, approximately 135 million of the 173 acres of com,
soybeans and cotton in the U.S. were planted with a herbicide tolerant variety, with the most
common tolerance trait being glyphosate tolerance (USDA NASS, 2009a). At the same time,
only about 6% of the total planted corn, soybean and cotton acres in the U.S. are estimated to
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have some level of presence of weeds resistant to glyphosate (Ian Heap as reported by WSSA,
2010).
A weed scientist from the University of Wyoming who specializes in sugar beet weed control,
has testified that in the coming years, "it is highly unlikely that the use of glyphosate in
connection with GR [glyphosate resistant] sugar beet will result in the same conditions that have
led to GR weeds in other GR crops” (Kniss, 2010, p. 3). This is in part because of the
fundamentally different growing practices with sugar beet, Kniss reports that more diverse
cropping systems (with more rotations and herbicide modes of action), such as those used with
sugar beets "are less likely to result in weed resistance issues” (Kniss, 2010, p. 3).
Approximately half of the GR weeds noted worldwide to date have been found in non-GR
cropping systems (such as orchards), in the U.S., of the confirmed GR weeds, two evolved
where there was no GR crop use (roadsides, vineyards, and tree crops) (Kniss, 2010a, p. 2).
GR sugar beet production systems are different than other GR crops, in part because multiple
year crop rotations are an integral component of effect weed and pest management programs
for the sugar beet crop in all sugar beet growing regions (Kniss, 201 Oa, p. 3). Given that the
sugar beet crop is susceptible to many diseases, nematodes, and insects, multiple crop rotation
is required to limit the economic impact of those pests. As such, sugar beet production grower
agreements with sugar processers will typically prohibit growers from planting a sugar beet crop
in consecutive years (Kniss, 2010a, p. 3).
Instead, sugar beets are generally grown on a three- to four-year rotation. While other GR
crops may be included In the rotation with GR sugar beets (with the exact rotation varying in
different sugar beet growing regions) (Table 2-2), "the crop rotation in itself will reduce the
potential for herbicide resistant weed development due to changing cultural practices between
crops (such as planting date, harvest date, tillage practices, etc.)" (Kniss, 2010, p. 4).
As discussed above, the characteristics of glyphosate itself reduce the potential for the
development of herbicide resistance as compared to other herbicide families. As such, certain
herbicide families have been classified according to their risk of resistant weed development.
Beckie (2006) lists acetolactate synthase (ALS) and acetyl CoA carboxylase (ACCase) inhibiting
herbicides as "High" risk for resistance development, while glyphosate is considered a “Low”
risk herbicide for the development of herbicide resistant weeds. ALS and ACCase inhibiting
herbicides are commonly used in conventional sugar beet production, and weeds resistant to
these two herbicide groups are widely distributed across sugar beet growing regions of the U.S.
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(Kniss, 2010a, p4) (Figure 2-4). Glyphosate tolerant sugar beets can help delay resistance to
these herbicides (Kniss, 2010, pp. 4 - 5):
In fact, glyphosate resistant sugar beet adds to the diversity of herbicide modes of action in
many sugar beet crop rotations because it introduces a new mode of action (glyphosate)
into the rotation with non-glyphosafe-resistant crops, that tend to rely heavily upon
acetoiactate synthase (“ALS’) inhibitors. ALS inhibiting herbicides pose a far greater risk
of developing weed resistance than does glyphosate. By adding glyphosate to their crop
rotations, growers of GR sugar beet actually decrease the likelihood of developing
resistance to ALS inhibitors, just as the use of other crops and alternative modes of action
in rotation with GR sugar beet reduce the likelihood of glyphosate resistant weeds.
Use of herbicides with different modes of action, either concurrently or sequentially, is an
Important defense against weed resistance (Weed Science Society of American [WSSA],
2010b). "Use of a single product or mode of action for weed management is not sustainable.
Some of the best and most sustainable approaches to prevent resistance include diversified
weed management practices, rotation of modes of action and especially the use of multiple
product ingredients with differing modes of action" (WSSA, 201 0).
The WSSA reports higher levels of awareness among growers regarding the need to minimize
the potential for development of glyphosate resistance: “In a market research study that
surveyed 350 growers in 2005 and again in 2009, in response to the question, 'are you doing
anything to proactively minimize the potential for resistance to glyphosate to develop,’ 67% said
yes in 2005 and 87%i said yes in 2009" (David Shaw, as reported in WSSA, 2010). "In a 2007
survey of 400 com, soybean and cotton growers, resistance management programs were often
or always used by 70% or more of all three grower groups” (Frisvold and Hurley as reported by
WSSA, 2010). There is widespread information available from universities and other sources
regarding glyphosate resistance. Public universities (i.e. North Dakota State University,
University of Minnesota), herbicide manufacturers ( i.e. www.weedresistancemanagement.com,
www.resistanoefighter.com) and crop commodity groups (i.e. National Com Growers
Association, American Soybean Association) have internet web sites with information on
prevention and management of herbicide resistance. An example of information provided by
public universities is Dr. Don Morishita, a weed scientist at the University of Idaho, who advises
sugar beet growers on weed resistance management strategies (Dumas, 2008). The Sugar
industry Biotech Council provides weed resistance resources on its website. Monsanto includes
information on weed resistance management practices in its Technology Use Guide that is
mailed annually to al! licensed growers. The sugar beet industry associations also hold annual
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meetings where weed resistance management practices and other stewardship measures are
included as part of the proceedings.
Sugar beet growers in particular have strong financial and practical interests in managing weeds
effectively to reduce the development of herbicide resistance in order to maximize yield
potential. Sugar beets are a high-value crop, and competition from weeds for moisture and light
can negatively impact yields and the overall value of the crop. The development of glyphosate-
resistant weeds harms the economic return per acre for the individual farmer and the entire
sugar beet industry (Cote, 2010a, pi 1).
As such, strategies and recommendations to delay the development of glyphosate-resistant
weeds have been developed forevent H7-1 sugar beefs (TUG, Appendix E), Specifically, the
TUG recommends the use of “mechanical weed confrol/cultivation and/or residual herbicides"
with event H7-1 sugar beets, where appropriate, and "additional herbicide modes of
action/residual herbicides and/or mechanical weed control in other Roundup Ready® crops”
rotated with event H7-1 (TUG, 2010, p. 40). In addition to the financial incentive to follow these
recommendations, all Roundup Ready technology users, including sugar beet growers, are
contractually obligated through the Monsanto Technology Stewardship Agreement to follow the
TUG.
3.12.3 Impact summary
Alternative 1
Under Alternative 1, there would be no effect of event H7-1 on the potential for weeds to
develop resistance to glyphosate, given that glyphosate use is minimal with conventional sugar
beets. Growers would continue to use conventional weed control methods, including other
herbicide modes of action, to the extent such conventional herbicides are available (see Section
2.5). A return to conventional herbicides could have consequences for development of further
resistance to those herbicides.
As discussed above, glyphosate use in GR sugar beet has proven to be an effective tool against
weeds resistant to non-glyphosate herbicides, such as ALS-inhibitors and ACCase-inhibitors. if
the planting of H7-1 sugar beets is substantially curtailed, a valuable tool for herbicide resistant
weed management will be unavailable to sugar beet growers, and the impact of weeds resistant
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to other herbicides may increase, although the impact would likely be small since sugar beets
are a relatively small crop (Kniss, 2010a, p. 7).
Alternative 2
Under Alternative 2, impacts, if any, with respect to the development of glyphosate-toleranf
weeds in sugar beet crops in the timeframe considered in this ER are expected to be very small.
First, sugar beets are a relatively small crop, (event H7-1 accounts for less than one percent of
the glyphosate-resistant crops grown in the US), suggesting that the likelihood for the
development of new glyphosate-resistant weed populations when compared to other herbicide
resistant crops is smaller, Second, as discussed above, the nature of glyphosate itself and the
growing practices for sugar beets makes it less likely that new glyphosate-resistant weed
populations will develop in sugar beets as a result of the use of glyphosate in sugar beefs.
Additionally, there is a high level of awareness about the potential for glyphosate resistant
weeds and many readily available resources to assist growers with management strategies,
indeed, event H7-1 growers are required to follow Monsanto's TUG, including its
recommendations for adopting growing practices aimed at reducing the development of
glyphosate-resistant weed populations. Finally, because herbicide resistance is a heritable trait,
it takes multiple growing seasons for herbicide tolerant weeds to emerge and become the
predominant biotype in a specific area (Cole, 2010a, p. 4). Researchers have concluded that
even if growers completely relied on only one herbicide. It is likely to take at least five years for a
herbicide-resistant weed population to develop (Kniss, 2010a, p4; Beckie 2006, Neve, 2008;
Werth et ai., 2008). This is a reason why crop monitoring and follow up by University and
industry weed scientist in cases of suspected resistance are important parts of all herbicide
resistance stewardship programs.
3.13 PHYSICAL
3.13.1 Land Use
As discussed in Section 2.3, acreage planted in sugar beets in the US has changed little over
the past 50 years (since 1961), ranging from a low of 1,1 million acres in 1982 (slightly less than
the 2008 acreage) to a high of 1,6 million acres in 1975. Table 3-2 shows planted sugar beet
acreage for the last six years. While there have been changes within individual states, overall
the range is small. As discussed in Section 2, a small part of the sugar beet crop was event
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Table 3-2 Sugar Beet Acres Planted 2005 to 2010
Location
2005
2006
2007
2008
2009
2010
California
44,400
43,300
40,000
26,000
25,300
25,000
Colorado
36,400
42,100
32,000
33,800
35,100
29,800
Idaho
169,000
188,000
169,000
131,000
164,000
169,000
Michigan
154,000
155,000
150,000
137,000
138,000
147,000
Minnesota
491,000
504,000
486,000
440,000
464,000
445,000
Montana
53,900
53,600
47,500
31,700
38,400
42,400
Nebraska
48,400
61,300
47,500
45,200
53,000
46,000
North
Dakota
255,000
261 ,000
252,000
208,000
225,000
227,000
Oregon
9,800
13,100
12,000
6,700
10,600
11,000
Washington
1,700
2,000
2,000
1,600
—
—
Wyoming
36,200
42,800
30,800
29,700
32,400
32,000
US Total
1,299,800
1,366,200
1,268,800
1,090,700
1,185,800
1,174,200
Source: USOA NASS, 2010
H7-1 in 2007, and in 2010, 95 percent of the planted crop was event H7-1 , During this time
period, the planted sugar beet acreage remained within the range of pre-event H7-1 plantings
since 1961.
As discussed in Section 2, sugar beet production is highly structured, vertically integrated, and
centered on production faoilities that are grower owned.. To maintain a healthy industry,
production cannot fluctuate much from year to year: a certain level of production is needed to
support the major investment of a processing facility, and a processing facility has limited
capacity. The sugar beet grower is bound to the local processing facility and the local
processing facility is bound to the sugar beet grower. Barring some unusual disruption in the
industry, large fluctuations from year to year would not be expected.
Crop data also provides no indication that the introduction and widespread adoption of GE crops
in general has resulted in any significant change to the total US acreage devoted to agricultural
production. The acres in the US planted to principal crops, which include corn, sorghum, oats,
barley, winter wheat, rye, durum, spring wheat, rice, soybean, peanuts, sunflower, cotton, dry
edible beans, potatoes, canola, proso millet, and sugar beets, has remained relatively constant
over the past 25 years (USDA NASS, 2010). From 1983 to 1995, the average yearly acreage of
principal crops was 328 million (USDA NASS, 2010). Biotechnology-derived crops were
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introduced in 1996, and in 2009, 321 million acres of principal crops were planted, which is not a
significant change (USDA NASS, 20Q9a).
Alternative 1
Under Alternative 1 , plantings of event H7-1 sugar beet would be limited and only occur under
notification or permit issued by APHIS. Growers would not have the option of planting event
H7-1 sugar beets. Since sugar beet growers are farmers who also grow other crops, those who
would have grown sugar beets could most likely grow some crop, but they could nevertheless
suffer significant losses as a result (See Section 2,3). They may choose to grow conventional
beets or other crops. A number of factors may influence this decision, including availability of
herbicides for conventional sugar beets, availability and cost of specialty cultivating equipment,
availability of desirable varieties of sugar beet, and the potential penalty or lost ownership
shares in the cooperative for not growing sugar beets. In the short term (the term considered by
this ER), Alternative 1 could potentially result in a large decrease in sugar beet production.
However, changes in land use would not be expected and the land use is likely to remain
agricultural.
Alternative 2
Under Alternative 2, growers who choose to do so could continue to plant event H7-1 sugar
beets. Sugar beet acreage would be expected to be similar to the levels of the past 50 years.
Land use that is agricultural would be expected to remain so and other land use would not be
impacted.
3.13.2 Air Quality and Climate
Alternative 1
Under Alternative 1 , plantings of event H7-1 sugar beet would be limited and only occur under
notification or permit issued by APHIS. Because the use of giyphosate as a post-emergence
herbicide has resulted and is expected to continue to result in an increase in conservation tillage
practices, an increase in the use of mechanical tilling would be expected under Alternative 1 , if
growers would choose to plant conventional sugar beets. If growers would choose other crops,
the effects would depend on what the other crops would be. Emissions related to global
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warming, ozone depletion, summer smog and carcinogenicity, among others, were found to be
lower in giyphosate-tolerant crop systems than conventional systems (Bennett et al., 2004).
Therefore, Alternative 1 would be expected to have slightly greater impacts on air quality and
climate, if growers planted conventional sugar beets rather than event H7-1 sugar beets.
Alternative 2
Under Alternative 2, growers who choose to do so could continue to plant event H7-1 sugar
beets. The continued use of event H7-1 sugar beets may result in continued increases in
conservation tillage, as discussed in Section 2 (changing to conservation tillage practice is
gradual, as it often requires different management practices and often requires new equipment).
Therefore, Alternative 2 would lead to a small but positive impact on air quality and climate
relative to Alternative 1.
3.13.3 Surface water quality
Surface water may be impacted from sugar beet production by runoff from sugar beet fields that
carries soil particles and herbicides or other pesticides to streams, rivers, lakes, wetlands and
other water bodies. As discussed below, based on existing data, the soil component of runoff is
a much more important contributor to surface water impacts than is the pesticide component.
Alternative 1
Under Alternative 1 , plantings of event H7-1 sugar beet would be limited and only occur under
notification or permit issued by APHIS. Under Alternative 1, growers who are now growing
event H7-1 sugar beets and who would choose to grow conventional sugar beefs would need to
use other practices for weed management. These practices would likely consist of some
combination of herbicide use and increased tillage (beyond conservation tillage).
If Alternative 1 would result in increased use of tillage for weed control, overall adverse surface
water impacts are likely to be greater than with Alternative 2. Tillage causes widespread soil
disturbance. Thus, wind and water erosion, topsoil loss and the resulting sedimentation and
turbidity in streams are likely to increase with Increased tillage. In 2009, based on the states'
water quality reports, EPA identified sedimentation and turbidity as two of the top 10 causes of
impairment to surface water in the U.S. in general; in 2007, EPA identified
sedimentation/siltation as the leading cause of impairment to rivers and streams in particular
(EPA, 2009, p. 15; EPA, 2007, p, 9). Although a comprehensive data set has not yet been
developed to prove the point, EPA has projected conservation tillage to be “the major soil
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protection method and candidate best management practice for improving surface water quality"
(EPA, 2002), EPA identifies conservation tillage as the first of its CORE 4 agricultural
management practices for water quality protection (EPA, 2008a).
Based on the states' water quality reports to EPA, which EPA makes available through its
National Assessment Database, pesticides in general and herbicides in particular are a
relatively minor contributor to impairment of surface water in the U.S., compared to
sedimentation/siltation and turbidity (EPA 2008b). Of the pesticides that were reported as
contributing to impairment, almost all are previously used, highly persistent chemicals that are
no longer registered for use in the U.S, Only one herbicide, atrazine, was found (EPA 2008b),
In summary, based on EPA data, herbicides in general are very minor contributors to surface
water impairment in the U.S,, whereas sedimentation/siltation and turbidity are major
contributors. Alternative 1 , compared with Alternative 2, would likely result in a different mix of
herbicides used and may result in increased tillage. Increased tillage could contribute to
adverse surface water impacts through increased runoff of soil particles to surface water bodies.
Alternative 2
Alternative 2 would result in continued application of glyphosate herbicides to event H7-1 sugar
beets. Herbicides that adsorb strongly, such as glyphosate, are less likely to degrade or
volatilize (USDA APHIS, 2009).
Other herbicides used on sugar beets have varying chemical fates, but, in general, most are
more persistent and are characterized by higher mobility in soils, making them more apt to
continually contaminate surrounding water systems.
3.13.4 Groundwater quality
Alternative 1
Under Alternative 1 , if growers choose to grow conventional sugar beets, the potential for
impacts to groundwater would be similar to that prior to the widespread adoption of event H7-1
sugar beefs. If herbicides are used that do not bind strongly to soil particles, and have a higher
potential to leach into groundwater, the potential for migration to groundwater may be higher
than with Alternative 2.
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Alternative 2
Because glyphosate binds strongly to soil, and has a low potential to leach into groundwater, it
is unlikely to impact groundwater.
3.14 BIOLOGICAL
Potential environmental effects of pesticide use are carefully considered as a part of the FIFRA
pesticide registration process. Prior to the approval of a new pesticide or a new use of that
pesticide (including a change in pesticide application rates and/or timing) and before
reregistering an existing pesticide, EPA must consider the potential for environmental effects
and make a determination that no unreasonable adverse effects to the environment will be
caused by the new pesticide, new use or continued use.
To make this determination, EPA requires a comprehensive set of environmental fate and
ecotoxicological data on the pesticide’s active ingredient (US 40 CFR Part 158). EPA uses
these data to assess the pesticide's potential environmental risk (exposure/hazard). The
required data include both short- and long-term hazard data on representative organisms that
are used to predict hazards to terrestrial animals (birds, nontarget insects, and mammals),
aquatic animals (freshwater fish and invertebrates, estuarine and marine organisms), and
nontarget plants (terrestrial and aquatic).
Information regarding the impacts of glyphosate on the biological environment is summarized
below. Additional information on this topic is also being considered in the USDA APHIS Draft
Environmental impact Statement (DEIS) on the Deregulation of Glyphosate Tolerant Alfalfa
(Docket No. APHIS-2007-0044). This information is applicable to the use of glyphosate in event
H7-1 sugar beet since the maximum single in-crop application rate for GT alfalfa (1.55 lb a.e./A)
is greater than the maximum single in-crop application rate for sugar beet (1 .1 25 lb a.e./A).
3.14.1 Plant and Animal Exposure to Glyphosate
Animals
The equivalence of the CP4 EPSPS enzyme to native EPSPS except for tolerance to
glyphosate is discussed in Sections 3.1 and 3.11. A number of researchers have conducted
laboratory investigations with different types of arthropods exposed to genetically engineered
crops containing the CP4 EPSPS protein (Goldstein, 2003; Boongird et al., 2003; Jamornman,
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et al., 2003; Harvey et al., 2003). Representative pollinators, soil organisms, beneficial
arthropods and pest species were exposed to tissues (pollen, seed, and foliage) from GE crops
that contain the CP4 EPSPS protein, to evaluate potential toxicity. These studies, although
varying in design, all reported a lack of toxicity observed in various species exposed to these
crops (Nahas et at, 2001 ; Dunfield and Germida, 2003, Siciliano and Germida 1 999).
As a part of the reregistration evaluation under FIFRA, EPA conducted an ecological
assessment for glyphosate. This assessment compared the results from toxicity tests with
glyphosate conducted with various plant and animal species to a conservative estimate of
glyphosate exposure in the environment, the Estimated Environmental Concentration (EEC). .
Glyphosate is practically nontoxic to slightly toxic to birds, freshwater fish, marine and estuarine
species, aquatic invertebrates and mammals and practically nontoxic to honey bees (which are
used to assess effects on nontarget insects in general) (EPA, 1993, pp. 50, 38 - 40, 45, 47, 48 -
50). Glyphosate has a low octanol-water coefficient, indicating that it has a tendency to remain
in the water phase rather than move from the water phase into fatty substances; therefore, it is
not expected to accumulate in fish or other animal tissues.
In the Reregistration Eligibility Decision (RED) for glyphosate (EPA, 1993, p. 53), the exposure
estimates were determined assuming an application rate of 5.0625 lb a.e., which exceeds the
maximum labelled use rate for a single application for agricultural purposes. When the EECs
were calculated for aquatic plants and animals, the direct application of this rate to water was
assumed. Based on this assessment, EPA concluded that effects to birds, mammals, fish and
invertebrates are minimal based on available data (EPA, 1993).
The glyphosate end-use products used in agriculture contain a surfactant to facilitate the uptake
of glyphosate into the plant (Ashton and Crafts, 1981). Depending on the surfactant used, the
toxicity of the end-use product may range from practically nontoxic to moderately toxic to fish
and aquatic invertebrates (EPA, 1993, pp. 42 - 45). For this reason, the 1993 Glyphosate RED
stated that some formulated end-use products of glyphosate needed to be labeled as “Toxic to
fish" if they were labeled for direct application to water bodies. Due to the associated hazard to
fish and other aquatic organisms, glyphosate end-use products that are labeled for applications
to water bodies generally do not contain surfactant, or contain a surfactant approved for direct
application to water bodies.
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Soil Microorganisms
Microorganisms produce aromatic amino acids through the shikimate pathway, similar to plants.
Since glyphosate inhibits this pathway, it could be expected that glyphosate would be toxic to
microorganisms. However, field studies show that glyphosate has little effect on soil
microorganisms, and, in some cases, field studies have shown an increase in microbia! activity
due to the presence of glyphosate (USDA FS, 2003).
Based on the data available on glyphosate usage, chemical fate, and toxicity, glyphosate is not
expected to pose an acute or chronic risk to the following categories of wildlife; (EPA, 1 993)
• birds,
• mammals,
• terrestrial invertebrates,
• aquatic invertebrates, and
• fish
• soil microorganisms
Alternative 1
Under Alternative 1 , the potential for impacts to animal species may be greater than with
Alternative 2 because of the return to greater use of additional herbicides, potentially with higher
toxicities.
Alternative 2
As stated previously, Alternative 2 is expected to result in the continued use and application of
glyphosate-based herbicide formulations. This could result in continued glyphosate exposure to
animal species within and adjacent to those fields through drift, as discussed previously, and a
decrease in exposure to other herbicides from runoff and/ or drift (USDA APHIS, 2009).
Considering the potential for aquatic exposure to glyphosate formulations from
terrestrial uses, EPA recently evaluated the effect of glyphosate and its formulations on another
amphibian species, the California red-legged frog, and concluded that aquatic exposure to
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glyphosate or its formulations posed no risk to this threatened species (EPA, 2008b). Because
EPA considered a wide range of application rates in their evaluation for the red-legged frog, this
conclusion can also be applied to amphibians exposed to glyphosate from applications on event
H7-1 sugar beet. Any possible adverse impacts to amphibians resulting from the deregulation
of event H7-1 sugar beet may be offset by the shift from other herbicides used in sugar beef
cultivation, which are considered to have higher environmental impacts in general. .
Additionally, amphibian habitat in watersheds where event H7-1 sugar beet is produced could
be improved through conservation tillage, resulting in decreased soil erosion, decreased
sedimentation in runoff, and decreased turbidity in ponds, lakes, and rivers fed by surface
waters.
Plants
Glyphosate is a non-selective herbicide with post-emergence activity on essentially all annual
and perennial plants. As discussed in Section 3.1,1, this activity is due to inhibition of EPSPS,
an enzyme involved in aromatic amino acid synthesis. As with any herbicide, a risk exists that
spray drift could pose issues for plants on the borders of the target fieldHowever, EPA takes the
potential for spray drift into account when conducting the risk assessment it uses to establish
pesticide application rates and direction for use, which are designed to minimize spray drift
risks.. As discussed earlier, glyphosate binds tightly to agricultural soils and is not likely to
move offsite dissolved in water. Moreover, glyphosate is not taken up from agricultural soil by
plants. However, because drift is a potential means of exposure to non-target plants adjacent to
an event H7-1 sugar beet field; Monsanto conducted a threatened and endangered (TE)
species risk assessment to evaluate the impacts to plants (and animals) from the use of
glyphosate-based herbicides in conjunction with glyphosate-tolerant plants. The complete
assessment was submitted to APHIS and has been reviewed by APHiS scientists to support the
petition for deregulation of glyphosate-tolerant alfalfa. The assessment is available on the
APHIS, BRS website at http://wvi/w.aphis. usda.gov/biotechnology/alfalfa_documents.shtml
The assessment identified some plant, but no animal, species for which glyphosate when
aerially applied could pose issues in areas bordering fields in certain locations where sugar
beets are grown. To address any such risks, Monsanto developed Pre-Serve, a web-based
program designed to eliminate any potential impacts on TE plants resulting from the agricultural
use of herbicides that contain glyphosate.
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Pre-Serve instructs growers to observe specific precautions when spraying glyphosate
herbicides on Roundup Ready® crops near TE plant species that may be at risk. Only a very
small percentage of glyphosate applications will require mitigation measures. This is because
the vast majority of U.S. cropland is outside of the Pre-Serve Use Limitation Areas - areas
where threatened or endangered plant species may be present - and most glyphosate
applications are made using ground application equipment at rates below 3,5 pounds of active
ingredient per acre (lb a.e./acre), which will not impact the TE piant species.
Growers who are licensed to purchase and use seeds containing Roundup Ready® technology
are required contractually to follow the requirements in Monsanto's Technology Use Guide.
This includes the requirement to access the Pre-Serve website fwww.pre-serve.orgj or contact
Monsanto before applying glyphosate-based herbicide products to crops grown from these
seeds. This website will guide growers and applicators through a user-friendly, four-step
process to determine whether their fields are located within Use Limitation Areas and, if so, to
identify the mitigation measures that must be taken. For fields located within Use Limitation
Areas, the following mandatory steps must be taken to reduce potential risks to TE plant
species:
• Ground applications are limited to rates of less than 3.5 lb a.e./acre (most uses).
• Aerial applications may be prohibited in buffer zones along perimeters of fields. The size
of buffer zones can be minimized by employing a coarser spray droplet size.
• In specified counties, aerial applicators will be required to observe a new maximum use
rate of 0.92 lb a.e./acre (26 fi. oz/A Roundup PowerMAX® or WeatherMAX®) if using
medium spray droplets^®, but can apply the current full labeled rate (1.55 lb a.e./acre or
44 fl. oz/acre of Roundup PowerMAX or WeatherMAX) if using coarse spray droplets.
In addition to the instructions provided by Pre-Serve, mitigations from local, state or federal
protection programs and/or landowner agreements may apply. Monsanto's licensees are
required to follow these measures where applicable. .
*' Roundup Ready is a registered trademark of Monsanto Technology LLC.
“ In counties where listed plant species observations were present, but not within 250 ft of a relevant land use, actual
separation distance was not assessed. In these counties aerial apf^ication rates with medium sized droplete are
restricted to 0.92 lb a.e./acre to avoid exposure to listed TE piant species that might be within 417 ft of the application
area, and thus within an area where aerial application at 1.55 lb a.e./acre using medium-sized spray droplets would
present a potential risk based on the Tier 1 assessment This restriction vwll be eliminated in many cases by further
distance assessments.
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The Pre-Serve web-based system, as described above, enables growers and applicators to
take steps where necessary to avoid potential effects to TE plant species from application of
glyphosate-based agricultural herbicides.
Alternative 1
Under Alternative 1 , the rates and volumes of glyphosate applications on sugar beet crops
would likely return to the level of use that existed prior to the deregulation of event H7-1 sugar
beets. Growers would use an array of other herbicides, some of which may be applied at
greater volumes compared to glyphosate. The herbicides used in conventional sugar beet
systems have been found, in general, to have somewhat greater human health or environmental
impacts than glyphosate (USDA, 2004). This is consistent with the EPA decision to grant
reduced risk status for glyphosate use in glyphosate-tolerant sugar beets. Error!
Bookmark not defined. Comparison of results from terrestrial and aquatic plant studies
with predicted exposure from herbicide use suggests that most of the herbicides used in
conventional sugar beet systems may have more effect than glyphosate on aquatic or terrestrial
plant species. These herbicides are selective herbicides that kill only particular groups of plants
such as annual grasses, perennial grasses, or broadleaf weed species and thus require the use
of more than one herbicide to achieve satisfactory weed control.
Alternative 2
Alternative 2 is expected to result in continued use and application of glyphosate-based
herbicide formulations. This could result in some incidental glyphosate exposure to terrestrial
and aquatic plants in the vicinity of event H7-1 beet fields by spray drift. The EPA has
concluded that glyphosate use on event H7-1 sugar beet can be considered to pose reduced
risk compared to other herbicides used for weed control in conventional sugar beets.'''’
. . Hundreds of millions of acres of other GT crops have been treated with glyphosate for over
ten years with minimal impact to adjacent non-target terrestrial plants including crops when
appropriate drift minimization measures are practiced. Because glyphosate binds strongly to
soil particles and has no herbicidal activity after binding to soil, no effects on aquatic plants will
result from surface water runoff from glyphosate use on event H7-1 sugar beet in accordance
with labeled directions for use.. Conservation tillage and no tillage practices that are possible
A reduced risk decision is made at the use level based on a comparison between the proposed use of the
pesticide and exisHng alternatives currently registered on that use site. A list of decisions regarding Reduced Risk
Status can be found at: httD.V/www.eDa.Qov/oDDrdOOIAvorkDlan/feducedrisk.htmt
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when glyphosate is used have the potential to decrease surface water runoff and sedimentation
which further benefits aquatic organisms.
3.14.2 Threatened and Endangered Species
As the action agency for pesticide registrations EPA has the responsibility to conduct an
assessment of effects of a registration action on endangered species. The EPA Endangered
Species Protection Program web site, http://www.epa.qov/espp/ . describes the EPA
assessment process for endangered species. Some of the elements of that process, generally
taken from the web site, are summarized below.
When registering a pesticide or reassessing the potential ecological risks from use of a currently
registered pesticide, EPA evaluates extensive exposure and ecological effects data to
determine how a pesticide will move through and break down in the environment. Risks to
birds, fish, invertebrates, mammals and plants are routinely assessed and used in EPA's
determinations of whether a pesticide may be licensed for use in the U.S.
EPA’s core pesticide risk assessment and regulatory processes ensure that protections are in
place for ail populations of nontarget species. Because endangered species may need specific
protection, EPA has developed risk assessment procedures described in the Overview of the
Ecological Risk Assessment Process (U.S. EPA, 2004d, p. 7) to determine whether individuals
of a listed species have the potential to be harmed by a pesticide, and if so, what specific
protections may be appropriate. EPA's conclusion regarding the potential risks a pesticide may
pose to a listed species and any designated critical habitat for the species, after conducting a
thorough ecological risk assessment, results in an "effects determination."
As a part of the endangered species effects assessment for the California red-legged frog, EPA
evaluated the effect of glyphosate at rates up to 7.95 lb a.e./A on fish, amphibians, aquatic
invertebrates, aquatic plants, birds, mammals, and terrestrial invertebrates. This assessment
determined that at the maximum application rate for in-crop applications of glyphosate to GT
sugar beets (1.125 lb a.e./A) there would be no effects of glyphosate on the following taxa of
threatened and endangered species: fish, amphibians, birds, and mammals. EPA also
determined that glyphosate formulations would have no effect on threatened or endangered
fish, amphibians, birds, and mammals. Although not specifically discussed in the assessment,
from the EEC's and effects endpoints presented, it can also be determined that there would be
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no effects of glyphosate or its formulations on threatened or endangered vascular aquatic
plants, and aquatic invertebrates (EPA, 2008b).2008). non-endangered small .H7-1 .
Monsanto has designed a web-based program fwww.Pre-Serve.orat . designed to ensure no
effect of glyphosate applications on threatened and endangered plant species. Pre-Serve
instructs growers to observe specific precautions when spraying glyphosate herbicides on
glyphosate-tolerant crops near threatened and endangered plant species that may be at risk.
According to the U.S. Fish and Wildlife Service Endangered Species website, there are no TE
terrestrial invertebrates in Colorado, Idaho, Nebraska, North Dakota, South Dakota, and
Wyoming. In other states, TE small terrestrial invertebrates, if present, are at no more risk
than from applications of glyphosate to conventionally grown sugar beets.
Alternative 1
Under Alternative 1, the potential for impacts to threatened and endangered species may be
greater than with Alternative 2 because of the use of certain herbicides with potentially higher
toxicities.
Alternative 2
As indicated, EPA is responsible for and has previously conducted analyses regarding
glyphosate impacts. Only two percent of glyphosate is applied aerially to all agricultural crops in
the US (USDA APHIS, 2009). Given that aerial application in event H7-1 sugar beets is not
expected to be any different than other agricultural production systems, approximately two
percent of glyphosate used in event H7-1 sugar beets is expected to be applied aerially.
Additionally, the use of buffer zones, based on the Pre-Serve program, between the sugar beet
field and any potential threatened or endangered plant populations can prevent any adverse
impacts due to drift of glyphosate from aerial applications (USDA APHIS, 2009), so that there
will be no effect on endangered species.
We evaluated the potential for deleterious effects or significant impacts on non-target
organisms, including those on the US Fish and Wildlife Service (USFWS) threatened and
endangered species list, from cultivation of event H7-1 sugar beet and its progeny. The enzyme
CP4 EPSPS that confers glyphosate tolerance is from the bacterium Agrobacterium sp, strain
CP4. This gene is similar to the gene that is normally present in sugar beets and is not known
■'* http://www.fws.aov/endanaered/sDecies/index.html
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to have any toxic property (Schneider, 2003). Field observations of event H7-1 sugar beet
event H7-1 revealed no negative effects on non-target organisms (Schneider, 2003). The lack
of known toxicity for this enzyme suggests no potential for deleterious effects on beneficial
organisms such as bees and earthworms. The high specificity of the enzyme for its substrates
makes it unlikely that the introduced enzyme would metabolize endogenous substrates to
produce compounds toxic to beneficial organisms (Schneider, 2003).
3.15 HUMAN HEALTH AND SAFETY
3.15.1 Consumer Health and Safety
AUernative 1
Under Alternative 1 , the potential for impacts to consumers may be greater than with Alternative
2 because of the use of herbicides with higher toxicities.
Alternative 2
The general public is not at a high risk of exposure to substantial levels of glyphosate under
typical use conditions (ERA, 1993; USDA FS, 2003). Under Alternative 2, exposure to
glyphosate would not increase beyond that currently experienced, since 95 percent of sugar
beet is already event H7- 1 . According to the ERA Glyphosate Fact Sheet (1993) glyphosate is
of relatively low oral and dermal acute toxicity and has been placed in Toxicity Category III for
these effects (Toxicity Category I indicates the highest degree of acute toxicity, and Category IV
the lowest). The acute inhalation toxicity study was waived by ERA because glyphosate is
nonvolatile and available adequate inhalation studies with end-use products show low toxicity.
The use of glyphosate herbicide does not appear to result in adverse effects on development,
reproduction, or endocrine systems in humans and other mammals. Under present and
expected conditions of use, glyphosate herbicide does not pose a health risk to humans (ERA,
1993).
Additionally, the nature of glyphosate residue in plants and animals is adequately understood,
and studies with a variety of plants indicate that uptake of glyphosate from soil is limited. The
material that is taken up is readily translocated throughout the plant In animals, ingested or
absorbed most glyphosate is essentially not metabolized and is rapidly eliminated in urine and
feces. Enforcement methods are available to detect residues of glyphosate in or on plant
commodities, in water, and in animal commodities (ERA, 1993),
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EPA conducted a dietary risk assessment for glyphosate based on a worst-case risk scenario,
that is, assuming that 100 percent of all possible commodities/acreage were treated, and
assuming that tolerance-level residues remained in/on ail treated commodities. Based on the
assessment, EPA concluded that the chronic dietary risk posed by glyphosate food uses is
minimal (EPA, 1993).
The addition of another GT crop to agricultural production may lead to a greater chance that a
GT crop, including GT sugar beets may be grown near other food crops. This could lead to
higher exposure to glyphosate in the diet of the general public because there would be a greater
chance for glyphosate residue to reach food crops via spray drift. Nonetheless, such increase
risk of exposure to glyphosate residue will not result in increased risks to the general population
because the current upper estimates of risk are based on highly conservative fruit and
vegetable intake rates with an assumed high estimated amount of glyphosate residue.
Glyphosate is registered for use as a direct application to weeds in several fruits and vegetables
and tolerances are established in the consumable commodities of these crops. The current
aggregate dietary risk assessment completed by EPA concludes there is no concern for any
subpopulation regarding exposure to glyphosate, including the use on many fruits and
vegetables and GT sugar beet (71 FR 76180, 2006). Moreover, the potential exists for
decreases in the applications and subsequent residues of more toxic herbicides if GT sugar
beet is deregulated.
3.15.2 Hazard Identification and Exposure Assessment for Field Workers
Alternative 1
Under Alternative 1 , the potential for impacts to field workers may be greater than with
Alternative 2 because of the increased need for hard labor to remove weeds and the use of
herbicides with higher toxioities.
Alternative 2
According to the RED document for glyphosate (EPA, 1993), glyphosate is of relatively low oral
and dermal acute toxicity. For this reason, glyphosate has been assigned to Toxicity Categories
III and IV for these effects (i.e., Toxicity Category I indicates the highest degree of acute toxicity,
and Category IV the lowest). An acute inhalation study was waived by EPA because
glyphosate is a non-volatile solid, and the studies conducted on the end-use product formulation
are considered sufficient (EPA, 1993). Expert toxicological reviews from US EPA (1993) and
the World Health Organization (WHO, 2004) are in agreement that glyphosate does not pose
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any human acute exposure concerns for dietary exposures and thus negated the need to
establish an acute reference dose.
With regard to subchronic and chronic toxicity, one of the more consistent effects of exposure to
glyphosate at high doses is reduced body weight gain compared to controls. Body weight loss
is not seen in multiple subchronic studies, but has at times been noted in some chronic studies
at excessively high doses a 20,000 ppm in diet (WHO, 2004), Other general and non-specific
signs of toxicity from subchronic and chronic exposure to glyphosate include changes in liver
weight, blood chemistry (may suggest mild liver toxicity), and liver pathology (USDA FS, 2003).
Glyphosate is not considered a carcinogen; it has been classified by EPA as a Group E
carcinogen (evidence of non-carcinogenicity for humans) (EPA, 1 993; 2006).
EPA has considered in its human health analysis the potential applicator and bystander
exposure resulting from increased glyphosate use. Based on the toxicity of glyphosate and its
registered uses, including use on glyphosate-tolerant crops, EPA has concluded that
occupational exposures (short-term dermal and inhalation) to glyphosate are not of concern
because no short-term dermal or inhalation toxicity endpoints have been identified for
glyphosate (71 FR 76180, 2006),
Additional evidence to support the EPA conclusion can be found in the Farm Family Exposure
Study, a biomonitoring study of pesticide applicators conducted by independent investigators
(Acquavella, et al. 2004). This biomonitoring study determined that the highest estimated
bodily adsorption of glyphosate as the result of routine labeled applications of registered
glyphosate-based agricultural herbicides to crops, including glyphosate-tolerant crops, was
approximately 400 times lower than the RfD established for glyphosate. Furthermore,
investigators determined that 40 percent of applicators did not have detectable exposure on the
day of application, and 54 percent of the applicators had an estimated bodily adsorption of
glyphosate more than 1000 times lower than the RfD (Acquavella, et at., 2004). Use patterns
and rates for glyphosate tolerant sugar beet are typical of most glyphosate agronomic practices.
Therefore, the deregulation of glyphosate-tolerant sugar beet would not significantly increase
the exposure risk to pesticide applicators.
Finally, the biomonitoring study also found little evidence of detectable exposure to individuals
on the farm who were not actively involved in or located in the immediate vicinity of labeled
applications of glyphosate-based agricultural herbicides to crops. Considering the similarity of
the use pattern and application rates of the glyphosate products in this study compared to those
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registered for use on glyphosate-toierant sugar beet and glyphosate-tolerant crops in general,
bystander exposure attributed to the use of glyphosate on glyphosate-tolerant crops is expected
to be negligible. Therefore, the use of currently registered pesticide products containing
glyphosate in accordance with the labeling will not pose unreasonable risks or adverse effects
to humans or the environment, in general, the herbicidai activity of glyphosate is due primarily
to a metabolic pathway that does not occur in humans or other animals, and, thus, this
mechanism of action is not directly relevant to the human health risk assessment. EPA
considers glyphosate to be of low acute and chronic toxicity by the dermal route of exposure.
Glyphosate is considered a Category IV dermal toxicant and is expected to cause only slight
skin irritation (USDA APHIS, 2009).
3.16 ECONOMIC IMPACTS
3.16.1 Sugar beet processing
Approximately 54% of the U.S. domestic sugar production comes from sugar beets (USDA
Farm Service Agency [FSA], 2010). Refined sugar from sugar beets is the product of a multi-
year cycle and involves beet seed suppliers, sugar beet growers, sugar beet processors, sugar
users and consumers (USDA FSA, 2010). As part of that process, beef seed suppliers plant the
commercial sugar beet seed crop in the fall of Year 1, which produces the commercial seeds
harvested in the fall of Year 2. The commercial seed is processed over the winter and sold to
sugar beet growers who plant it in the spring. Sugar beet growers harvest the beet roof in the
fall of Year 3 and deliver them to beet processing facilities owned by the beet processors. Beet
sugar is extracted by beet processors beginning in the fall of Year 3 and throughout Year 4.
The sugar produced from these beets is purchased by food manufacturers and consumers
(USDA FSA, 2010).
Of the sugar beet root crop planted in the spring of 2009, 95 percent was reported to be event
H7-1 sugar beet seed. This is also the same for the sugar beet root crop planted in the spring
of 2010, and harvested in the fall of 2010. This represents 98 percent of the sugar beetroot
crop outside of California, where, as discussed in Section 2, event H7-1 has not been grown
(USDA FSA, 2010). The harvesting of the 2010 root crop will begin between late August and
early September, depending of the projected size of the sugar beet crop. The bigger the crop,
the earlier the harvest will begin to make sure it is completed before the ground freezes, By late
August, most of the crop's sugar will have been contracted for sale (USDA FSA, 2010). The
economic impact of preventing that crop from being harvested and processed is discussed
below.
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3.16.2 USDA’s role in sugar marketing
The domestic sugar market is closely managed by USDA's sugar program and therefore, not
governed solely by supply and demand. USDA controls domestically produced sugar through
the Flexible Sugar Marketing Allotment Program, and controls foreign imports through the raw
and refined sugar tariff-rate quotas (TRQs). Unlimited amounts of refined sugar can be
imported under a high duty of 1 6.3 cents per pound and raw sugar of 1 5.36 cents per pound.
Under section 156 of the Federal Agriculture Improvement and Reform Act of 1996, as
amended by the Food Conservation, and Energy Act of 2008 (the Farm Bill), and the
Harmonized Tariff Schedule of the United States (HTS), USDA is required to establish a range
of acceptable market conditions, which means maintaining a price floor in potentially
oversupplied situations by removing surplus supply, and maintaining “adequate supply” in
potentially undersupplied market situations (USDA FSA, 2010). The minimum raw and refined
sugar prices that the sugar program must support are the levels that would cause sugar beet
and sugarcane processors to forfeit their sugar that was put up as collateral under the USDA
sugar nonrecourse loan program. Sugar nonrecourse loans support raw cane sugar prices at
21 cents per pound and refined beet sugar prices at 24 cents per pound. The nonrecourse
loans support price because forfeiting the sugar collateral completely extinguishes the
borrower’s debt, thus sugar beet and sugarcane processors are assured of getting at least the
USDA loan proceeds for their sugar. Loan collateral forfeiture also removes surplus sugar out
of the market because the government is limited by the Farm Bill in its sugar disposal options
(USDA FSA, 2010).
At the other end of the range, the objective of maintaining "adequate supply” (as described in
the Farm Bill) or “adequate supply at reasonable prices" (described in HTS) requires USDA to
increase supply under tight markets, which will make domestic prices lower than they would
otherwise be. However, there is no maximum sugar price strategy stipulated in federal law, as
there is a minimum sugar price. Under the Flexible Sugar Marketing Allotments Program, the
sugar beet processors are guaranteed a market share of 46 percent of the domestic market. If
the sector cannot fulfill its quota, USDA is required to increase imports to maintain adequate
supply (USDA FSA, 2010).
3.16.3 Economic Impacts
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Alternative 2 is not expected to result in adverse economic impacts. Growers and seed
producers would continue to use and sell event H7-1 seed and crops and seek return on their
investments. This section discusses the economic impacts of Alternative 1 .
Economic implications of a halt in event H7-1 sugar beet cultivation
Should the unrestricted use of event H7-1 sugar beets be impacted, effectively removing the
product from the market, an estimated 4.25 million tons of beet sugar would be removed from
the market (USDA FSA, 2010). This sugar is expected to supply about 40 percent of U.S. sugar
consumption during 20 1 1 .
Because the federal government has a major effect on sugar supply, and hence sugar price, the
market reaction to a reduction in refined beet sugar is somewhat determined by USDA's supply
management response. USDA has recently reacted to two similar, but smaller, events in 2005
and 2008 (temporary loss of cane refineries) that demonstrate the potential effect from a
reduction in sugar. In both cases, U.S. refined sugar prices averaged about 18 cents per pound
above the world refined sugar price, even as USDA increased the world refined quota to
moderate U.S. sugar prices (USDA FSA, 2010). However, an action that effectively precludes
further planting, cultivation, processing, or other use of event H7-1 sugar beets would cause
greater disruption and greater harm to the U.S. sugar market than caused by the 2005 or 2008
disruptions because the reduction, 4.25 million tons, is 20 times larger than the loss of supply in
2005 and 1 0 times larger than the loss in 2008 (USDA FSA, 201 0). Prices increased
substantially in those years, but were never high enough to cause sugar to be imported off the
world market at the high tariff rate of 1 6.3 cents per pound. Under the scenario where event
H7-1 sugar beet is effectively precluded, world sugar could enter under a high tariff and set the
refined price in the U.S. market (USDA, 2010).
Additionally, USDA learned from the temporary loss of cane refineries in 2005 and 2008 that
many U.S, food manufacturers have difficulty using imported refined sugar because of
differences in product quality or packaging. After the 2005 and 2008 events, a new business
developed to clean, repackage, or liquefy imported refined sugar for domestic use. This was
required because domestic food companies would not use the crystallized imported sugar in its
original packaging (USDA FSA, 2010).
U.S. sugar cane refiners are expected to run at near full capacity in 201 1 , therefore, they will not
have the capacity to refine imported raw cane sugar to replace the 4.25 million tons of beet
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sugar lost. Normally, USDA would increase the raw sugar TRQ to alleviate domestic sugar
shortages. However, in 201 1 , domestic needs for sugar would have to be filled by increasing
refined sugar imports by 6 times from an average of 690,000 tons over the past 3 years (USDA
FSA, 2010). This increase in refined sugar imports may cause an extensive disruption in the
current refined sugar distribution system. For example, the 2.6 million tons would require about
250,000 containers on at least 330 ships by the end of September 2010 (USDA FSA, 2010).
If sugar beet root crop growers cannot harvest, they will experience an economic hardship
because they will have incurred all the costs of producing the 2010 root crop except for
harvesting. Further, they would incur the cost to destroy the crop to prepare the land for the
next crop, and to prevent the sugar beet root crop from overwintering and reaching the flowering
stage in 201 1 . Sugar beet processors are currently contracting FY 201 1 beet sugar at 38 cents
per pound (USDA FSA, 2010). Therefore, sugar beet growers and cooperative owners would
also experience lost revenue estimated at $3.23 billion (4.25 million tons X 0.38 $/lb X 2000
Ibs/ton) (USDA FSA, 2010).
Sugar beet processing factories, and the local economies organized around them, would
experience economic hardship if beef processing factories were prevented from purchasing,
processing, or selling sugar from event H7-1 sugar beets. The sugar beet processing factories
would be idled, thousands of jobs would be lost and the livelihoods of many rural communities
would be at stake (USDA FSA, 2010)Dr. Richard Sexton, an agricultural economist and an
authority on agricultural cooperatives, recently conducted an investigation as to what the
economic impact would be on growers and processors if the growing of GT sugarbeets was
enjoined in 201 1 and 2012. His results are particularly insightful because they rely, in part, on
direct interviews and written surveys with each of the eight sugarbeet processing companies. Dr
Sexton estimated that the consequences on a ban of GT sugarbeets in 201 1 are: 1) 8 of 21
sugarbeet processing plants would close (and unlikely to reopen): 2) grower crop income would
be reduced by approximately $253 million; 3) sugarbeet processor worker salaries would be
reduced by about $138 million dollars; and 4) the adverse economic impact on the local
economies where sugarbeets are grown and processed would be approximately $1.1 billion. If a
ban continued through 2012, Dr. Sexton estimated that processor full-time and seasonal
employment would be lowered by approximately 1 ,570 workers, grower income would be
reduced further by another $282 million and the adverse economic impact would be $964 million
in lower net revenue to growers and their communities (Sexton 2010). Also, a. A 2004 study by
the University of Idaho found that if sugar beet production and processing ceased in Idaho and
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alternative crops were planted instead, Idaho would lose over 3,000 jobs and farm incomes
would decline (given returns to corn, wheat, and other production options based on 2004
projections). Sugar beet growers generally produce other crops, and their land would not
remain idle; they have the equipment and expertise to produce other crops. The longer-term
concern, however, is in terms of the impact on infrastructure, as some companies may not
survive closing down for one season (USDA FSA, 2010).
Additionally, individual sugar cooperative shareholders are significantly penalized for not
fulfilling their contract. For example, one cooperative member stated that, "I currently own 485
shares that are valued at $350 each and I am required to produce 485 acres of sugar beets
annually to Western for processing, By contract, I am subject to an economic penalty of $350
per share if my annual share of sugar beets is not delivered to Western for processing. Western
has enforced this penalty against growers in the past” (Hofer, 2010).
Sugar Beet Seed Production and A vailabUity
Only sugar beets grown from approved varieties can be utilized by growers for sugar beet
production. The processor seed committee will establish a list of approved varieties from which
growers may select. Once a variety has been approved for commercial production by the
processor seed committee, the seed producer produces the seed in the quantities projected to
be sold to the processor's growers. Seed suppliers must predict years in advance the likely
demand for new varieties. If a seed supplier over predicts likely demand, the excess seed may
be inventoried for a period that does not exceed the viability of the seed (Manning, 2010).
The approved varieties have undergone extensive multi-year planting trials to determine how
well each variety tolerates exposure to particular diseases and pests known to infest the
growing region, particular growing conditions such as exposure to particular weather conditions,
and the variety’s ability to deliver acceptable yields per ton and sugar content (Manning, 201 0).
The approved variety list denotes sugar beet varieties that may be delivered to the processor for
sugar production. As a cooperative member, a grower has a contract to deliver sugar beef from
a specified number of acres. Sugar beet varieties that do not make the approved variety lists
cannot be delivered to the processor for sugar production because they do not meet the
standards set forth by the processor. A grower is not permitted by the processor to plant a
sugar beet variety not on the approved list (Manning, 2010).
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When event H7-1 sugar beet was deregulated in 2005, the industry began production of event
H7-1 sugar beet seed. The majority of conventional seed varieties and seed available for the
201 1 crop year originated prior to 2007, Consequently, some approved varieties, including the
genetic traits of those seed, and the inventory of some conventional seed now available were
based on production decisions made many years ago (Manning, 2010). Certain seed producers
have not engaged in new varietal development for conventional sugar beet since 2006/2007.
Some processors have no conventional seed on their current approved variety list, while others
still list some conventional seed varieties (Manning, 2010), Manning looked at the availability of
sugar beet seed should event H7-1 sugar beet seed be unavailable. Based on Manning’s
analysis, all sugar beet growing regions in the U.S. would experience a shortfall of sugar beet
seed to plant (Manning, 2010). The USDA FSA (2010) also stated that domestically-produced
conventional sugar beet seed is in short supply because domestic seed companies have
reduced production of conventional beet seed in recent years.
Sugar beet seed produced outside the United States may not be suitable for commercial
production in the U.S. Certain sugar beet seed varieties produced in the European Union (EU)
or elsewhere have not undergone extensive multi-year variety trials in the U.S to determine if
that variety meets the standards for disease resistance required by growers and beet
processors.
The limited availability of conventional seed could severely restrict plantings of sugar beets in
2011 and sugar production in 2012 (USDA FSA, 2010). Based on information provided by
sugar beet seed producers and buyers, UDSA FSA (2010) estimates that prohibiting the harvest
of event H7-1 sugar beet seed in 2010, would reduce projected sugar beet root crop acreage by
37 percent in 2011. Based on that estimate, the reduction in acres planted for sugar beet
production would lower beet sugar production by an estimated 1.6 million tons in 2012 (lost
acreage with unchanged yields and unchanged sugar recovery)(USDA FSA, 2010). The
economic impact of a reduction in beet sugar supply on consumer costs and grower incomes in
2012 would be severe (USDA FSA, 2010). However, the severity would be mitigated depending
on the degree to which sugar users and consumers reduce their consumption of sugar or switch
to non-sugar sweeteners. Manufacturers and consumers will have time to reduce their beet
sugar use and manufacturing costs if a decision to prohibit event H7-1 sugar beets is
announced at least a year before it affects domestic supply, USDA FSA (2010) estimates that
U.S. demand for sugar could fall 1 percent due to the higher sugar costs in 2012.
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if event H7-1 sugar beet seed could not be planted in the spring of 201 1 to grow the root crop,
the 2012 U.S, refined sugar price is expected to rise from 33 cents per pound to 41 cents per
pound, which includes transportation, product modification costs necessary to be suitable for
American users, and the premium the U.S. Sugar Program provides domestic growers. Sugar
users and consumers would pay a total of $1.6 billion additional for sugar in 2012 even if they
consume less due to the higher sugar prices. Growers and processors are projected to
experience a loss of 700 million in lost 2012 sugar beet and sugar sales (USDA FSA, 2010).
A summary of the projected costs from an action that effectively precludes the planting,
cultivation, and processing of event H7-1 sugar beets on sugar users and consumers and sugar
beet growers and processors over the next two years is shown in Table 3-3.
Herbicide Shortages
The availability of herbicides is another factor that will iikeiy affect a growers' decision to plant
conventional sugar beet varieties. The advent of event H7-1 sugar beets caused a decline in
the use of certain herbicides that were used with conventional sugar beet crops. The
manufacturers of these herbicides have reduced production. Should growers plant conventional
seed, the herbicides may not be available unless the manufacturers ramp up production to meet
anticipated demands. This decision must be made far in advance of when the herbicides would
be needed (Manning, 2010).
Table 3-3. Production Loss and Project Costs from an event i-17-1 Sugar Beet Injunction
parent
Seed
Planted :
Commercial
i $eed
Produced
Harvest/
Safes
Year
Expected
Sugar
Production
: Sugar
Production
Lost
; Cost to
Users/
Consumers
(1,000 tons)
fall 2008
fail 2009
spring 2010
wEsm
4,477
3.232
2.972 ,
fail 2009
fall 2010
spring 2011
wBm
4,396
mmsm
658
1,592
Source; USDA FSA, 2010
3.17 SOCIAL AND ECONOMIC IMPACTS ON RED BEET AND CHARD GROWERS
Seed Production
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In contrast to the very significant social and economic impacts identified in section 3.16 if H7-1
sugarbeet cultivation were hated, the effect of continued cultivation subject to the proposed
interim measures would be minimal. As indicated in Section 2.8, most red beet and chard seed
crops are grown in areas outside the Willamette Valley in Oregon where the large majority of
sugarbeet seed crops are grown. The geographic limitations in the interim measures would
preclude H7-1 seed cultivation in those areas and remove any chance of gene transfer between
the crops. In the Willamette Valley, there is limited production of red beet and chard seed. See
Section 2.8. The majority of such seed producers in those areas have agreed to and comply
with the existing Willamette Valley Specialty Seed Association isolation distances for those
areas, and have not reported issues or losses due to genetic transfer. There appears to be only
very limited organic red beet and chard seed production in the Willamette Valley, and no
indication of genetic transmission in the years since H7-1 seed cultivation began on a large
scale in 2006, Although one identified organic grower has chosen to grow chard (among other
organic crops) in the Western margins of the Valley, that grower has tested his crops on
repeated occasions with PCR tests over multiple years and found no indication of gene flow
from H7-1 crops.
In addition, in the years since 2006, seed companies producing H7-1 seed in the Willamette
Valley have increasingly employed a “gene on the female" nonpoilinator approach for H7-1
production fields, meaning that those fields shed virtually zero pollen that could transmit H7-1
genetic material. As a consequence, as discussed in Section 1 .5, even an organic grower who
chose to market and sell chard seed with a “zero tolerance” for H7-1 genetic material would face
no risk from such fields.
The organic community's consensus Non-GMO Project Working Standard does not require zero
tolerance - it contemplates a tolerance for GE traits in verified Non-GMO seed or 0.25%. The
National Organic Program is a process-based standard; no organic grower has ever lost organic
certification due to an unintended trace presence of a GE trait. Further, if an organic grower
sensitive to H7-1 genetic material wished to ensure “zero tolerance," relatively inexpensive
testing is available to do so, and common seed production methodologies can be employed to
maintain a “zero tolerance” for organic seed if desired. This is discussed in Sections 1.5 and
1.6. There is also no realistic prospect of mechanical mixing between red beet and chard seed
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and H7-1 seed because the two production processes are entirely separate. As discussed in
Section 2.7, seed is processed in different facilities, and no common equipment is used.
Under APHIS'S proposed interim measures, each seed company producing H7-1 would be
subject to third party audits of compliance with the standards to ensure that the measures
remained in place and were effective. Accordingly, Alternative 2 would have no or negligible
social or economic impacts on red beet and chard crops, Alternative 1 , by contrast, would have
highly significant negative impacts on nationwide sugarbeet production, as discussed above.
Root Crop Production
As indicated above, including in Sections 2.8 there is little or no overlap of H7-1 root crop
production and red beet and chard seed production. To the extent certain red beet or chard
seed savers may exist in root crop production areas (none have been identified), the measures
for roguing bolters and related stewardship render the potential for genetic transmission from
H7-1 negligible. As indicated. Alternative 2 would have no or negligible social or economic
impacts on red beet and chard crops. By contrast, Alternative 1 would have highly significant
impacts across multiple growing areas.
Consumer Acceptance of the Sugar from Event H7-1 Sugar beets
Since wide-scale production of event H7-1 sugar began, there has been no indication of
significant concern regarding acceptance of H7-1 sugar producers of food products with sugar
derived from these products or from consumers. The sugar is identical chemically to sugar from
conventional sugarbeets (Baker, 2010a, pp. 2-3; Hoffman, 2010a, p. 10). In addition as
indicated in Section 3. 1 1 .2, food and feed issues have been reviewed by FDA. This FDA review
has not been challenged
For any consumers who are nevertheless concerned about the source of this sugar, there are
alternatives available. Cane sugar and other sweeteners are readily available for instance.
And certain public interest groups, including the Institute for Responsible Technology, have
publicized the readily available alternatives to sugarbeet sugar and other sweeteners derived
from biotechnology (Burkam, 2010, p, 58).
Event H7-1
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CUMULATIVE IMPACTS
This section discusses the cumulative impacts that may be associated with Alternative 2, when
combined with other recent past, present, and reasonably foreseeable future actions within the
affected environment. Alternative 2 is expected to be maintained for a short time duration, and
an EIS will specifically address the environmental impacts associated with full deregulationin ,
Cumulative impacts that will occur before the EIS is completed are expected to be negligible.
By contrast, as indicated in Section 3.16, the specific and cumulative impacts of Alternative 1
are expected to be significant for growers nationwide.
Cumulative impacts occur when the effects of an action are added to the effects of other actions
occurring in a specific geographic area and timeframe. The cumulative impact analysis follows
CEQ’s guidance: Considering Cumulative Effects Under the National Environmental Policy Act
(CEQ, 1997). The steps associated with the analysis include:
• Specify the class of actions for which effects are to be analyzed.
• Designate the appropriate time and space domain in which the relevant actions
occur.
• Identify and characterize the set of receptors to be assessed.
• Determine the magnitude of effects on the receptors and whether those effects are
accumulating.
4.1 CLASS OF ACTIONS TO BE ANALYZED
This analysis addresses large, regional and national-scale trends and issues that have impacts
that may accumulate with those of the proposed interim measures.
4.2 GEOGRAPHIC AND TEMPORAL BOUNDARIES FOR THE ANALYSIS
As described in Section 2, over the past 10 years, the number of acres planted annually in
sugar beets in the US has ranged from 1.1 to 1.4 million (USDA ERS, 2009, Table 14), Event
H7-1 sugar beets are produced in five major regions in the US, and commercial production of
seeds takes place in the Willamette Valley of Oregon. Therefore, the spatial domain for past,
present, and reasonably foreseeable future actions considers the five growing regions for issues
associated with growing event H7-1 sugar beefs; the Wilametfe Valley for issues associated
with seed production; and the nation, and in some cases international areas, for issues
associated with consumption of sugar beet food and feed products. Also, as indicated, the
measures at issue would apply for a limited time period, estimated at less than 2 years.
RESOURCES ANALYZED
Issues evaluated in this cumulative impacts analysis include some of the resource areas
discussed in Chapters 2 and 3 including land use, air quality and climate, water quality,
Event H7-1
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biological, and human health and safety. In addition, specific topics analyzed include;
cumulative impacts related to any possibility of development of glyphosate resistant weeds, and
cumulative impacts of potential increased glyphosate usage with the cultivation of glyphosate
tolerant crops.
4.3 PARTIAL.CUMULATIVE IMPACTS RELATED TO THE DEVELOPMENT OF
GLYPHOSATE RESISTANT WEEDS
Glyphosate offers many benefits to the grower as a weed control product. Glyphosate controls
a broad spectrum of grass and broadleaf weed species present in sugar beet production fields,
has flexible use timings, and when used in glyphosate-tolerant crops, has a very high level of
crop safety (see petition 03-323-01 p. Tables VII-4 and VII-4, pages 90 and 92, respectively). As
the adoption of glyphosate-tolerant crops has grown, the use of glyphosate has increased over
the past several years. With the increased use of glyphosate, there is also the potential for
increased selection pressure for the development of glyphosate-resistant weeds (Section VIII),
Because a glyphosate-based herbicide program is currently being used with event H7-1 sugar
beet, glyphosate use for event H7-1 is not expected to increase beyond current levels, as
market penetration is already at 95 percent. Current levels of glyphosate use in event H7-1
sugar bests are a minor (approximately 0.7 percent) amount of total US glyphosate use.
Additionally, with Alternative 2, growers still would have the currently available weed control
tools (e.g., non-glyposate herbicides and cultural practices described in Section VII.B of petition
03-323-01 p on page 88) needed on a small scale to manage any glyphosate-resistant weeds,
whether they are present in sugar beet or other crop production fields.
4.4 CUMULATIVE IMPACTS OF POTENTIAL INCREASED GLYPHOSATE
USAGE WITH THE CULTIVATION OF GLYPHOSATE TOLERANT CROPS
Studies of the relationship between genetically engineered crops and herbicide use has shown
that an increase in glyphosate tolerant crops can result in a decrease in mechanical tillage
(Brimner et al., 2005; Fernandez-Cornejo, 2006; Gianessi and Reigner, 2006; Kleter et. al.,
2007; Sankula, 2006; Johnson et al., 2008). The potential cumulative impact from this reduction
in mechanical tillage is discussed in the following sections.
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According to the USDA ERS (2009), US farmers have adopted genetically engineered crops
widely since their introduction in 1 996. Soybeans and cotton genetically engineered with
herbicide-tolerant traits have been the most widely and rapidly adopted GE crops in the US,
followed by insect-resistant cotton and com. Figure 4-1 shows the percentage of acres of
genetically engineered crops in the US between 1996 and 2009.
Figure 4-1 Growth in Adoption of Genetically Engineered Crops in US
Source; Graph from USDA ERS, 2009
Herbicide-tolerant crops, which are engineered to survive application of specific herbicides that
previously would have damaged the crop , provide farmers with a broader variety of options for
effective weed control. Based on USDA survey data, herbicide tolerant soybeans went from 17
percent of US soybean acreage in 1997, to 68 percent in 2001 and 91 percent in 2009.
Plantings of herbicide tolerant cotton expanded from approximately 10 percent of US acreage in
1997 to 56 percent in 2001 and 71 percent in 2009. The adoption of herbicide tolerant corn,
was slower in previous years, but has reached 68 percent of US corn acreage in 2009 (USDA
ERS, 2009).
Corn growers use the largest volume of herbicides. Approximately 96 percent of the 62.2
million acres used for growing corn in the 10 major corn-producing States were treated with
Event H7-1
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more than 164 million pounds of herbicides in 1997 (USDA ERS, 2009). Soybean production in
the US also uses a large amount of herbicides. Approximately 97 percent of the 66.2 million
soybean acres in the 19 major soybean producing States were treated with more than 78 million
pounds of herbicides in 1 997 (USDA ERS, 2009). Cotton production relies heavily on
herbicides to control weeds, often requiring applications of two or more herbicides at planting
and postemergence herbicides later in the season (Culpepper and York, 1998), Close to 28
million pounds of herbicides were applied to 97 percent of the 1 3 million acres devoted to
upland cotton production in the 12 major cotton-producing States in 1997 (USDA ERS, 2009).
Pesticide use on corn and soybeans has declined since the introduction of GE corn and
soybeans in 1996. Several studies have analyzed the agronomic, environmental, and economic
effects of adopting GE crops, including actual pesticide use changes associated with growing
GE crops (McBride and Brooks, 2000; Fernandez-Cornejo, Klotz-Ingram, and Jans, 1999, 2002;
Giannessi and Carpenter, 1999; Culpepper and York, 1998; Marra et al., 1998; Faick-Zepeda
and Traxler, 1998; Fernandez-Cornejo and Klotz-Ingram, 1998; Gibson et al., 1997; ReJesus et
al., 1997; Stark, 1997). Many of these studies have concluded that herbicide use is reduced
with herbicide-tolerant varieties (USDA ERS, 2009).
Studies conducted by the USDA also show an overall reduction in pesticide use related to the
increased adoption of GE crops. Based on the adoption of GE crops between 1997 and 1998
(except for herbicide-tolerant corn, which is modeled for 1996-97), the decline in pesticide use
was estimated to be 19.1 million acre-treatments, 6.2 percent of total treatments (USDA ERS,
2009). Most of the decline in pesticide acre treatments was from less herbicide used on
soybeans, accounting for more than 80 percent of the reduction (16 million acre-treatments)
(USDA ERS. 2009).
The adoption of herbicide-tolerant crops such as event H7-1 sugar beets, glyphosate-tolerant
soybeans, and glyphosate-tolerant corn results in the substitution of glyphosate for previously
used herbicides. The glyphosate tolerant crops allow farmers to limit and simplify herbicide
treatments based around use of glyphosate, while a conventional weed control program can
involve multiple applications of several herbicides. In addition, and more importantly, herbicide-
tolerant crops often allow farmers to use more benign herbicides (USDA ERS, 2009).
There are known benefits associated with the use of glyphosate herbicides compared to
herbicides currently used by sugar beet producers. Glyphosate has documented favorable
characteristics with regard to risk to human health, non-target species, and the environment
Event H7-1
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(Malik et al., 1989; Geisy et al., 2000; Williams et al., 2000). Glyphosate is classified by the
EPA as a Group E pesticide (evidence of non-cardnogenicity for humans) (57 FR 8739), In
1 998, the EPA granted Reduced Risk status for an expedited review of the submitted residue
data package supporting the use of glyphosate, as Roundup Ultra herbicide (EPA Registration
No. 524-475) for use in glyphosate tolerant sugar beets. Reduced Risk status was granted by
EPA based on a detailed hazard comparison of glyphosate to alternative herbicides available for
weed control in sugar beet production (Reduced Risk petition document: MRID 44560501), and
an overall conclusion that weed control with Roundup Ultra herbicide offers a substantial benefit
to sugar beet growers in the form of reduced risk to human health, non-target species, and the
environment.
4.4.1 Land Use, Air Quality and Climate
As discussed in Section 3, sugar beet acreage has fluctuated little for the past 50 years, was not
impacted by the introduction of event H7-1, and is not expected to be impacted by continued
use of event H7-1. Therefore, as discussed in Section 3, Alternative 2 is not expected to impact
land use. As it is not expected to directly or indirectly impact land use, Alternative 2 would not
have cumulative impacts on land use.
As discussed in Section 3, Alternative 2 is expected to continue to have small positive impacts
on air quality and climate, primarily resulting from reduced tillage. Consequently, Alternative 2
is not expected to have any adverse cumulative impacts on air quality or climate.
4.4.2 Water Quality
As discussed in Section 3, the advent of glyphosate tolerant crops and the use of post-emergent
herbicides that could be applied over a crop during the growing season have facilitated the use
of conservation tillage farming practices, since weeds could be controlled after crop growth
without tilling the soil (USDA ERS, 2009). The use of glyphosate tolerant crops (particularly
soybeans) has intensified that trend since it often allows a more effective and less costly weed
control regime than using other post-emergent herbicides (USDA ERS, 2009; Carpenter and
Gianessi, 1999).
The impact of conservation tillage (including no-fill, ridge-tilt, and mulch-till) in controlling soil
erosion and soil degradation is well documented (Edwards, 1995; Sandretto, 1997). By leaving
substantial amounts of plant matter over the soil surface, conservation tillage 1) reduces soil
erosion by wind; 2) reduces soil erosion by water; 3) increases water infiltration and moisture
Event H7-1
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retention; 4) reduces surface sediment and water runoff; and 5) reduces chemical runoff (USDA
ERS, 2009).
Glyphosate maypotentially be found in surface water runoff when erosion conditions lead to the
loss of surface particles. However, as discussed in Section 3, partial deregulation of glyphosate
tolerant crops typically leads to an Increase in conservation tillage and no tillage systems, which
would result in less mechanical disturbance of the soil during sugar beef cultivation and thereby
decrease the loss of surface soil. Because of this, and the fact that glyphosate binds strongly to
soil particles, no-tillage and conservation tillage are expected to further reduce the likelihood of
any impact surface wafer runoff (Wiebe and Gollehon, 2006), Therefore, no cumulative adverse
impacts to surface water or groundwater are anticipated,
4.4.3 Biological
For non-target terrestrial species, available ecological assessments in ERA RED (ERA, 2003)
documents or registration review summary documents provide the support that the use of
glyphosate represents reductions in chronic risk to birds compared to trifluralin and sethoxydim,
in acute risk to small mammals in comparison to EPTC, in chronic risk to mammals from
quizalofop-p-ethyl, in acute risk to endangered birds and mammals from pyrazon, and in chronic
risk to mammals and potentially birds from cycloate. For all other sugar beet herbicide
products, as well as glyphosate, no significant risks to birds or other non-target terrestrial
species were indicated in the available information.
For non-target aquatic species, Tables 4-1 , 4-2, and 4-3 provide summaries of the estimated
exposure and hazard information for the traditional herbicides used in conventional sugar beet
production, and present quantitative comparisons of the derived Risk Quotients. Exposure,
defined as the EEC, was calculated for all products using the standard assumptions (assuming
aerial application) of 5 percent drift of spray applied to a one-acre field onto water and 5 percent
runoff from 10 treated acres into a one-acre pond six feet in depth. Herbicide treatments were
based on the maximum single application rate taken from product labels. Hazard information
(LC50 or EC50) for each active ingredient was taken from the ERA Ecotoxicology One-Liner
Database (if available) or other ERA source documents and summarized in Tables 4-1 , 4-2 ,
and 4-3 as the upper and lower values from the range of values reported. Hazard information
for the end-use formulated products is generally not readily available, thus this analysis is a
comparison based solely on the active ingredients. Any label warnings and other available
hazard and/or risk descriptions for non-target aquatic species are also included. The Risk
Event H7-1
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Quotient is determined for each active ingredient by dividing the EEC by the hazard (LC50 or
EC50) value.
Plants potentially at risk from the use of glyphosate are potentially at risk from the use of any
herbicide. Like most herbicides, plants are highly sensitive to glyphosate. Monsanto has
developed a program named Pre-Serve to address aerial spraying in areas where threatened
plants may be located. Following label use instructions and use limitations described in Pre-
serve swould address any such risk of exposure. Federal law requires pesticides to be used in
accordance with the label.. Because glyphosate binds strongly to soil particles, conservation
tillage and no tillage practices provide additional assurance that the impact to aquatic plants
through decreasing soil-laden runoff are negligible.
The labels for products containing desmedipham, phenmedipham, sethoxydim, clethodim and
trifluralin include warnings of toxicity or adverse effects to fish, and/or aquatic invertebrates
and/or aquatic plants. Risk Quotients that exceed the Trigger Value of 0.5 for aquatic animals
and 1 .0 for aquatic plants are highlighted in bold text in Tables 4-1 , 4-2, and 4-3 as exceeding a
Level of Concern, based on EPA Ecological Effects Rejection Analysis and Deterministic Risk
Characterization Approach. Current sugar beet herbicide products containing triflusulfuron,
trifluralin, and pyrazon are shown to exceed these Levels of ConcernAs supported by the EPA
designation of reduced risk for application of glyphosate to H7-1 sugar beet,, glyphosate is a
more environmentally preferred herbicide compared to other herbicides currently used in sugar
beet production since glyphosate is generally less toxic and has favorable degradation
properties,
4.4.4 Human Health and Safety
A tolerance increase was required to support approval for the use of glyphosate in the event H7-
1 sugar beet-cropping system compared to the limited pre-emergent use of glyphosate in
conventional sugar beet production. However, the potential health effects of pesticide residues
that may be present in food, regardless of whether they result from uses in conventional or
glyphosate tolerant crops, are carefully considered by EPA before establishing maximum
residue limits or tolerances.
Before establishing a tolerance in an agricultural commodity, EPA must find that the potential
resulting residues covered by the proposed tolerance will be “safe”. Section 408Cb)(2)(A)(ii) of
the FFDCA [21 USC 346a(b)(2)(A)(i)] defines "safe" as a reasonable certainty that no harm will
result from aggregate exposure to the pesticide chemical residue. As part of this determination,
Event H7-1
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the total maximum theoretical level of residue present in all food commodities with approved
uses for the pesticide must not exceed the EPA established Reference Dose (RfD), or chronic
Population Adjusted Dose (cPAD). Following a comprehensive review of the results of
toxicological studies conducted on the pesticide, the RfD is set by applying appropriate
uncertainty factors to the most appropriate No-Observed-Adverse-Effect-Level (NOAEL).
In 1999, EPA conducted a dietary exposure risk assessment and concluded that the
incremental dietary exposure associated with the use of glyphosate on glyphosate tolerant
sugar beet did not pose a concern to human health (64 FR 18360, 1999), . .
Event H7-1
Draft ER
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n of Potentlai Effects of Glyphosate and Sugar Beet Herbicides on Freshwater Fish
L365
Draft ER 156
1366
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ison of Potential Effects of Glyphosate and Sugar Beet Herbicides on Aquatic Plants
Draft ER 158
1368
In a recent risk assessment supporting establishment of certain new food crop tolerances for
glyphosate, EPA estimated that chronic (daily dietary) exposure to glyphosate from all food and
water sources would use only 2 percent of the glyphosate RfD (1 .75 mg/kg/day) for the general
US population and 7 percent of the RfD for the highest potentially exposed subgroup population
(71 FR 76180,2006).
The cumulative impacts from use of glyphosate on sugar beets was considered. ,
Biomonitoring of pesticide applicators conducted by independent investigators has shown that
bodily adsorption of glyphosate as the result of routine, labeled applications of registered
glyphosate-based agricultural herbicides to crops, including to glyphosate tolerant sugar beet,
was thousands of times less than the allowable daily intake level established for glyphosate
(Acquavella et al., 2004). Given similarity to current use pattern, herbicide label rates, and the
percentage of cultivate acres for sugar beets, the continued use of event H7-1 sugar beet
through partial deregulation will not significantly increase the exposure risk to pesticide
applicators. Furthermore, EPA, the European Commission, the WHO, and independent
scientists have concluded that glyphosate is not mutagenic or carcinogenic, not a teratogen nor
a reproductive toxicant, and that there is no evidence of neurotoxicity associated with
glyphosate (EPA, 1993; EC, 2002; WHO, 2004, and Williams et al., 2000),
Bystander exposure to glyphosate as a result of pesticide application to event H7-1 sugar beet
would be negligible, since such applications would occur in an agricultural setting in relatively
rural sugar beet fields, not in an urban setting.
Presented below is an brief, comparative analysis of the hazard/risk characteristics of
glyphosate, the active ingredient in Roundup WeatherMAX® herbicide (EPA Registration No.
524-537), to the most commonly used herbicides applied in conventional sugar beet production,
based on total pounds of active ingredient applied (USDA-NASS, 2001 ), A detailed assessment
of the potential chronic human health risks compared to traditional products will not be
presented in this comparison. The assessment is based on information obtained from various
sources, including product-specific labeling, EPA Reregistration Eligibility Documents (RED,
EPA. 1993), EPA RED Fact Sheets, product-specific Federal Register publications, the EPA
Roundup UltraMAX is a registered trademark of Monsanto Technology LLC
Event H7-1
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Ecotoxicology One-Liner database42, the USDA Pesticide Properties databas643, and other
public sources of product-specific toxicological and environmental profile information. The
assessment shows that in the majority of cases, weed control with glyphosate, formulated and
sold as Roundup WeatherMAX herbicide, in the event H7-1 sugar beet system offers the benefit
of less risk from potential exposure for applicators and handlers of concentrated product and a
reduced potential to impact non-target species and water quality.
Table 4-4 provides a comparison of product-specific labeling for herbicides commonly used for
weed control in sugar beet production, including required precautionary statements associated
with acute exposure hazards and environmental risk concerns. Although most alternative
products carry the same signal word as Roundup WeatherMAX herbicide (CAUTION), the
associated precautionary statements of each of the alternative herbicide products are indicative
of toxicity findings that represent a greater acute exposure risk than Roundup WeatherMAX.
Nearly every sugar beet herbicide product evaluated has more restrictive requirements for the
use of Personal Protective Equipment (PPE) than those required for Roundup WeatherMAX
herbicide, indicating a greater need to reduce the risk of acute exposure, and, in some cases,
the risk of longer-term or chronic exposure, for applicators and handlers of these other products.
The comparative analyses provided in this section are summarized in Table 4-5 and show those
areas for which glyphosate (designated with a checkmark using Roundup WeatherMAX
herbicide in the comparison, offers the benefit of potential risk reduction compared to the most
commonly used sugar beet herbicides in sugar beet production. In this cumulative comparison,
glyphosate offers potential benefits over all the traditional sugar beet herbicides in at least one
and up to four risk assessment categories. These comparisons demonstrate the benefits to
applicators, mixers and non-target organisms from the use of glyphosate in the event H7-1
sugar beet system.
4.4.5 Summary of Potential Cumulative Impacts from Increased Use of Glyphosate
When considering the impact that the use of glyphosate in the event H7-1 sugar beet system
could have on the human environment in conjunction with the use of glyphosate in other
glyphosate tolerant crops already being cultivated in the same affected environments, the facts
suggest that this use will have little or noadditive effect Additionally, use of glyphosate.
® EPA Ecotoxicology OneTIner database; htlp;//vvww.ipmcenters.orgtEcotox/index.cfm
USDA Pesticide Properties database: ttp://wvvw.ars.usda.gov/ServicesWocs.htm?docid=14199
Event H7-1
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Alternatively, this has the potential to reduce risks to the affected environment from the use of
other, more harmful, herbicides. This is supported by the assessment of the environmental and
worker safety hazards associated with glyphosate when compared to other available herbicides
used for weed control in sugar beet production. Based on such an assessment, EPA granted
reduced risk status for this use of glyphosate, and expedited the review of supporting residue
data. Therefore, there is no reasonably anticipated adverse cumulative impact on human health
or the environment from the use of glyphosate associated specifically with the deregulation of
event H7-1 sugar beets
For a discussion of coexistence of H7-1 and conventional beta species crops, see Sections 1 .6
and 2.4..
Event H7-1
Draft ER
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Table 4-4 Alternative Herbicides for Weed Control in Sugar Beets - Label Comparison / Exposure Mitigation
1371
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Table 4*4 Alternative Herbicides for Weed Control in Sugar Beets > Label Comparison / Exposure Mitigation
1372
Draft ER 163 7/28/2010
Table 4-4 Alternative Herbicides for Weed Control in Sugar Beets - Label Comparison ! Exposure Mitigation
1373
Draft ER 1S4 7/28/2010
Table 4-4 Alternative Herbicides for Weed Control in Sugar Beets - Label Comparison / Exposure Mitigation
1374
Draft ER
Table 4-4 Alternative Herbicides for Weed Control in Sugar Beets - Label Comparison I Exposure Mitigation
1375
Draft ER 166 7/28/2010
Table 4-5 Potential Reduction in Risk from Use of Glyphosate Compared to Traditional Herbicides Used in US Sugar Beet Production
1376
Draft ER • 167 7/28/2010
1377
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Sprague, Michigan State University. Weed management in wide- and narrow-row glyphosate-
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Baker, 2010. C.J. Baker. Stakes high as beet suit hearing arrives. Powell Tribune, Powell,
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2351/79/2203-0554. Pp. 554-559.
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Event H7-1
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Appendix A
Willamette Valley Specialty Seed Association (WVSSA) specialty seed production
isolation guidelines and Columbia basin vegetable seed field isolation standards
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WVSSA Specialty Seed Production isolation Guidelines
Beta species (Beets and Swiss chard)
Must be pinned at the Beta species maps
Four Separate Groups: Sugar beets, Table beets, Fodder beets, Swiss chard
Between one O.P. and another of the same color and group 1 mile
Between Hybrid of the same color and group 1 mile
Between Hybrid and O.P. of the same color and group 2 mile
Between different colors within a group 3 mile
Between stock-seed and a Hybrid within a group 2 mile
Between stock-seed and O.P. within a group 3 mile
Between Hybrids of different groups 3 mile
Between Hybrid and O.P. of different groups 4 mile
Between GMO's and any other Beta species no closer than 3 mile
(And is excluded from exception to lessen this distance)
Brassica species (Fall types - 9 chromosomes)
Includes: Cabbage, Kale, Kohlrabi, Brussel Sprouts, etc.
Between O.P. of the same color and group 1 mile
Between O.P. of different color 2 mile
Between O.P. cabbage and non-heading cultivars 2 mile
(Savoy, Kale, Brussel Sprouts, Collards and Cauliflower)
Between Hybrids and Hybrids and O.P. of the same color and group 2 mile
Between Hybrids and O.P. of different colors or group Smile
Between Hybrid cabbage and non-heading cultivars 3 mile
Brassica species (Spring types - 6 groups)
1 Turnip types - 10 chromosomes (Japanese type, purple top, strap leaf, Shogoin)
2 Chinese Mustard types - 10 chromosomes (komatsuna, mizuna, mibuna, tatsoi)
3 Chinese Cabbage types - 10 chromosomes (heading, semi-heading, non-heading)
4 Pak Choi types - 10 chromosomes
5 Choi Sum types - 1 0 chromosomes
6 Indian Mustard types - 1 8 chromosomes (Florida broadleaf, southern giant curled,
red mustard, Chinese mustard, leaf mustard)
SPECIAL ATTENTION MUST BE PAID TO THESE CROPS AS THERE IS A VERY WIDE
RANGE OF PHENOTYPES THAT CAN CROSS. IF THERE IS ANY DOUBT. CHECK
WITH THE OTHER COMPANY REP. BEFORE PINNING & PLANTING.
Between any 10 chromosome and any 18 chromosome types Physical separation
Between O.P, of the same group 1 mile
Between O.P. of different groups 1,5 mile
Between Hybrids or Hybrids and O.P. of same group and phenotype 2 mile
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Between Hybrids of different groups or phenotype
Between Hybrids and O.P. of different groups or phenotype
Brassica species Canola
Must be grown under permit from Oregon Department of Agriculture.
GMO type Canola or Rapeseed is not allowed to be grown
between any other specialty seed crops.
Allium cepa (Onion)
Male parent used to pin hybrids
Onion Hybrid
Between Hybrid and O.P. of different color
Between Hybrid and O.P. of same color, different shape
Between Hybrid and O.P. of same color, shape and type
Between Hybrid of same color, shape and type
Onions Open Pollinated
Between Hybrid and O.P. of different color or shape
Between O.P. of different color
Between O.P. of same color, but different shape
Between Hybrid of same color and shape
Between O.P, of same color, type and shape
Allium fistulosum (Bunching Onions)
Between another variety of fistulosum
Allium porrum or Allium ampleoprasum (Leek)
Between another variety of Leek
Allium other species (Chives)
Umbelliferous other species (Parsley, Dill, Parsnips, etc.)
Between same types
Between Hybrid and O.P. of similar types
Between different types
Rhaphanus sativus (Radish)
Between O.P. varieties of same color and or shape
Between Hybrids or Hybrid and O.P. type
Between Hybrid and O.P. of different colors and or shape
Between Red globes or from White tip type
Between Long Red from any other Red type
Between Any Red from any other White type
Spinacit used to pin hybrids
Between O.P. of the same leaf shape type
Between O.P. of different leaf shape type
Between Hybrid and O.P. type
2.5 mile
3 mile
3 mile
3 mile
2 mile
2 mile
1 mile
3 mile
3 mile
2 mile
2 mile
1 mile
1 mile
2 mile
no distance
1 mile
2 mile
3 mile
1 mile
2 mile
3 mile
1 mile
2 mile
3 mile
1 mile
3 mile
3 mile
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CIchorium intvbus (Chicory)
Includes: raddichio, chicory, witloof, fodder root
Between O.P. type or endiva species 1 mile
Between Hybrids or Hybrid and O.P. type 2 mile
Cichorium endiva (Endivel
Includes: endive, escarole, frizze
Between O.P. type or intybus species 1 mile
Cucumis sativus (Cucumber)
Types: Slicer, Pickle, White spine, Black spine, Beta alpha.
Between O.P. of the same type 1 mile
Between O.P. of different type or spine color 2 mile
Between Hybrid and O.P. type 3 mile
Between Hybrid of different type or spine color 3 mile
Cucurbita species (Squash)
Includes: pepo, moshchata, mixta, maxima
Between Similar types, shape and color 1 mile
Between Same or Different species 1 mile
Between another Hybrid of similar variety 1 mile
Between Hybrid and O.P. of similar type and shape 1.5 mile
Between O.P. or Hybrid of different type, shape or color 2 mile
Flowers
All Flowers need to be pinned
Between ones that cross pollinate 1 mile
Includes; Chrysanthemums, Sunflowers, Helianthus, Poppies, etc.
Multiple non-crossing flowers at one location can be pinned with one pin denoting flowers
Consult company representatives on general pinned flower locations
All other seed crops need to be pinned .
For isolation distances consult company representatives
WVSSA
Specialty Seed Production
Pinning Rules
To facilitate communication and protect the specialty seed industry in the Willamette and
Tualatin Valleys of Oregon, isolation mapping procedures have been drafted and agreed upon
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by the Willamette Valley Specialty Seed Associatton (VWSSA). The procedures and isolation
distances as outlined below have been set up to ensure quality seed production of all
vegetable and other specialty seed in the designated areas from potential cross pollination.
The isolation control area of interest referred to as the Willamette and Tualatin Valleys
includes the counties of; Multnomah, Washington, Clackamas, Yamhill, Polk, Marion, Benton,
Linn, and Lane,
Maps
The association has four separate maps for the purpose of pinning and maintaining
appropriate isolation distances. There are two for non-Befa species, and two for Beta
species. The maps are then divided by the North and South valley isolation areas. They are
established at four different locations as follows:
Non-Befa Species Locations
Map1 - North Valley Pinning
OSU Extension Service Marion County Phone: 503-588-5301
At; 3180 Center NE, Salem, Oregon 97301 Room 1361
Map 2 - South Valley Pinning
OSU Extension Service Linn County Phone: 541-967-3871
At: 104 4"' Ave SW, Albany, Oregon 97321 Room 102
Beta Species Locations
Map 3 - North Valley Pinning
West Coast Beet Seed Phone
At: 2380 Claxter Rd NE, Salem, Oregon 97303,
Map 4 - South Valley Pinning
Betaseed, Inc, Phone
At; 34303 Hwy 99 E, Tangent, Oregon 97389
The non-Befa types are to be pinned at the non-Befa locations in respect to their valley area.
The North map is for pinning isolations: Includino and North of Township 9 South .
The South map is for pinning isolations: Including and South of Township 9 South .
Fields located within Township 9 S. must be pinned on both North and South maps.
The Beta types are to be pinned at the Beta locations in respect to their valley area.
The North map is for pinning isolations: Including and North of Township 11 South .
The South map is for pinning isolations: Including and South of Township 12 South .
Pinning Procedures
To identify production fields for location on the map, pins and flags will be used to mark the
isolation. On the non-Befa maps, different color flags are used to separate the major crop
types,
1 , Must have approved pinning rights and abide by the guidelines of the WVSSA,
2, Observe the dates covered under the priority pinning,
3, Check for acceptable isolation distance on the maps,
4, Use proper flag to pin the field.
Written on each flag will be : Party name, Crop type, Hybrid or 0,P., Legal location,
5, Fill out pinning card at time of pinning.
: 503-393-4600
: 541-926-0161
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6. At non-Befa maps, have Extension personal date stamp card and place in lock
box.
7. At Beta maps, pin as set up at each location, date stamp card and place in lock
box.
8. Contact any companies involved if isolation guidelines are in question.
Pins will be placed as close to the center of the field to be planted as possible. This will be done
to facilitate proper isolation distances to other fields. The isolation is not valid if that isolation is
pinned incorrectly.
The map cannot be pinned until an established agreement has been made with the grower for
planting the crop. The map cannot be pinned on a speculative basis in order to reserve
isolation. Upon cancellation of an intended production prior to planting the pin must be removed
within 5 days. Upon abandonment of an established production, the pin must be marked failed.
A penalty may be assessed of $50.00 if in violation and payment is required to remain a
member in good standing.
Pinning Priority
The WVSSA allows the grower to hold the right to the isolation in his perspective farming area
tor the following year, to produce the same crop within a one-mile radius to the prior year’s
isolation. The grower maintains the right to elect the contracting company. The isolation right,
known as a prior year’s priority can only be held for the specific grower until the dates specified
below.
A prior year's priority is only valid until the following dates;
For non-Befa species: Annuals - March Biennials - August
For Beta species: Transplants - February 1'‘ Direct seeded - August 1®'
After these dates, all isolations are available on a first come basis.
Pinning Rights:
The contracting company or responsible seed representative, who is a member of the WVSSA,
may do the pinning. The intent is for the contracting company or responsible seed
representative to do the pinning. The representative appointed by a company may also do the
pinning If the company is a member of the WVSSA. Oregon State University is considered here
as a non-due paying member that has pinning privileges.
The contracting company or responsible seed representative with a grower agreement acts as
the grower's appointed representative in establishing the isolation. Individual growers are to
allow their contracting company or responsible seed representative who is a member of the
WVSSA, to establish the isolation. Growers are allowed to be members of the WVSSA
and would be considered as a responsible seed representative and as a member would be
allowed to pin isolations for their farms under their own agreements. The contracting company
or responsible seed representative agrees to abide by the pinning and isolation guidelines of the
WVSSA.
New pinning parties need to contact an officer of the WVSSA for eligibility approval a
membership is required prior to pinning. The responsible party may be required to have
membership approval by the association. The association may elect to appoint a representative
to meet with the new parties at the appropriate isolation map to clarify pinning practices.
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Membership and Pinning Fees:
The member or responsible party for the seed is subject to fees as established by the VWSSA.
Fees are inclusive of the WVSSA annual membership dues of $150.00 per year, or a
Homestead membership fee of $5.00 per year. The pinning fees are; $10.00 per OP crop,
$25.00 per Hybrid crop, and $25.00 Multi-crop fee. Annual dues for the current year and
pinning fees for the prior year's pinning are assessed at the beginning of each year. If dues and
pinning fees are not received, pinning rights may be revoked.
A multi-crop fee may apply when producing multiple crop species of an OP in one location, and
one acre or less. Only one per member is allowed and is intended for research farms, and
small commercial farms used for seed production. The multi-crop fee is not a pin, crop pins
must be used to pin different species, and multi-crop must be designated on each card turned
in.
A Homestead membership fee and no pinning fees may apply for a Homestead non-voting
member when producing in one location non commercial OP seed crops. Intended for the seed
saver this member is not eligible for the pinning priority and is required to follow WVSSA rules
and to be accompanied by a designated appointee when pinning the map. Crop pins must be
used to pin different species, and Homestead must be designated on each card turned in.
Exceptions Agreements
There are two exception agreements, the Isolation Distance Encroachment, and the One Year
Isolation Deferral. The Encroachment exception applies to an established crop isolation where
one company agrees to allow another company to produce a like crop under less than the set
isolation distance. The deferral applies to an established crop isolation where one grower and
company agrees to allow another grower and company to produce a like crop for one year, and
the established grower retains the isolation priority.
The parties involved prior to planting a specific crop must agree upon any exception to the
established isolation for the specific crop year. The exception agreement needs to be in writing
annually and to include the right to the isolation the following year. There are exception
agreement forms available for this use. All parties must agree and all other VtA/SSA isolation
rules must be followed.
Securing Isolations
At all maps a system of cards and a lock box will be used and parties using the maps must
follow the WVSSA rules. Fields must be currently identified for both the past and present crop
year. Failure to pull pins will result in a penalty under the WVSSA.
At the non-Sefa maps, at the time of opening the lock box, a representative from two different
companies of the VWSSA, in addition to an Extension Agent, are required to be present. The
lock box will be emptied annually when the prior crop year's map is cleared.
At the Beta maps, the procedures for pinning must be followed at each location. The cards will
be date stamped, except not by an Extension Agent, and placed in lock box. The lock box can
only be opened and will be emptied annually by two members of the VWSSA.
The purpose of the lock box is: 1.To use as the archive and formal record of posting of pins. 2.
To review established pinning priority rights. 3. To be used for pinning dispute resolutions. Any
discrepancies over pinning locations will be solved through the cards. The cards will be used
for accuracy of pinning and in case of arbitration. Pinning cards will be archived indefinitely.
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Arbitration
Should all precautions fail in preventing potential cross-pollination problems between seed
companies or responsible seed representative, and or growers, the VWSSA suggests the
following system or arbitration: Fields not pinned will be considered at fault in event of
arbitration. If the parties agree to arbitration by the three-person committee, they agree to abide
by the committee's recommendation. The two contesting seed companies or responsible seed
representative, in consultation with their growers, each chooses an outside field representative
from the VWSSA, The arbitrators, A and B, are suggested to a neutral facilitator who notifies
them of their role. They do not know whom they represent and together choose a third
committeeman. Arbitrators A, B and C agree to hear the facts of each seed company.
Maximum would be two representatives on each side of the issue. After both parties present
the facts, only the arbitration committee. A, B and C, remain in the room to discuss the facts
fully. They agree to a solution before leaving the room and the chairman will deliver the
recommendation immediately to both parties.
Columbia Basin Vegetable Seed Field Isolab'on Dates'’
With a valid "release"^, vegetable seed company representatives may reserve fields for
vegetable seed production as follows:
Annuals and carryover onions^
Onion and other biennials
f exceot carrots)
Carrots and fall planted annuals
February 1 or closest weekday
thereafter
March 1 or closest weekday
thereafter
June 1 or closest weekday
thereafter
’ These dates for crops are as per agreement at the January 21, 2005 meeting of the Columbia
Basin Vegetable Seed Field Representatives Association.
^ A release must include the production company , crop , and crop year for placement in
Columbia Basin production and either the number of fields or number of acres .
^ Carryover onion crops may be repined with priority between February 1 and March 1 , after
which priority is lost.
Columbia Basin Vegetable Seed Field Isolation Standards*
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All genetically modified crops will be designated as GMO.
CARROT FAMILY {Apiaceae)
CARROT fPinned bv Group and Tvoe^
Groups; Hybrid and Open Pollinated
Types; Chantenay (Danvers, Red Cored. Royal, etc.)
American Market (Imperator, etc.)
Early (Amsterdam, Baby Carrot, etc.)
Medium (Nantes, etc.)
Late (Flakkee, Berticum, etc.)
Round and Odd Shapes (Paris Forcing, etc.)
Oriental (Usually short Chantenay shape)
Distance; Between Hybrids 2 miles
Between Hybrids and Open Pollinated 2 miles ♦
Between Types within Groups 1 mile
Between Varieties of same Type 'A mile
Between same Varieties for different companies 'A mile
Off-color carrots should be grown outside main production area and pinned by color with a
minimum isolation distance of 5 miles from other colors.
♦ Note; A 3 mile isolation will be permitted between Hybrid and Open Pollinated carrots where
requested.
PARSLEY Between all Types and Varieties 1 mile
CORIANDER (cilantro or Chinese parsley) Between all Types and Varieties 1 mile
MUSTARD FAMILY (Cruciferae)
RADISH (Pinned bv Group and/or Type... Understood to be O.P. unless otherwise noted)
Groups: Hybrid and Open Pollinated
Types; Round Red
Round Red Forcing
Crimson Giant
Round Red White Tip
Half Long White Tip
Long Red
Icicle (and related forms)
Round White
Purple
Black
Other
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* Standards as of March 1, 2006 as agreed upon by the Columbia Basin Seed Field
Representatives Association. Revised 03/06.
RADISH Cont’d.
Daikon (assumed to be white rooting type unless specified)
Daikon Sprouting
Daikon, Red
Daikon. Green
Distance: Between Hybrid and
Open Pollinated .....2 miles
Between any red Type and any white type 2 miles
Between any round white, icicle Type, purple, black, or any
Daikon Types and any other radish 2 miles
Between Round Red, Crimson Giant, Long Red, round White Tip,
and Half Long White Tip 1 mile
Between Daikon, Sprouting, and any other Daikon of same color 1 mile
Between Round Red and Round Red Forcing 'A mile
Between Round Red Varieties (unless negotiated between companies) %. mile
RAPESEED
Canola and other Oilseed Types 3 miles
Genetically modified Canola and other Oilseed Types will be designated as GMO
OTHER CRUCIFERS fPinned by crop name and chromosome number)
All Groups or Types 2 miles
ONION FAMILY {Alliaceae)
ONION (Pinned bv Group and Tvoei
{Allium cepa)
Groups; Hybrid and Open Pollinated
Hybrid : (Should be posted as male parent)
From Hybrid or O.P. of different color 3 miles
From Hybrid or O.P. of same color, but different shape (i.e. Globe vs. Flat) 2 miles
From O.P. of same color and shape 2 miles
From Hybrid of same color, but different shape 2 miles
From Hybrid of same color, shape, and Type (i.e. Yellow Spanish vs. Yellow Spanish) 1 mile
From Allium ^stulosum, Chives, or Leek None
Open Pollinated :
From Hybrid or O.P. of different color or shape 3 miles
From O.P. of same color, but different shape (i.e. Yellow Globe vs. Yellow Ebenezer) 2 miles
From Hybrid of same color and shape 2 miles
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From O.P. of same color, but different Type (i.e. Yellow Spanish vs. Yellow Globe)
miles
From O.P. of same color, Type, and shape (i.e. Yellow Spanish vs. Yellow Spanish)
From Allium fistulosum, Chives, or Leek None
{Allium fistulosum)
Open Pollinated :
From Allium cepa, Chives, or Leek None
From another variety of Allium fistulosum (i.e. Tokyo Long White vs. He-Shi-Ko) 1 mile
ONION Cont’d.
Hybrid :
From any O.P. or Hybrid A fistulosum 2 miles
(Allium cepa-fistulosum cross) CFG
tetraploid double chromosome
Open Pollinated :
From Allium cepa or Allium fistulosum of the same color None
From Allium cepa or Allium fistulosum of a different color None
From another Variety of CFC of the same color 1 mile
From another Variety of CFC of a different color 3 miles
CHIVES
From Allium cepa, Allium fistulosum, or Leek None
From another Variety of chives 1 mile
LEEK
From Allium cepa, Allium fistulosum, Chives None
From another Variety of Leek 1 mile
GOOSEFOOT FAMILY (Chenopodiaceae)
BEETS
Between all Beets, Swiss Chard, and Mangels 3 miles
Sugar Beet Types:
Diploid
Tetraploid
From Sugar Beets of the same or different Type 2 miles
Genetically modified Sugar Beets will be designated as GMO
1
1 mile
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Appendix B
West Coast Beet Seed Company protocol for genetically modified (GM) seed production
and GM grower guidelines
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PROTOCOL FOR GENETICALLY MODIFIED (GM) SEED PRODUCTION
(Direct-Seeded, Transplants, Nurseries, Plots)
DETECTION
1 . West Coast Beet Seed Company will request the help of Members to set up assay for
QC (detection) of Roundup Ready (RR) gene in sugar beet seed lots.
2. West Coast Beet Seed Company will, from time-to-time, add additional assay of QC
(detection) for other events as ne^ed.
3. West Coast Beet Seed Company will conduct the assay for QC of RR on all RR seed
lots. For the protection of West Coast Beet Seed Company and to learn if the processes
are meeting the desirable criteria, random testing of non-GMO seed lots will be
conducted. West Coast Beet Seed Company may consider using zones, based on
distances from the GM source, for determining this random testing. Members have the
option of requesting all of their lots be tested. Members have the option of requesting
this information in written form.
4. The shipping document will indicate that the shipment contains GM seed.
5. West Coast Beet Seed Company assigns a lot number to the potential seed lot prior to
the item being planted. This number stays with the seed lot and becomes a permanent
record for this lot.
6. West Coast Beet Seed Company will inform members of all past events grown so
members can test their seed lots.
ISOLATION
1. West Coast Beet Seed Company’s goal is to develop an agreement with sugar beet,
chard, and red beet seed companies to avoid cross contamination and to develop a
program to inform each other as to the locations of present and past GM and non-GM
seed productions.
2. Within a three mile radius of any RR field, West Coast Beet Seed Company will monitor
for any volunteers in any fields used for sugar beet production, over a minimum of the
past five years or until no volunteers are observed.
3. West Coast Beet Seed Company will monitor GM fields for a minimum of five years or
until no volunteers are present. This will protect chard, red beet, and sugar beet seed
production in the area. The removal of the volunteers will be done under the supervision
of West Coast Beet Seed Company representatives and recorded in a log book. The
costs will be shared between West Coast Beet Seed Company and the grower.
4. West Coast Beet Seed Company will maintain a minimum three-mile isolation between
GM and non-GM sugar beet production. The isolation between GM
pollinators/producfions where the same event is present will be a minimum of one mile.
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The isolation between sugar beet, chard, and red beet will be a minimum of three miles
until an agreement can be reached with the other companies.
STOCK SEED/STECKLINGS/SEED TAGS
1. West Coast Beet Seed Company has adopted an orange color tagging system to
visually identify GM material (GM stock seed, GM steoklings, GIVI seed in tote boxes,
cotton or burlap bags, GM seed samples, and member's shipping containers). The
orange colored tags identify the product as GM and it is to be treated according to the
protocol. In respect to each Member company’s policies, GM material going to or
coming from West Coast Beet Seed Company will be tagged with the preferred
identification of that member company.
Member Requirements:
1 . Prior to GM stock seed being shipped to West Coast Beet Seed Company, the members
will send a document (Movement Traceability Form) identifying the stock seed items (I.
D. code number, etc.) that will be GM.
2. Each GM stock seed bag arriving from members will already contain an orange tag
marked in writing, stating it is GM seed. The stock seed bags can also contain the
Member company’s GM identifying colored tag, code, symbol, etc,
A. If stock seed arrives and there are any inconsistencies in the paperwork, orange
tagging, non-orange tagging, or any other inconsistency of labeling, the
warehouse personnel will notify the Manager and the seed will be put on hold
until the member clears the issue and backs it up with the proper documents.
The seed will be stored on a separate pallet in the GM portion of the warehouse.
The pallet will be marked clearly in a manner to prevent it from being prepared
for planting.
West Coast Beet Seed Company’s Requirements:
1. The GM stock seed will be stored separately from the conventional stock seed. The
area will be in the main building, along the east wall, near the Warehouse Manager’s
office and will be identified in a clear manner.
A. Non-GM seed will be stored in the northwest warehouse, of the main building, by
the main dock.
2. The GM stock seed will be prepared for grower disbursement in the main building, along
the east wall, near the Warehouse Manager’s office.
A. A sample of the GM stock seed will be held in a separate area of the warehouse
for five years. This sample will be labeled with the orange colored tag and the
preferred identification of the member company.
3. Once the GM stock seed is prepared for the grower, it will be labeled wnth an orange tag
indicating to the grower that they have in their possession GM seed.
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4. Accompanying the GM stock seed will be a written document declaring that the seed is
GM,
5. The stock seed for GM and non-GM productions will not be transported to the growers in
the same vehicle at the same time. The field staff will be trained properly at least once a
year in the handling of GM seed and ail seed movement will be documented,
6. The field supervisors are responsible for collecting the remaining stock seed from the
growers immediately after planting. The Warehouse Manager will log in the stock seed.
When GM stock seed is returned from the growers after planting, sealed bags will be
returned to the member. Opened bags will be incinerated at the County garbage
burning facility to prevent use of potentially grower-contaminated seed.
The Member will be informed, in writing, of the amount, location, and date destroyed.
The Member also will be informed, in writing, as to amount being returned to them.
GM NURSERY
1 . The GM nursery will be kept separate from the conventional nursery.
A. The owner of the nursery ground will have given West Coast Beet Seed
Company written permission to plant GM stock seed.
2. The GM stock seed for the nursery will be handled the same as any other GM stock
seed (information from member, orange tag, stored in separate area, etc.) (see above
"STOCK SEED/STECKLINGS/SEED TAGS").
3. The digging equipment will be completely clean of any stecklings before entering or
leaving the GM nursery. West Coast supervisors will sign a document stating they have
personally inspected the equipment after cleaning and found it to be free from any
stecklings.
4. All GM stecklings will be stored in sacks that are marked with a GM orange tag. The
stecklings will be stored in a cooler or warehouse separate from non-GM stecklings.
5. There will be a separate GM observation nursery and it will be isolated in the area where
GM productions of the same event(s) are being grown.
GROWING THE CROP
(Planters, tillers/flail, sprayers, separators, male removal,
swathers, combines, tote boxes, hauling, tarps/lids)
Any equipment (planter, transplanter, sprayer, flail, tiller, tractor, irrigation equipment, vehicle,
separator, clipper, swather, combine, tote box, post-harvest tilling equipment, seed cleaning
equipment, or any other equipment) must be monitored, treated,., cleaned, and the process
documented, according to West Coast Beet Seed Company’s policies.
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The intent is to prevent seed, pollen, or sfecklings from being transferred out of the area of
control or transferred to where they could contaminate other Beta species productions (details
of the methods are found in other parts of this protocol).
1 . West Coast Beet Seed Company will use only designated totes for GM seed harvest by
growers. Phase one will be metal totes only. Phase two will be metal totes and
designated wood totes.
A. During transportation, the totes will be covered with a West Coast Beet Seed
Company approved high-quality tarp or high-quality lid,
2. Trucks transporting commercial GM seed will not carry non-GM seed on the same load.
3. Growers will not be allowed to transfer bulk seed to totes at third party locations
(i.e. grain elevators) unless, in the opinion of West Coast Beet Seed Company
and upon approval of the member company(ies), the seed can be transferred in a
manner that would allow complete and easy transfer without contamination of
equipment or surrounding area. To avoid spillage, growers must not transfer
seed from one tote to another,
4. Any pesticide application made during the flowering period needs to be done by aerial
applications. If aerial application is not possible, then West Coast Beet Seed Company
will use its operator and modified equipment to spray. If the grower has high clearance
spray equipment that does not leave his farm, then we can consider using this
equipment.
The Member will be notified in advance as to which productions West Coast Beet Seed
Company will use its equipment for spraying after flowering begins.
5. When the GM production is in bloom, any person who enters the field (grower or their
workers if they would be going to any other Beta species production, West Coast Beet
Company staff or temporary workers, Member or their representatives), will wear
disposable coveralls. They are to be removed and disposed of after each use. The
disposable clothing will be stored in a separate, closed container so that live pollen
cannot escape the area or be transferred into another field.
A, Clean, disposable, coveralls will be kept in a closed container prior to use.
These coveralls will be furnished at West Coast Beet Seed Company’s expense.
West Coast Beet Seed Company’s field supervisor is responsible for the
disbursement of the disposable clothes, for having people wear them, for training
people how to dispose of them, and finally to control the good use of them.
SEED CLEANING. STORAGE, SHIPPING CONTAINERS.
AND SCREENINGS DISPOSAL
1. GM seed will be delivered in designated totes. The totes will be affixed with all
appropriate tags, including a GM orange tag which will designate it as containing GM
seed.
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A. These totes will be stored in a designated portion of the warehouse(s) physically
separated from non-GM seed. The seed will also be unloaded in a separate area
and only GM designated and marked equipment (brooms, conveyors, etc.) will be
used for GM seed.
B. The field-run samples also will be affixed with a GM orange tag and these
samples will be stored separately from non-GM samples. This requirement will
be added to the scale house procedures and policies. Scale house personnel
will be trained in these procedures, each year, prior to seed delivery.
2. West Coast Beet Seed Company will, in the beginning years, utilize one or two of the
cleaning lines to process GM seed. The GM seed will be cleaned at the end of the
processing period to avoid potential problems.
A. The Company shall not clean conventional and GM seed simultaneously, except
in an emergency. In the event of an emergency and the Company must clean
conventional and GM seed simultaneously, a physical barrier, such as a plastic
wall, shall be put in place to avoid contamination.
B. All cleaning equipment will be thoroughly cleaned prior to and after cleaning GM
seed. This will ensure that all GM seed has been removed from equipment prior
to any non-GM seed being introduced after that point. (Detailed instructions of
cleaning the equipment are already in place).
C. A permanent log is kept for the cleaning sequence.
3. West Coast Beet Seed Company will draw a representative clean seed sample and tag it
with a GM orange tag.
A. Part of this sample will be tagged with a GM orange tag and sent to Agri Seed
Testing for germination and purity testing. Agri Seed Testing will be informed
that the seed is GM. Agri Seed Testing holds their samples for three (3) years
and then will destroy them by incineration in the County garbage burning facility.
B. Part of the sample will be tested via the QC assay method for the eventfs). (This
will be expanded to include how this information will be disseminated). See
DETECTION category number 3, paragraph 1 above.
C. A minimum of one (1) pound will be stored in a separate area for five years
labeled with an orange tag and the preferred identification of the member
company.
D. Members at their request will be sent their requested amount of properly labeled,
clean seed samples.
4. Screenings from GM production will be delivered to either the pellet mill or composting
facility.
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A, West Coast Beet Seed Company will check yearly with the pellet mill company to
see if the feed pellets will be sold where GM is presently not allowed (Europe)'*'*,
West Coast Beet Seed Company will keep members informed on the result of
this discussion.
B. in the future, regulated screenings can be delivered to a landfill if required.
5. Shipping of GM seed to members will be in new containers (boxes, poly tote bags, etc.).
The containers will be affixed with a GM orange tag and the preferred identification of
the member company. Shipping containers (cardboard boxes and poly bags), because
they are known to hold some seed in crevices, will not be allowed to be reused at this
time. Therefore, West Coast Beet Seed Company would prohibit GM shipping
containers from being returned for reuse.
A. The paperwork that goes with the seed will indicate seed in truck contains GM
seed.
B. For the protection of West Coast Beet Seed Company and its members, GM and
non-GM seed will not be shipped on the same truckload to the Members’
facilities.
GM GROWER GUIDELINES
The policy for the grower guidelines will include the following revised requirements:
1 . The policy will be a part of the Grower Contract.
2. The grower will have only a GM production (of one event) or a non-GM production; not
both in a given year. This applies to growers who grow only for West Coast Beet Seed
Company and to those growers who grow for both West Coast Beet Seed Company and
another sugar beet seed company.
A. The grower will not raise a GM crop and a chard or red beet seed production in
the same year.
3. The grower will use precaution in the field to eliminate seed from remaining loose on the
transport deck prior to leaving the field,
A. Clean off deck of loose seed prior to leaving field. This is part of the protocol that
will be reviewed with the Grower.
B. (West Coast Beet Seed Company will work on designing a method to prevent
seed from falling between boxes. We may also promote bulk hauling to the plant
and transfer to boxes).
4. Grower cannot use/share any equipment that might be used in a non-GM sugar beet,
chard, or red beet seed production in the same growing year.
'*'* Import of food and feed products derived from Roundup Ready sugar beet event H7-1
was approved by the European Union in October, 2007.
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5. Grower cannot use same combine to combine GM sugar beet, non-GWl sugar beet,
chard, or red beet seed in same year.
A. The grower will combine 200 acres of another crop between combining any beta
species.
6. We want a rotation of five crop plantings since the last beta species was grown on the
field for seed,
7. Grower training on all aspects of GM growing handling will be conducted by
management and field staff.
RECORDKEEPING
1. West Coast Beat Seed Company will continue to maintain a permanent GPS
computerized mapping system to record all productions including year, item number,
and lot number.
2. West Coast Beet Seed Company maintains a yearly and ongoing computerized log
where all important activities of the production are recorded (Crop Tracker). The Grower
may collect information, but the final responsibility for this data collection is the field
supervisor.
3, Crop histories of herbicide and crop are collected each year prior to planting.
4, West Coast Beet Seed Company will develop a method for tracking all movement of GM
seed from the time West Coast Beet Seed Company receives the stock seed, to
the final processing and shipment to the member. This information will be
communicated to the members upon request. The members may also request
additional information when necessary for stewardship of the GM crops.
INSPECTION
New disposable clothing will be used by West Coast personnel, grower, custom contractor, and
member company personnel when entering the field when pollen is present. After each use, the
clothing will be discarded into a sealed container and then disposed of in customary container
(garbage can, dump box).
RISK ANALYSIS
The protocol needs to be continually reviewed. During the review and handling of the crop, new
areas of concern may become evident. When this occurs, the concern must be addressed and
solutions implemented. Final approval of any changes to the contracts must be approved by the
Contract Committee and recommended by the committee to the Board of Directors in a timely
fashion.
TRAINING
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1. All West Coast Beet Seed Company employees will be trained in all areas of the
protocol. Date, time, personnel attending, type of training and instructor should be
recorded for all training sessions and appropriately filed.
A. West Coast will train personnel on these policies and procedures. Written
training documents will be reviewed and approved by the board.
2. West Coast Beet Seed Company employees that deal with specific areas will have
extensive and continual training in the specific area.
3. Both West Coast Beet Seed Company growers and personnel will be trained in the
relevant areas of the protocol. Date, time, attendees, type of training and instruction
should be recorded for all training sessions and appropriately filed.
4. Part of the training will include the following West Coast Beet Seed Company policy:
Operators discovering evidence of spillage or GWI seed out of place immediately will
inform their supervisor, the head of department, and the West Coast Beet Seed
Company Manager. At first evidence of the problem, appropriate action will be taken to
halt the release of any additional seed, pollen, or plant material. The problem will be
evaluated immediately to prevent a reoccurrence. Appropriate individuals or companies
will be informed of the situation.
GM Grower Guidelines
The following are guidelines to which all West Coast Beet Seed Company commercial
growers are required to adhere in the contract production of genetically modified (GM)
sugar beet seed. If questions arise with this production, contact West Coast Beet Seed
Company's fieldmen for clarification or explanation.
Direct seeded and transplant productions will adhere to the guidelines, except with
reference to transplanting. West Coast Beet Seed Company will perform the
transplanting in winter/spring.
A. Field Selection: Genetic purity is of the utmost concern with this type of seed
production. Field selection encompasses many characteristics, but the main
features that are necessary include fields with required isolation of at least three
miles from non-GM productions and one mile between GM
pollinators/productions, the least chance of having volunteer beets from previous
productions, good fertility, favorable location (not likely to flood), available for
timely plantings into pre-irrigated conditions, good irrigation systems, and good
water availability. At a minimum, a rotation of five crops since the last beta
species were grown for seed is required.
B. Planting: Stock seed will carry an orange tag to indicate GM. The goal is to
plant into fertilized, pH adjusted as necessary, and pre-irrigated fields to ensure
timely establishment of desired stands. It is desirable to have a population of 4-5
beets per foot of row in all lines for direct-seeded production.
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stock seed normally is limited in supply, so close monitoring of seed drop is
essential to establishing uniform stands across the entire planting. Stock seed
will be stored safely to ensure no seed is lost inadvertently or released into the
environment inadvertently. All unused stock seed will be returned to company
personnel in a timely manner.
Planters must be monitored both before and after planting to ensure that the
proper seed is being planted. After planting, the planter and the tractor need to
be cleaned in the field to remove 100% of the seed prior to moving the planter to
another location. The intent is to prevent seed from being transferred out of the
area of control or transferred to where it could contaminate other beta species
productions.
C. Irrigation: Fall irrigation of direct-seeded production should start after planting,
as necessary, and continue through emergence and stand establishment.
Spring irrigation of direct seeded and transplant production should begin as the
soil moisture drops and crop growth requires supplemental moisture. Spring
irrigation should continue as the crop grows and matures to the point that
additional moisture is no longer beneficial to production of a quality crop.
West Coast Beet Seed Company personnel will determine the timing of the last
irrigation.
Irrigation equipment will be cleaned of any live GM pollen before leaving the field.
If this is not possible, then irrigation equipment should be left by the field for 24
hours before moving to another location.
D. Disposable Clothing Requirements: When the GM production is in bloom, any
person who enters the field, and who may enter another Beta species production
that same day, will wear disposable coveralls. These will be furnished at West
Coast's expense and they are to be removed and disposed of after each use.
This will prevent live pollen from being transferred to another field.
E. Care of the Crop: The crop will be cared for in the best interest of obtaining a
high quality and high-yielding production. Management practices of individual
fields vary and shall be approved by West Coast Beet Seed Company’s field
staff. Recommendations by Company representatives will be carried out in a
timely and efficient manner.
1. Any pesticide application made during the flowering period needs to be
done by aerial applications. If aerial application is not possible, then West
Coast Beet Seed Company will use its operator and modified equipment
to spray. If the grower has high clearance spray equipment that does not
leave his farm, then we can consider using this equipment.
F. Pollinator Removal: Removal of pollinator in a timely manner is very important
to production of high quality seed. Pollinator destruction will be completed within
the time frame agreed upon with West Coast Beet Seed Company
representatives. West Coast Beet Seed Company representatives will approve
destruction methods and equipment. Equipment will not be used in another
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beet field until thoroughly cleaned of pollen and/or seed and inspected by West
Coast Beet Seed Company field supervisor or his representative.
1. Any equipment (flail, tiller, separator, tractor, vehicle) must be cleaned to
kill all live pollen before leaving the field according to West Coast Beet
Seed Company's policies.
The intent is to prevent pollen from being transferred out of the area of
control or transferred to where it could contaminate other Beta species
productions.
G. Swathing; Swathing will be done in a timely manner as directed by West Coast
Beet Seed Company representatives. Swathers wilt be inspected by West Coast
Beet Seed Company’s field supervisor for cleanliness prior to and after cutting.
Swathers will be cleaned in the field after swathing to ensure that no seed is
released into any adjacent field or area.
H. Combining: West Coast Beet Seed Company will approve the cleanliness of
the growers combine. Before use, the combine must have threshed at least 200
acres of another crop since it was used last to combine any other Beta species.
Approval for grower combine usage will be determined on a case-by-case basis
and will depend on previous crops combined and acreage.
Combines must be cleaned before they leave the field to ensure no seed is
moved into adjacent areas. Combined seed will be placed in designated tote
boxes within the confines of the existing field. Grower will clean off the truck
deck in the field to ensure seed is not spilled during transport. West Coast Beet
Seed Company's supervisor will approve the cleanliness of the grower's combine
before leaving the field.
I. Bulk Seed; Growers will not be allowed to transfer bulk seed to totes at third
party locations (i.e. grain elevators) unless, upon approval of West Coast Beet
Seed Company, the seed can be transferred in a manner that would allow
complete and easy transfer without contamination of equipment or surrounding
area. To avoid spillage, growers must not transfer seed from one tote to
another.
J. Hauling Seed; All loads of seed shall be covered with West Coast Beet Seed
Company approved, high-quality tarps and/or sealed with lids so no seed can be
lost during transport, GM and non-GM seed will not be hauled
simultaneously on the same truck.
K. Post-Harvest Field Management: Fields will be shallow tilled after harvest to a
depth of not more than 3". To promote sprouting of the shattered seed, full
irrigation is required, unless a West Coast Beet Seed Company representative
determines adequate rainfall has occurred to promote the required sprouting.
Fields will not be fall plowed for any reason. Control of sprouted seed is
essential to prevent any pollen release and seed formation in future crops.
All tractors and tillage equipment must be monitored and cleaned according to
West Coast Beet Seed Company’s policies before leaving the field.
Event H7-1
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Appendix B
7/28/2010
1424
The intent is to prevent seed from being transferred out of the area of
control or transferred to where it could contaminate other Beta species
productions.
L. Fields will be inspected by West Coast Beet Seed Company for a minimum of
five years or until no volunteers are noted.
M. All of these actions will be recorded at West Coast Beet Seed Company in order
to establish a record of adherence to GM policy, whether the actions were taken
by the grower, the company, or by both in a shared responsibility.
Event H7-1
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Appendix B
7/28/2010
1425
Event H7-1
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Appendix C
International Seed Federation Code of Conduct
216
Appendix C
7/28/2010
1426
Inicrnationai Seed Federation
CODE OF CONDUCT
(adopted by the ISF Sugar and Fodder Beet Commission)
Principles of quality assurance in beet seed production.
(Final version of 22 October 2007)
Summary
The principles and measures highlighted in this paper aims to the adventitious presence of
GW!'*® beet seed in conventional sugar beet and fodder beet, as well as the adventitious
presence of other CMOS'*® in GM sugar beet and fodder beet seed. The adventitious presence
of GMOs can only be minimized but not totally excluded because seed production occurs in
open fields under natural conditions. There is a strong necessity for practicable rules and
regulations governing a high level of purity for seed of conventional varieties reiating to
adventitious presence of GMOs and for seed of GM varieties reiating to adventitious presence
of other GMOs.
1. Objective
The objective of this industry position paper for the quality assurance of sugar beet and fodder
beet (hereinafter referred to as "beet seed") is to describe the measures the seed industry has
taken to minimize the likelihood of adventitious presence of GM beet seed in conventional seed
or adventitious presence of different GMOs in GM beet seed. The Industry recommends to
apply the same measures to table beet and/or Swiss chard seed production®.
This objective is accomplished by implementing guidelines and operating procedures
(preventive measures) covering every step from the stage of R&D activities up to delivery of
commercial beet seed to the customer. In addition to these measures, actions are undertaken
to control the various steps of this process.
2. Deregulation of GM beet events
The status of deregulation of GM sugar beet events varies according to territories. Similarly,
requirements set up by regulators may vary by country. Therefore principles adopted by the
industry must reflect these regional differences.
GM: Genetically modified
GMO: Genetically modified organism
This code of conduct has up to now been agreed upon by the following companies: Danisco Seed,
Dieckmann GmbH & Co. KG. Fr. Strube Saaizucht GmbH & Co. KG, Maison Florimond Desprez S.A.S.,
KWS SAAT AG, SESVanderHave, Syngenta Seeds and their affiliated companies. It is open for adoption
by other seed companies producing sugar and/or fodder beet seeds.
Event H7-1
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Appendix C
7/28/2010
1427
2.1. USA
There are three GM sugar beet events which have been deregulated in the USA. One of the
three events is commercialized since 2007.
2.2. Europe
No GM beet events are deregulated at this moment in Europe. As of today no
commercialization of GM beet seed can take place in Europe. There is one sugar beet event
undergoing the European deregulation process. This process has not been finalized. Similariy
there is one fodder beet event undergoing deregulation but the process is still in progress.
2.3. Other territories in the world
There is one sugar beef event undergoing a deregulation process in certain countries.
3. Adventitious presence of GM beet seed
3.1. Adventitious presence in conventional seed
Adventitious presence of GM sugar beet seed in conventional beet seed cannot be totally
excluded. As of today, there are no official thresholds governing the adventitious presence of
GM seed in conventional seed in Europe. There is an urgent need for such a threshold to be in
place in Europe due to the market introduction of the first GM sugar beef in the US. Thresholds
will vary and some territories or countries may not regulate adventitious presence.
Adventitious presence of GM seed in conventional seed would result from the presence of GM
seed or GM plants in other beet seed production at some stage of seed production or
processing.
Three possible main sources of adventitious presence of GM seed in conventional seed
productions are identified:
• Spread of GM pollen to multiplications of conventional seed.
• Unintentional mixing-up of plants during transplanting.
• Unintended traces of GM seed during han/est, transport, processing or storage.
Quality assurance systems have been implemented to address the issues posed by the
adventitious presence. These consist in preventive measures and testing procedures for
adventitious presence. They are presented in section 5.
3.2. Adventitious presence in GM seed
Adventitious presence of unintended GM seed in GM seed production would result from the
presence of GM seed of another event in a production of a given event at some stage of seed
production or processing of GM seed.
Similar measures as above in point (3.1) are addressing this case.
Event H7-1
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Appendix C
7/28/2010
1428
4. Pre-commercial and commercial production of GIVI beet seed
4.1. Europe
There are currently no pre-commercial or commercial productions of GW! beet seed in Europe.
Until now, production of GM beet seed in Europe is limited to R&D'”^ activities only.
Quality assurance measures that would be taken in the future for commercial seed production in
Europe will be focused on the separation of GM seed and conventional seed during the whole
production procedure (e.g. multiplication and processing steps).
In addition to this, tests for adventitious presence and traces of GM beet seed in commercial
beet seed lots are performed.
4.2, USA
There are commercial productions of GM beet seed of one deregulated event in the USA.
Quality assurance systems to prevent adventitious presence and traces of GM seed as
presented in the data sheet of the Annex have been implemented by the seed industry.
These measures are focused on the separation of GM seed and conventional seed during the
whole production procedure (e.g. multiplication and processing steps).
In addition to this, tests for adventitious presence of GM seed in the GM commercial seed lots
were implemented (this refers to traces of another event in a GM seed production based on an
intended event).
6. Principles for preventive measures and testing procedures for adventitious presence
in R&D, in conventional and in GM beet seed production
This section describes main measures (preventive measures and testing procedures) to ensure
a high level of purity for beet seed regarding AP''“ of GM. Three base cases cover all situations
encountered either as producer of conventional seed or as producer of GM seed.
The guidelines for preventive and control measures have thus been divided into three parts:
1 . R&D activities related to GM seed (all stages of the seed development up to the basic
seed production) - Data sheet in Annex 1
2. Production of conventional seed for commercialization - Data sheet in Annex 2
3. Production of GM seed for commercialization - Data sheet in Annex 3
The following sections outline general preventive and control measures to ensure a high level of
purity regarding AP for conventional seed and/or GM seed.
5.1 Preventive measures
R&D: Research and development
AP: adventitious presence
Event H7-1
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Appendix C
7/28/2010
1429
Several principles are innplemented in all types of activities and operations by each company:
• A quality assurance system is implemented, whereby every GM plant material is recorded
and can therefore be traced.
• sops'*® are written for all aspects of the handling of GM beet plants and GM beet seed and
the staff is trained and briefed on their use and application.
• Conventional and GM seed are handled separately, and specific labels or the unique
identifier will be used for all GM material.
• The above mentioned breeding companies have agreed in sharing information on the
locations and traits of their respective GM seed production worldwide.
5.2 Testing procedures
• Testing for adventitious presence of GM in conventional seed lots and for unintended events
in GM seed lots.
• Exchange information on detection methods of such traits which are shortly before
production.
More detailed information can be found In the Annexes.
Annex 1
Data sheet for “R&D activities for GM and Non-GM (all stages of seed development up to the
basic seed production of regulated and deregulated GM beet)”.
Preventive measures
• All activities involving GM beet plants and GM beet seed are subject of national and
international regulations which are adhered to by the breeding companies.
• By sharing information between breeding companies about the locations and traits of their
respective GM seed production, companies will have the opportunity to redefine their
location of seed production in case it is located close to a conventional seed or another GM
event production area,
• Minimum of four years of rotation between GM beet seed-crop and conventional beet root-
crop.
• Isolation distance of at least 1,5 miles between GM and conventional or other GM event
seed production.
• Bolting plants of Beta species are removed within a radius of at least 1 000 m around GM
multiplications before flowering.
• SOPs are written for all aspects of the handling of GM beet plants and GM beet seed and
the staff is trained and briefed on their use and application.
• Transport of GM seed only in closed containers or bags.
• Storage of GM seed in dedicated areas separated from conventional seed.
• Careful cleaning of all machinery is carried out before and after each step in the production
process of a GM seed lot or separate production lines (different GM, Non-GM) are used in
the production process.
• Monitoring for volunteer beets is done at fields or locations used for GM seed production
• Shallow post harvest tillage
SOP: standard operating procedure
Event H7-1
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Appendix C
7/28/2010
1430
Testing procedures
• Seed lots are tested for the adventitious presence of GM and GM seed lots for unintended
GMO before shipment to third parties, for example:
o Testing of conventional seed lote used for variety trials,
o Testing of GM seed lots used for variety trials,
o Testing of conventional seed lots used in field trials by research institutes and/or
industry.
o Testing of GM seed lots used in field trials by research institutes and/or industry.
• Basic seed lots used for commercial production are tested by either PGR or immunological
tests and/or herbicide application in case of herbicide tolerance traits.
• Seeds are sampled after harvesting or before pelleting according to internationally accepted
sampling techniques.
Annex 2
Data sheet for "Production of conventional beet seed for commercialization"
Preventive measures
• The above mentioned breeding companies have agreed in sharing information on the
locations and traits of their respective GM seed multiplications worldwide.
• In addition, as part of the information sharing, breeding companies will exchange information
on detection methods of such traits which are shortly before production.
• Isolation distance of at least 1,5 miles between GM and conventional seed production.
• Bolting plants of Beta species are removed before flowering within a radius of 1000 m
around GM multiplications.
• Minimum of four years crop rotation in seed production.
• Separation of conventional and GM, seed during processing
• The order of lots processed and pelleted is thoroughly recorded.
• Careful cleaning of all machinery is carried out before and after each step in the production
process or use of separate production lines (GM, Non-GM) in the production process
Testing procedures
• Conventional seed lots are tested for adventitious presence of GM seed by either PCR or
immunological tests and/or herbicide application.
• Seeds are sampled after harvesting or before pelleting according to internationally accepted
sampling techniques.
Event H7-1
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221
Appendix C
7/28/2010
1431
Annex 3
Data sheet for “Production of GM seed for commercialization"
Preventive measures
• All activities involving GM beet plants and GM beet seed are subject of national and
international regulations which are adhered to by the breeding companies.
• SOPs are written for ail aspects of the handling of GM beet plants and GM beet seed and
the staff is trained and briefed on their use and application.
• The above mentioned breeding companies have agreed in sharing information on the
locations and traits of their respective GM seed multiplications worldwide.
• In addition, as part of the information sharing, breeding companies will exchange information
on the appropriate defection method for GM traits,
• A quality assurance system is implemented, whereby every GM plant material is recorded
and can therefore be traced.
• Isolation distance of at least 1.5 miles between GM and conventional seed production.
• Bolting plants of Beta species are removed before flowering within a radius of 1 000 m around
GM multiplications.
• The order of lots processed and pelleted is thoroughly recorded.
• Careful cleaning of all machinery is carried out before and after each step in the production
process or use of separate production lines (GM, Non-GM) in the production process
Testing procedures
• GM seed is tested by either PCR or immunological tests and/or herbicide application in case
of herbicide tolerance traits.
Seeds are sampled after harvesting or before pelleting according to internationally accepted
sampling techniques.
Event H7-1
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222
Appendix C
7/28/2010
1432
Event H7-1
Draft ER
Appendix D
Sugar Beet Production by County and State
223
Appendix D
7/28/2010
1433
Corr/nDi/Y
Year
Sale
Rssiaj /yi nsposes
{Tlmsan±cfAc»s)
Harvested
filtousands cf Acres)
mm
ygg
rTDclucion
{Thousands afTons)
Sucn:ss
jPercan;)
■iTijifi
■nit II —
D.ct!ii
■KIM
HHHHHEHa&lciS
■■ESQ
HWJ
1.0GD
Hilil
Kn
■EiStl
aiD
sOO
tw
HHHIIliillHMlB^
■m
^KSiS^
7.«ia
7.300
MAW
tTC'sfiai
i&.^
1B.10Q
13B
HHHHHEliiSS
Kffi
1 ^ 1 PCfUn ZI^TTVSPin ^STTTIV^H
fg.ISfl'
—Wiu
Km
KKI
■■■HBnrm
25.400
»liw
■K^
500
=00
KS
HWI
2.100
Maaa
■^D
TiTin
III 1
4^0
isad
■HHBHIII^ISSI
wmmi
tnf7^.s^m
1.aM
»«H|-.I
KSIS
14(»
1.300
Hra
■Ki^
B.30D
KB
HraSI
22.303
1B.4D0
taa
4B5.0Kj
■KB
bgr.).f;;?sa
—
3.^B
KB
64i50
mm
'.tJTOaRrnSRBHHBHH
■m
55333
4.700
WB
■am
8DS
3G0
KB
KK
ac^3
Cdorads
DSQsastCctnlra]
11.500
1D1D0
KB
KK
iSunarteets
20QS
aoiorado
^^teTola)
33.«»
26.800
KSSl
(:S>KImI4aL*
mtm
iSSHHIi^HHHI
iiSt
kb
KEEi
mmm
8100
■E^
KS
mMaaaHi
S.30D
■fclB
ii^HHHi^i^l3
KSIS
Sfff!pR5H
leoo
■■H
Hd^
W 1 1 1 M
1.100
341
S7.70D
16,9EI
mnirmm
mm
(h>l«^nnT^iHji..i^.'H
1.ffi}0
800
32.6
22-.3bS
1621]
2!XS
D7Q Sculny^est
i&nno
17,500
34.3
6R1.0DD
mm^
\smmm
RrnmBMB
300
■aB
251D0
■■Si!!
tssa
25.400
20,100
■EiB
652.0D0
■KEBI
Boxino
1.00D
^ISf
■AM
■BS^
fcSffifiiPScH
mbhhi
mTKwmmm
HHBBIHTMililil
e./BB
»!Wi|
a/KBESl
■E^l
IBSSSHHHHIH
riHBHHKfTi^n
3.100
mmm
KKKISliin
■K^
mms«k\
2B.tD0
KB
■Bios
«<iSI
5<SI3^IEiHHil^Bii
5.eoo
KB
^■SB
mm
Rinn^^HB
1 nil uMrrr idSHliM
BO.0QD
55;55B
KIB
■Ki&!i
fcOTT.'TOTa
mm
Bin^jm
20.000
16.500
■BB
RnnBIHM
11.000
KB
KKBE
■H^l
iMUHIHHcClilin
20.500
KB
mtsfs
StaieToUi
131.000
116.008
KB
HHHBESSIEIil]
tKSES
mfS^':\
63fl donbined Ccunt^s
303
3fifl
«.«
11.000
HaZD
fe-M>-l-14Ca
wami
ws?™*
*kli 1 jM J :r
535
KB
«jI35
■USO!)
&00
10 GOD
KB
MKKM^
mam
■1^
Rftasrn^M
700
KB
17.000
mass
Kir^jTiFTi^^BB
3.000
K.ia
TOTO
wr^TfiTOfU
HkiK^
Xtfa»W*M
XRDSnrS^^^HHH
4oir
KB
1S.CDC
KB
■■n
3.100
KW
amm
pfnTi.THFa
■Bsa
11600
i 2 .eoo
■5M
HHESEEH)
»i»i
iISSuElil^HHHBiBH
45,800
WB
IHHHHES3B&2
■KMII
i^^EHSHHHBHI
TUW
KM
■■W
■1^
21.100
H!l>l
HSE
tjpyijBMB
KiijitI
IB. 100
Km
HUH!
S5?S5253i
Deo sasi Central
115.503
113,000
KJH
KH
@SE5^a
IHI^
ISSEIHHHHHiH
500
Klllll
14.0DD
Mtf
SOD
330
KiB
ODB
Kffl-T'1
!W:iTI
1.200
K<B
30.D0D
17.20
ERfRW!?®
(SlSSjSBII^B
ItikliUgtriSKBffSSMI^W
zsoc
2,100
K3i
a2.0DD
HEil!}
^^SSSSi
OS^SfSI^H
Genesee
300
300
KB
6.0Q0
■■sni
IS^ISSJ3IIIII^I
1.100
■Bilil
■KQgg}
MBgg
SiSI^StlV
i^SS^HHHHil
^uniiiiiiiiiiimiim^g]
15D5
IKB
HHHHBESiSlS
amm
IMga—
'isr?ii39fiSffm^^^H
2 ROD
HHHHHE0SI3
MBl^
j^fflSuSSS
itm
1 —
137.000
136.000
KB
— — iHijiXUUiJ
Him
MRgI
iiSSS^IBHHHH
7.3Q0
2l.i
153.D0D
17.1D
bgf.|tli.[-j4'gM[
ISSBHHIIIIi^H^H
jiiimii[iiiiiiii^^gi2iQ
mmi
majmi
@SSiIS3i
32.700
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IHiSSSlIW
lISSiSSSSSBHBHH
1.700
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■EH
li^^l
IISSSSHiH^^HHii
41.200
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IBESl
IlSSuSlIBBIHHHi
33.000
MgE
HHHHEISSSSI
■■SB
^SuSSSH
IBI^^
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ilZEBIHHHHIBBI
1 1 1 )i
sBiob
26.5
■m
'■Kl
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OHiTS^S^H
IIH^HHiiiE^iEl
■IS^
DlONarJirttsj
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■■■KiSESS
■BBi!
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29.aOD
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HEm
Evenl H7-1
Draft ER
224
Appendix D
7/28/2010
1434
Cotiniy
Fisrried M rutposes
fnKu^ii^ ef Acres}
Hani'eslsd
(Thousands cf Acrss)
BSI
lUgg
Frcdueitn
(Thousands ufTons)
Sucrose
(Peixeni)
wmbim
Caitfcmia
— 5TT
164,000
1S26
SiioarbeEis
Catifemia
1.000
Milil
BBBHHBEai^
IHBl
S-iToaffaeels
2‘^a
Calif^ania
351 Conbtn*-d CciMss
500
500
3&.0
IS-ODl
15.02
S'jaarbesis
2CQ3
California
351 San Josau'n Vaiisy
7J0D
7.300
32.6
233.COD
15261
HTtfSl
1B.10Q
1S.503
iS.iSQ
4Zz
770.000
15.35
2806
C^ifnntfa
'TT*%i"W— —
■■■■^Kfxrrn
25.400
397
T.&M.OGD
18.58
isw.mMiJJc*
3SJ3
£00
736
1t.3D0
16.78
Larmsr
2.800
ztoo
Kil
H^B^BHII^Era
iKlti:
KaRFr,tT53C«
■n>w
335ff
■■■BBESESS
IKS^!
Sa?i'<liTit'n3S*
■■■■■i^^KYiTirt}
IsCfl
mmi
3C-.8DD
IIKI^
tai
1.300
M.Ka
^-.89D
2im
Cclorada
0.200
27.6
257,000
16.011
IS^arbeets
2QC3
Cckira^
22.303
18.400
KIS
HBBBBKEmm
bbbesi
»£8?»Kn>T33M
■K^
3.4CD
24.6
S4.8D0
16.08
m^A
•fSRfrceMH
i.aoD
2fAI
i4.35D
iS-bS
4.7Q0
27.6
131.DDD
16.41
gngggffigi^gi
fiOO
SCO
Tm
BBBBBBESES
BBEHii
WJr.H!>!=t3L-«
■^1
•BfSffrRSh^B
360 Has: Csr.*/at
iiaio
1D.2DD
■gga
jBBBHBI^l!^^
Tn
Suaarteete
2QQS
Colorado
Ststa 70121
33JOO
2a.SM
BflHBHBSiE^
■E2&
S^aarbsEis
2K-3
Idaho
iififl
36.0
&4.0SO
S^marbeeis
2C*Da
Idalto
0.200
35.3
22L0DD
Ifi 201
2£G3
5.300
31.6
157300
15841
Si-aarfeeets
2C?2Q
Idaho
2.600
BESS
imiiiimi^^]
BBESH
fi3W1IJ!a?S'ai
1.100
S7,70D
KS
mmm
•llihSEUSSiSI
1.003
800
Mpgra
mmm
iSiiOarbests
2CCe
370 Sfliithw*»5t
10003
17.500
_M,3
6I&..0Q0
WKEM
ir n
Idaho
SOD
twa
2500D
■KB^
MJ-M
Cassia
25.403
20.100
602000
KK
m^A
SSSinHHHBHBi
ado
■EEl
1*2.000
BH^
r^iamma^m
lf3r!«73^^HHBHi
MBHHHmiiliTn
8.70D
32.6
iie-.0D0
i/.ea
KRmHHHHBIHl
■■■■■■ciTiTil
3.100
Km
63.000
BK^
Htjahl
20. IDO
2BA
BKDDD
17.031
fegpinirnM
“wh Falls
7.000
5.500
KB
■KKl^^
■BalS
lamrat*
muB^
fmaaiH
33QSoutn Canlrsl
§3i533^
60.000
mm
KBBi)
m^j^A
1B.5QD
BBB
■BiS
11 COO
wm'm
KBnD
wr.iit.M-.iL«
20.500
fTTR
BBHBHE^OHS
KB!S
kiU'f '*•!-; 'u-B
2006
Idaho
State Total
nt.ooo
118.000
KB
■■■Ksm
■i[Mi
!.lich' 0 an
i1i:Til«r«tJ.i ilU-i.1W JII.1 K>tL«
^55
■PM
1055
■n-ni'i
HpTTnTWH
7ffsyrn»*
300
mm
niSb
KSB
WFUi-lilHI
■■■■■■nrsi
fiOO
WtfSKi
20,000
■umil
U*>r.Kli»IJ4L«
K^J
"' HIM
10.000
24J
245.008
■Kra
700
17,DDD
■QBi]
«Tr4.'i444i--«
3.000
tan
OT5
■KUd&i
Wȴ-J
^ini^TT—
<B0
na
fu®
Ktei!)
15.DDD
Maw
357.000
KMi^
l^'LUrliUll
M#]
5 100
67.000
■KEIil
!S-jnarbeets
ISiS
'.lichdan
5a^
12.000
12.500
MKI
341.000
KH
B!PE52S33i
[SS^5iE33BBH
45.800
1.336.000
iOSl
SStESISSSI
SgSTSSl^H
iJlDS
»MW
KI«
RSHSTJ?®
[JESSMi
21.100
KBBBR^i^
■Kli]
m!smm
[!^nai
1B.100
SOI
&44.50D
15301
IKS
‘.fch-gan
1 16.500
116.CD0
■is
uir.nimm
[!£QB3HHHHHHHI
500
wmsm
HBIliHBEElISiD
KfA
iS^SIUlHI
3C5
&.ad&
■K^
Sg!f5?fBgi
■ILI
[S3RHB
1.200
KSD]
s?.ooa
■Kil
LCHtnarbatUs
2coa
'.iiefi'nan
Dao Snun CsnfsJ
2 500
2.100
26.5
S3.099
1T.3D!
iS^inaibeels
2K3
'.licrgan
300
■1^
5.0D0
HI^QSj
■HBBn
lESSSf^ZH^I
[Qi^jiiiiinniiim
1.100
ksb
i2SSl!^3IH
ggggQIlllllllllllllllllllll^^
l||||[||||||||||||||||||||||^
1.200
IKB
32.QDD
Klffli]
gggga—
I^HB^BIIIIi^^
1600
28.1
73.0DD
i5.nnl
■EiH
UfSS^HtRlHi
SbrteTotsI
137.t»D
138.000
KB
KH
■ESS3
iSSSjHHHHHHI
7,300
21,.!
153500
ir.iDi
2&D3
ggcmiiniii^^iiiiiii
BHHHHKEiilliS
38.000
23.0
6i5.100
iBjol
EuoartiesSs
4innea:ta
tSIlSISHHHHIHHil
32,700
■^i
S17.00D
Km
S-sioartteste
1003
'.fsinescU
Mahnanen
.2I0Q
1.700
32?
37.800
i7.nnl
H‘jn3 [basis
MinnescU
BHHHIKIlSiSl
41.300
■BflBBE^^^H
BBEHUil
'^ctTTan
53,103
S6.00D
24.2
546.500
17.10
■1^
fi3.2flS
26.3
2.335.000
17.50
kgr.kli-i44L^
■Bga
^ed Lake
1.200
1.1CD
25.8
:a,40D
17.30
13WSn!958BI
DIO Combmsd CciBitss
4DD
300
i^i
5.503
wmm\
iStvOariiests
loos
•finnescts
310 NoRhnost
261.$}D
245.500
24.6
e-.124.50D
17.50
ZmSHi:
Chiopst'/a
SOJJniD
20.SOO
23,0
654200
17,00
Event H7-1
Draft ER
225
Appendix D
7/28/2010
1435
Corrmcday
■w—
PIstied M rupases
{HiiKisands of Acfes)
■HI
Frnducdarv
(Thousands of Tots)
Sucrose
jPercen:)
S-wSameets
— Wtfftiftgir
< ; iH3
oSCD
S!7
iM.ui'a
"'loISc
kgf.hl,.!44H
^mmmsmm
■■■■■■KITrif
1.CC0
Milt!
■BHHiii^^^
■m
imsBffftmtsmsm
nOD
EClO
■■■■^^ii^
■Bios
BFFTi.'mTa
74{g>
7.300
328
232.030
16^
KEtsa
1 1 1
18.100
■K
llllll^■■HD^^^
tisarn'iir'i him
iKji^:f!WuT?MlU*t:ir/>.'<.'<KH
1S300
16.100
42.5
770.030
16.651
^nraSlSBPjrT'IM
2S.4QD
■HiHU
HEK.^irJ!nffi9rMHi
500
27.e
11300
HKn
LaE'msr
Z80&
2,H10
24.0
K.4DS
IM^S
kai.n..iaj!Hi
»«eii«ra55f^™
24.7
03,800
■HS^
i^■il^^■^Kl^t]l^
libfl
24.6
3?-,S0D
■RH
■W^iri7!!!!f!5!9BIH
■■■■^■KFTnn
1.3DC
27.4
35.800
■HS
^B?;v!^ig!n!T9!n^B
■■■■■■RBTPn
8.70C1
HlQ
257.000
IKES
kfflJMi-USJlrl
1S.4DD
M-tH
4E5D03
®hri«
3.400
KB
64.800
■Ksms
f.3'fifl
■■HHiiml^m
■KH
|■|||||||■|||^^^|Qg^
27.9
■HHIK^SSSI
BOD
SOD
—ara
SJ.IDD
■HSiB
Bssma
11.300
10,200
■Biin
273.QDD
H'l-T't
ZQOSlCoterado
StateTotal
23.800
28,g3d
7^9 Jbb
■KSE
■KSKiiman^
i.Sbb
&4.S555
■iffi
8.200
3n8
222.D3D
■B^
3.200
KB
(■HHHK^E^
2.600
HESS
■■■■ESS^
■m
mui'&imviimium
i.iSo
HR
■KMl
1.00D
800
■raa
■■■■ESi^
■ESI
2GC-a ildaho
370 Sciithw€£{
ionnn
17.500
■EB
■HHI^^^^S
■BOS
800
HiSB
25.000
KEBS
fc5T!^!!33^
■u.<.uir.e!nHHi
20.100
6SB.0D0
KBS3
Ml II II 1
eCTPfnTHBHI^^^B
€00
mem
HHHHM^u^
■m
^■BHHHBIUTi^
e.Too
32.6
316.OD0
17.991
3.100
MaEtii
92 000
KSH
29.100
KB
5K.aDD
Kn
RiraUBSl
w«<!-.i!r.r!nr^^
s.eoo
KM
177.0D0
KSi
■tWrllPP.T—
iTjiKhrlisCtPmTn^HM
&0.00D
eo.coD
KEB
■B^
BinchJfn
20.0QD
18,500
IP
Kwm
11.000
Kffl
■nsni
Ml mil 1 MMB
«l III f’PMMM
28.500
31-7.
_ 17.271
■KilrClieP'.'Tl^^M
StateTotaJ
131.000
118.000
KtW
^^■cnKi
A AilRnMH
•W'«iy-!fi!'llil--S.lif*ll|iiei«
Sbtt
Sflfi
MiHH
11.000
■Kl'1
»wi^'irir'^Ti'—
■Niifi.»>r).nd^^H
36&
MilOH
iXSISS
KW
flOO
KB
SM3
KBS
10.000
KB
■BS
700
K!W
17.0DD
KBSil
3.C0D
MMH
7-#.030
KSil!]
wmrori
■■■■■■■ETiin
<EiD
KB
llObS
KlSt!]
15.000
KiW
ifiiaea
■nBil
Biif'''‘liili' iH iii^ii
3.100
HD
^^HHHI^SIu^
Kffl
12.M0
12.600
WB^
KHKIISI
■■SI
kgf.Mfl !JTM
•KigfllS^a^SagHi
SZIuIBHHiHHHHii
4S.eoo'
—30
1.3^.083
IS.501
msnssm
^SECSHHHHHI
10.2DD
■ES
■HI^H^u&a
tmB
21.100
KDIF}
18.100
mn
544 .000
■n^
@5253531
1ie.5DD
115.000
MREB
3.3'».0!)9
Tfn
glilliSins
Clintcn
700
cOO
14.020
^■^j]
[SiilHIlHHi^^^B
300
HQ
8.QDQ
■KBD
1.3QD
33.0
itf.QDO
!L2a
CT?P!nR?PB
1 in III 1 iiMi^M
2.500
2.I0D
62.09D
KIK!
@f>SIlS9
Een55&e
300
300
KiH
■HHHHHillEI
■Bf.-W.l
SES331Sli
l^lHHHBBSEcJ
1.100
M;lilil
S3.0&D
■HE
SISHHHBHHI
1.200
M.I.M
32.0DD
■KEB!]
(lEIlIlSISSSHHBHi
7.enn
i^B
■HHHH^iiSS
Hn
■ElEilBSHI
IT"iTli'''T''— —
137.000
13S.000
KiW
^^kieseib
Hm
HE^ilSBi&ISSSBH
7.300
3I.«
1K.0DS
HUE
CT!iitil»i45tjW
33.000
KB
&f5.1D0
■HE
33.000
~~WjW
Milsia
617,033
■im
BBSmISSB
I£I!S^S9M
(SSSSSSflHHHlHI
BBHHHHHBBIH]
1.700
KS)
S7.6DD
^■n
[l![S!SS!9HHHBHi
41.200
KB
KBS
^sSSSSi
[SSSSHHHIilH
33.000
24J
S46.SDD
17.10:
Se.2QQ
1^^
■■■■gESSi^
■mm
K»tiEii.«ci;^M
HHIHHKEilS
1.1Q0
25.8
33.40Q
KBS>!
.100
■EaH
■■HHHkS^
KSl
M!!!f5!H5ga
■SIS
■■IIII■■S]^@
KB^
H^^|{SIi!S!SS^Hi
SSlIlSSSIIlillHHI
Man
^■BS
Event H7-1
Draft ER
226
Appendix D
7/28/2010
1436
—
state
Flst^ Al riaposes
■;Ths»s»):& Acres)
HafKesifirf
(Thoasands of .Acrss)
Yisid
{ToraJ
Frcducian
(Thousands sfT-orts)
Sucrcse
(Percent)
b.eUi]
31.?
BWr
■^■^^■■nrrn
l.EOO
■im
&5.02C
16.86
■1^
Sl^
fOD
■BBI
■HBHHIIIIIIISOiS]
kch
wmm
iTtlfi'P-r"—
ii'iid^jilkrik4lTii!.ii’^=t^4i
7.6Iffl
3■■■3EEll^|i]
■W*1
HHHHIII^I^
■m
18.100
■E^
k^es
C^^ifcmla
380 Sculhem CaQicrra
1S.100
■EES
■KEiii
fe8f!fti!R3Sl
mrm^
III 1 '!'■■
25.400
MB
iB13@
■KZSPEI
cOD
■@3
11 300
■mill
latffiilTiei
2.100
HSI
52.4D0
HSi
mm
•fSIiliTi^S^^H
1.£0Q
■KW
kbes
[sSRffiS ■■■■■■■
1.300
■EnS
■■■■i^RRTtn
BJ20D
■E^
Kim
Sisc-a
Cdor3±>
D30 fisrthesst
2^3Cg>
18.400
waa
4S5.00D
■iltl
■■■■■■■niSTrn
3.4DD
WB
iiroff
— M
ti9T«K!i!I33C?fc
1.3fl0
HE9S
.KH
bSSHisas^
HSi
4.700
mem
'Km
2-30S
D80 Combin*rt Ccuntss
BOO
800
.2M
23.100
ie.30l
1^
CcJorad:
D6Q &is: Central
1t.80D
lOJDD
Wif'TrrittrjSI
m'hw
*W?!Trn?!l^B
28.^00
HHHHHESOSlIiS
■am
|iTOilS5Sc^
■Em
l.fOO
■mu
■K^
illll^
IIIttMBlII
6.300
Km
5.200
31.3
157300
15.84!
fcWI^SRSB®
■■■■■■KRTli)
2.600
wmir^
■m
fflSHiSBESi
r^wmaam
^hbb^bhh^
■fcaa
■SEi
■jjto^
Ifiiftvr.iMidMixIVx'llilZi^'S
1.000
800
32.9
KiaoD
isa
.. 2Sqa
'daho
D7D £cuC".Y<6st
le.ODD
17.fOQ
HSb
Hn
■■■■■HiKTiTn
800
■BEI
25 000
tasBWRai
VilKI
Cassia
25.400
2D.1DD
■BiTii
6&3.0DD
Mtffi'l
wmm\
mffimam
cOD
K^y
55355
ierorr*
11.003
9.706
wail
drr^TiJrnra
hrxhm
mmBHHlHHHi
■■■■■KvTnti
3.100
Htn
HHESCSSl
2B 100
_. 28.4
855.000
1T.B3.
JiWni»!25CB
■555^
SRSfSnnHHIBH
■■^■■■ITTITn
s.eoD
■EIEI
177.000
■USB
KHI.Hi.l-I-U-W
R^nnBi^B
IKtlKrBIiCl’«W!W^^*
69.000
^ bwod"
Wli«
■iai]
fipTi^riiTOirw
■R^l
18,200
Km
mms
IRTMB
mmsE
■ESitJ
29.200
Kna
^SBS
nttmiwn
Win
rnxBHH
stale Total
131.000
118.000
KtH
MBES
W^'l
D30 Conbir\ed Ccuntes
300
-'ggfl
■■.I.W
HOT
Hum
mim\
KinwraiH
306
mm
~ i*35I
W>M
60D
22Zi
2Q.0D0
17.801
i■^■■^^KTiY^T^
ID.CDD
240.DDD
Km
WW!:I
700
■ml
17,000
K^
HmJTTSW
■Kl
A II •n 9 • K
3.000
W.Til
75355
■■m
2S?
MicJtdan
400
WHB
iT35o
KUfl!l
Mssrogi
W>t4l
^■■^■I^KElTiTn
16.C00
Km
S67.000
Km
HHI^H^^^^EVTTin
3,100
■Kill
57.000
■am
kgrTTi«I-?-V-M
Hfcmi
iSSSHH
Bav
izaoo
ueoo
27.1
341.000
15.00!
QSSSnSMHI
CZSSIHHHH
4S5B3
— 3S3
i.454.(J55
— Wm
gnsEGnsi
iSO^EnHi
SlfSBSHHHHIH
!3!5B3
■ms
■■mi
si?r!rRigB
■tSt-l
SSSHHHHHIi
21.100
mesB
■■m
18.100
30.1
544 000
16.301
[SISI^ESJHH
11S,5DD
1 1S.ODD
23.2
3.390.0DD
15301
SSHHaS^B
■^1
^l33IHiiHHHHi
stib
■KHTit
14.0KI
Wi&a
300
»Wtt
0.000
IH^
I’lriM
SSSE^S^HHHH
HHHHIHDillli]
1.300
HSil
.3-JDDn
■ura
■^I
Z50D
2.100
28.5
32.000
17.30!
2X3
liOcitodn
HIB^BHHEIiEI
300
6.000
■USE
[SSSIsESHHl
lElSi^HHHHHii
HHHIBBHIIlS]
1.100
3D.C
33.00D
17.30!
■E^
1.200
SZODO
■![ggS
■1^1
iil>liL49lll99iaHBHHi
zeOD
20. 1
71.030
15.00
2908
Michigan
stale Total
137.000
138.000
2B.7
3.603,000
18.10
bUii;.i..r--!-jUB
ITTTTfTI 1^
7.300
21.4
1K-.0DQ
17.10
faajj^iufajLw
Wtf^
dJISS^SHI
ISSSHHHBH^H
38.000
210
675.1 OD
15.BD
iSlSISHi
ISISSHHHHHHi
32.700
25.0
617,000
15.10
EgTOHSBi
ISHiSSSgHH
1.700
223
37.fiOD
17.00
gggEBgiB
41.203
24.8
t.0S5.3O0
17.90
fiicrnan
Sd.100
35,000
Mgia
■131
q|^I52332BI
■E^
[2^200^2311111111
tiSQHHHHHHHi
^II^HHIIIIisEIiS
88,200
■MMMBBgaraga
{igSSr'iilHgPIH
■li^^
3HiiHHHBSli3
1.100
25.8
32 ,400
17.3D]
2iKS
Wnnfisota
Did Conbined CcUnt'-ss
400
3DD
2S.3
8,5QS
17.30!
£-jaarbesis
"rxv?
NSnnesDts
DlDMorJittesi
.•'nln^h
245.200
KSU
Ml^
SuosfbEsts
T&^a
'»finne=ct3
Chlpoev^
28.800
Kaa
WtEEM
Event H7-1
Draft ER
227
Appendix D
7/28/2010
1437
Coirm^tly
Year
Siata
HHI
Plepsed Ml rurposes
{Th9JS3^ Mtes)
Hsfvaslsd
phDusarrfs cl Acres)
■Hj
in^
Sucrcss
PenKo:)
Idi'EliMItS
mmi
22 1
2D5,St)5
16.70
■aa
S,igO
2if
73.5DD
16.40
Wf^
mrn^^riKSm
1.500
■1^
■MBii}
HKfXOtl
■
8.200
■MMMKS^
■mil
■1 . i..7 ! — wm
■■■■■■Rnnw!
a.20Q
Ma0k7
■m
faiH.VLr>Tn!?e«
m ..1 — H
25.700
■K5B
MMMMHI^^BiM
Ha
Y6;c'«M=<3irJr>=
3u203
3.100
HS
MMHMMMS^!
—HU
?ail^!H!ll!BWil!Bga
000
eoQ
16.7QD
■iHiSI
D4QVk'ett Cental
P2C0Q
BicIrJ
■MMHB^li
—
■
14.400
— m
k«raei
■
IaQU
24.4
S4,10D
16.70
■ " 1
32.500
25.2
E22.SDD
17.00
3.200
24.0
7^.700
16.60
l^tSOSlS
■Ki
Al<llll44>t«rtflii
2.0QD
274
44.700
17.30
iSyaarbesis
2t3C€
2.503
4.40D
26.8
eCiJOD
17.00
S-aoaftegls
25^
DaQCsrcral
57.MD
58.600
■m
tohvp'li-ilww*
4Q0
■i^
■MMMMMBHiS
■m
■i^J
^edkvocd
3.603
3.40Q
MHHHMM^I^
■m
teii.V'i>iaak-»
2C02
'41nn8acta
370 Combinad Ccunties
300
200
mm
MMMHMME5IS
HK^
mmmjm
■1^
inn^TTCCn^BB^H
^■■■III^^EOIilS
mmsm
■■■■Iggggg
HKB
■1^
1 13 • riiOt 1 un
BOO
eoD
mam
BBHMMBSii^
HH
■BH
i^'l 1 1 ,..l..j.!-l<i
Hf^Eh /frf ■■MIHH
■■■■■■FTTTriTn
393.0DQ
K!Q
MMHHEIl^OES
MBq!^
lE^jaarbests
2sca
(.tentana
D30 ConbifiSd Ccunt «
6 003
6.600
KE
MMMMMCSI^
HM^
ISynarbests
20CS
Mcntana
DSQNsnheas-
6.003
aeoo
mukti
S.SQO
■ISIS
HMHMM^SI^l
wmmi
AWtUlikHHH
a.soo
mmm
HHBMMESES!]
MMQS
6.000
mtm
BMD
HiW:1
3503
1500
Maaa
1JV}-7E‘Q
MMfXi
tSESTLTSHI
■Bsa
ikIcnOna
02Q Scut^ Cerural
22.803
2i.aoo
BgP
■■■■^SSiE]
Bn
KPfirMl*^44
2.GD0
wmm
HMHHHIi^^^
—m
2C-ca
Mcntsna
DOO Scutheaa]
2.CCD
msm
■MHMii^SBiSil
HMfiEE
KEBl
TiTITrirMi
30.700
M^n
MMBHMB^iIIin
WKSEl
ifflTFliTm:*
400
Wfm
^^■IHHHEIEIilO
■KHB
kr.Hiiiiri
■KM
■■■■■■nFTtin
17.300
■ra
^HMiMESII^
wmsM
mnrmm
■KA^I
■■■■^■KfTfrsi
1.100
37.300
wm^
feStElri-lU^
W>»1
mnmTMi
2.600
■HR
SS'.AOO
■■n
»KI
iTOBWnMi
4.100
IRB
83.103
■ds
■K<i^l
TRSlPnBB
5.700
■HU
■dii
ySf.f.|,.lJjLfl
■Ri!«j:l
l£QiIE2£^B
2400
■KHI
HMn
WiHI
im-rv
w.T«»srai«5rarai
703
700
■HR
iSj55
mam
tyrMS'-iA*-#
wmim
iniimssBB
•iiiifi.r;[rra:^^BB
^■■■■^EIXTiTil
SfSSlJ
tw
771603
■Kn
y,cs
jn!CT5^B
800
■BcR
10.KKI
SPBTTB?!
mrmi
laoo
w-in
4f-.DDD
Bi^
srnrro^i
^IT'iT 1
eoo
■«!H
14.700
WKsm
wffr,THril
«gg]
Nebnska
□70 Scuti/«st
4.100
i.fl05
laH
7535
BtHS
t.-|| II Ml ■IFTTtlfTrnTTP’F^M
3735ir
mrm
■■■■m^vf^
msM
m!tmqii^«a.gBai
BHHHHHHCnS
1.900
■< 14.1
43.030
MB^
fayjMEra
iillilMWtWjiB— M
1,900
■S
43.000
■Mn
me^
iiM,i,i.nw
WRU d.fl
27, COO
■ElQ
T^i.ODO
BBES
EESSSiDB
^uUSSHHH^Hi
I^HHiiiiHiSIiSE]
68,300
25.6
1.4'S2.000
mesB
HHBHBHEQUIEl
40.40D
WWW
assKiiisai
:fiit!li|j!iB!BW^—
127.090
125.790
mm
BIVI1
5.8C0
mm
Msn
HHKTifTBM
D40W«st Cental
6.203
5.200
144,000
MMn
IHHMHKHISS
16.500
IBS
HHBHHEE^I^
Bn
bgffkfj.u^u
wmm
'MMSBBIHHHHi
millHIII^HIIQI^
400
WEB
■MHHIKSIIISI
mw
ysajEsai
KMI
24 con
B^i
HHMBill^Si^
43.503
41.800
MBSI^
bg!ffBy45?BI
<tr.r,4i.g!af
21.4EK)
mm
HMHMM^S^S
MMiiS
KSMSi
2025
403
400
mmm
MMHIliBMSESS
■m
SSuESSSI
2&200
21.500
mBm
MHHHMI^SSSil
■HESS
■n
HliHHHEIIilCM!]
137.000
■ElS
mm‘^
■SI
SS^SHBH
IIIjaSSHHHBHHHI
1.400
mm
BQ^
Sucrattesls
aeoa
Of&xn
D30 NorJieast
1.503
1.400
mm
■■|■||■||^|i]^
■Bn
tS'jQartieels
2isa
Oreccn
Malheur
5.200
4.500
wmm
■MHHMI^g^
msm
4.500
mm
IHHHHHK^^S]
Bm
iSJSiBillllH
Stale Total
6 700
S.9Q0
mm
MHHHHBSliIiEI
MBS
mmmt
IBiS
BHHHHHOniiS]
i.aoo
■SB
imm
bBg.!i«W4M
203a
i/VaSijngten
Cerrral
1.80D
1.600
MBS
■MMMHIIII^EllS]
MBS!
kSB^ir-gsgi
{l2£2^B:^HHHHBIil
iiiiiimiiiiiiiiinim?^
ran
MHMHHI^Sj^
MBS!
I^^ISuBIlii^^HHHi
8.100
KS
MIHIMHK^S^
MMB
■SI
1.5C0
■Enn
MHHMMBSSSI
Bn
Event H7-1
Draft ER
228
Appendix D
7/28/2010
Event H7-1
Draft ER
229
Appendix D
7/28/2010
1439
CorTTOKi-ty
Bl^gi
Ptasted ^1 T^iiposes
{Ttoj^Kfe cf tees)
Harveslad
(Thousands sf .^cres)
Qg|
Sucrcse
-Jrercen;)
Suaartieete
ejgimiiiiiii^^Bi^ni
8.3CD
22.1
255.503
IHBI
S^jdafteets
^Bd^lMniTiT^sfSH
3.1C0
msm
73.502
9lim
l3l5B«>f5SiSi
■■■■■■■nrinn
J.5DD
99E1
SIDSO
17.50
4.3GD
25.0
107.302
17.20
9H9I99^!E?h1
0.200
25,3
1&D,1013
17.4Q
KSiRTiiTSta
8.2C0
wmsm
9999H«^ffl
■■Bui
S^joartesls
2-KS Minnesats
^^^^^■KISTTS]
25.700
■cgfi
9999il^!^i
9ra^
Sgsarbesis
YfeEcvj ^teolci^.5
32!03
3.1C0
21.5
K-.eoD
Ir.DDi
^'^uarbeels
2C>2a Minnescti
D4fl CombifisdCtxmt-a^
SIO
eoD
15.702
raaoii
Sugarbests
23C3 Minnescta
D40W&£tC«nS^
ne.Qoa
92,000
23.7
2.152.332
16.60
14.400
252!
376,600
17.20
i:pr;feiiinEC«
Hst^lXIfiRTSSSHH
1.400
24.4
31.102
16.70
:^.TiarfaBSlS
RenWie
32.700
33.500
5X.300
17.00
iPtrnarbeEis
2‘I-‘2-d Minnescts
5^‘ev
3.20D
99999K)kS1
1^
79.7DD
16.60
l4i«.*tli.W4Ca
Steams
2.1D0
2.000
22.4
44.70Q
17.30
MggaitirrnrTV
)c0 Canhined Ccuntes
3.300
3.400
a..c
K-,5DD
17.00
5B,iDD'
■KaB
HaM
iOD
15.3
6.102
17.00
Suoarbssls
ij3!l!SS099HHHi
3.4DD
226
?6.b:.o
16.70
S-yaarbesss
m
2CD
15-= 1
3.7QD
17JD
S'joarbeets
2003 Minnesota
A2K1
l9^^9HI^3iu3
21J|
£c.60D
SjOarbeslB
3X3 Minnesota
SOD
SCO
91^
15.300
911^^
Sunarbeels
■TSitnnRmHHHaHH
399.800
mprwi
S'jaa/besis
2i>2 Montana
D30 -Donbrnsd Count es
S.MD
6.900
24.9
171 .900
16..32I
Sijoarbests
2Cv3 Montana
]20 Northeast
&.K)0
e.QC0
■rag
I999KuE^
911^1
BiBpynBsci
■r'fTTrifin 1 II —
8,300
28.3
253..D33
16.01
3.500
24.0
53.930
16.84
BBBSRIWStTsnS^^^B
e.oon
25.C
155,200
16.PB
i£-.icarbesls
■Hii«iifflB!r^!iiBiaa
3.502
S.non
1CC-.700
^■ai
iS^narbesIs
iC-CS iMcntsna
oao Scutr. Cenb^
22.8DD
21.200
27.2
592.830
15.86
WR7Fn*TOC«
j;5di
29.2
5=.305
17.35
BSSfflSS™
3S0 ScuDeast
2.0K
2.0CD
29.2
SS-.SbD
17.36
Iff n
30.700
26.0
S23.0D0
17.27
iQD
■EiS
■99991^1010
M3EB
W.WIi'WJH
SRfEDCmBHHH
1T,3DD
mm
99B9l^i^&]
1'rtH
laiiifcitn^iyh
■■■■uHiniiiti
l.lflB'
24.3
27,S&D
if.22i
lctf.{g|iigiqi
■iaB»a!^iii m^m
2,600
21,3
BSiS
1r.S6|
kilT.W.4--HL-«
XRnn^Bn^^^^H
4.100
9k
93.100
■ESSIITnBI^H
5.700
33-1
131.900
16.311
i^stEstma
^iSl^ll9IH9H
3,400
22.1
63.1 DO
15.85i
vtottiiisrnmaM
■IlIHRtSiniaSilWdlltltM
70D
700
99S
lllOD
iHSiS
ikMi^.ll»R{Trfl'niHi
3tD Nanhrtes:
41.10D
34.300
7>2.^[)j
■i^
HdtWaiiB.TffiSBH
600
Mrti
10.500
■■SiB
tsRFTiJn^Ea
H(IUA1l!n77n9^^l
^^^HBKrrrsi
1 son
9BEin
45.000
kflfrfflTOPl
■■999^Hn)]i]
eoo
WEB
14.700
■m
W.H343E*
MaSSir'TI^TTTlM
4.1DD
3.CC0
■KH
TT0.2DD
■DEB
Hr.'Rri'raii
■►wiimT-nTiM
stale Tout
45.200
57.56ti
22.6
lllllltoWtiiirn»ili^a»y-iij
SSIS599H9IH
99^^^9^3E!SI
1SQD
■■MM
43000
Is-joaittijs
iC*33iNcrth Dakra
DlQ Nanhftes
2.10D
1.C0D
mimi
43.020
910^
igipsnESi
MEBBSinfBr.aiBgjBW;
199991^^9
27.000
msm
TX.OOD
SS1!S!E9HH999
H9M9H9IB2!IiSl
OB.30Q
25.8
1.4-92.080
iS£IS^^9HH9BH
999iHK^SE}
40,400
iii
t.O55-.D00
(■nsoB
^lioarbeels
2'I-r3jMorth Dakota
330 Nartheasr
^77 non
. 125,700
28.0
3 Om DOO
17.851
S'joarte&ts
99999^^13
5 200
144i)0D
1B18I
S^jjarbeels
2X3 iNatn Dakota
040 West CenbaJ
6.2D0
5.300
99S
■HMESS
(9iBSij
'ISgligBTiiBinigkW.
9^^H99Syg2]
miiiniiiipmQgi|i]
25.3
4 IS, ODD
17.Q8:
Wlri4^L-a
Mtg^fgBT.aiaggrM
SUels
400
9eu1!]
12.000
wmsm
.'rt.uarbesls
MKEgSlf!B?f3iiSlSf9
SS[19^^^I99HI
2B 1
651 ODD
17.48
Staiarbeste
North Dak«a
Oeo =3S! Central
43 500
41. son
25 0
5.D?1 000
1732
Sunarbetls
2X3 North Dakota
RicJtand
25.80D
21.400
25.9
554.D&0
15.37
SuGScbeets
2’X€ [•Joilh Dakota
DSO Conbined Ccjntes
403
400
■m
a020
91^1
SuDarbeslB
2X3 NcrftDakcss
DSD Scuhsas;
2&.203
21,800
■Ban
566,000
16,371
2003 North Dakoia
Stale Tola!
209.000
19999^0010
■KWT:!
9li^9Biiimi
■m
Union
1.50D
i99999DEO0
27.9
39,0DD
17.32
030 Nonhess;
1.60D
t.4DQ
27.9
39.DD0
ISE0ilS99999l9
^999B9BEi2]
4.500
34.7
156. DSD
WMB
fc8!?l?ti»f-3ggi
2X3 jOf^ccn
030 Scutheas:
5.30D
4.5Q0
34.7
165-022
9BS^
ISunarbeels
2008 Oreoon
5.800
331
1S5.000
16.34
[^3!It999999i
1.800
67.000
999
Liwni?- ..B
l.BOO
1.600
41.9
67.000
9BIS1
State Tcta^
i.eoo
i.eco
41.9
67.DDD
Sil^
SiJOarfae&ts
2003 !A‘vonir>3
1(^2029999991
9l9HI9im!S
8.100
23.-i
15S.3DD
17.46
S'joarfaeets
2X3 Wv'O'Tiim
-remcn;
1^9199191^*13
1.500
■Bin
32.2D0
9ra[ill
Event H7-1
Draft ER
230
Appendix D
7/28/2010
1440
CorrmKtty
El
HHIH
8
k
1
Hareestsd
rrcduKjyi
SuercsB
IBSH
(n«x&aftd3 cf Acres)
iThcasands ci Acres]
B9
fTliousandsafTons)
‘?erD=nt)
MB3
Allrl'iiS.j^lHi
e.aco
mam
BBBBI^SKuf
BKSSS
risked
3.1CD
■RW
BHHHHqS^S
S'joarfaeels
2’:-:-a
Minnescts
B^^^^^BBBnriTfil
1.500
flBH
S18DD
BEqI@
WMI
XlffRimSSH
BBHBBBBBBi^
4.30D
BEiH
■MBBIimm
WKE3SS
teSrfIsftJWSli
8,200
25.8
1&2.1D3
17.40
m^\
6,20B
22.3
1S2.5D0
17.00
■wi
AITtTir^cMB
HBBBBBEI3V!il9
^BBBBI^Sil!]
2o.4
652..0D0
16.30
wmm
Ye'vyw Mrdicirs
BBBBBBBBECn^l
3,100
21.5
55-.65r>
17.00
F-itjarbeets
201?.
Winnpecfs
D40 Cotnbinsd Ccunl’es
000
acD
tia
bbbbbbbsi
BBoil
Suaarbesis
2GC3
Minn^scts
D40 West Central
1ie.ES3
92.000
MBaa
BBSKESf^l
BKSI^
SvgartieEls
2203
Minnesota
SSSRggBBB^^^B
14.400
■USB
flB£i
IHBSfol'3319
1.400
Tm
M.IOD
BBSS]
■fctM
iTT-ni*
rRnVBBB^^^H
■BBBI^KS?!^
32.S00
25J2
S2'2.SDD
■BBS
■1^
StiiiftsaJHI^H
3!PraB^B^BBBH
■BHI^^^EIiTi^
3.200
BKaB
7-5.79D
HRRJflSSSl
sisizii^HHiitaBii
2.000
WKSE
BBBBK£s^
IKK]
■gsi
XjSBlMl
■Hll«!3ra:Will.llli«
3.503
3.400
25.6
&2.5DD
17.0D
Sugarbesls
2203
Minnssata
58.900
25.4
1.445.900
1r.50
imH^^HBBBB
BB^BB^^^^^
4D0
15.3
5.10D
17.8D
mi^
3.400
22.8
7€-.B0D
16.7D
■ii^j
f lfT!iE53SBBi
300
200
■rag
3.700
■BB
Syaaftieels
2!>:-a
D7Q ScuS-//E£t
4JOO
4,000
21.7
95.800
16.80
S-:ja3rbeEte
2K!a
Fitonescta
D9S Conbined Cis^cts
600
gdlll
25.5
15,300
16.56
Siioarbecte
2Q0a
fifinnesota
^B
399.000
Biti
BKBBe^^
■Kf@
S'jnarbeats
2023
Mcndns
□30 Combined Ccui«ss
6KK
6.900
34.9
171.900
16.32
Suaarbefels
2GD3
Montana
330 Nonhess;
6.K)0
8.9C0
24.0
175,900
16.32
2003
SiaHom
0.1DD
s.aoD
26.2
252.C'D0
15.01
2CC€
ArtTilScTi^^^^l
3.500
24.Q
92-.0D3
16.84
Ve'w/sr-^te
e fOD
e.CQD
25.9
155.200
15.96
□30 Gofftfained Count' a.<5
3 5D0
3.500
^■■BBI^gbSi
■BBB!
ISuaaftieets
20’02
Montana
D20 Scuti Cent-al
22.800
21.200
592.903
1B.B6I
Sugarbeels
20-ia
McnDna
inSESRBBBIBBB
2,000
28,2
55,300
i7.3ej
m^\
iB]iKr?rs^E!^^BBB
BBIi^H^BBtliTrn
^cdo
WME
BBBBBuli^
BBSS
Wiiilil
VP.fl^BBB^H
30.700
25-e
8Z3.DD0
17.271
ISgoarbe&ls
SOM
Nebraska
400
20.2
S.3DD
ILliJ
{dgrEESSa
SijIrSSBB
■■■■■■PIsTiin
17.300
B^
353.650
Kmll
Sgoartieeis
SC?
Nsbrasics
itirromBBBBi^B
1.100
M>£fj
27.300
S'j03rt)e&t5
2C03
Nebraska
^■Bi^^^Boniiin
2 ,eoo
BBqW
5146S
■ike
^Mfsarbesls
2303
Nebraska
4. TOO
22.7
92.103
16.34
Cjinarbeate
2003
Nebraska
TVTl >W
^^^^■BBS^TTitil
5.700
23.1
131.000
16.31
WBniTRc*
2,400
22.1
53.100
18.85
»ggl
mramTW^
3lD ConbinedCcuntes
700
700
■wia
15,190
KSES
■Kgg
■IliUMtilll^lBHBBi
41.103
K3DD
Bwaa
I/1.60D
3!PPBBBB^^^^B
ecD
BGS
fBBBBKSi^
BBXB
wpEi-ma
BBBBBHBEHTni
\m
B^
45.DD0
Bra^
iSuoarbests
2023
Nebraska
eoo
mtem
14.700
BBWrW
IS'Jiatbeels
2003
Nebraska
370 Scutr.vest
4.100
3,000
Mggj
75.555
KEGB
HSTEEISa
■f™
2S3eSSHi
37,300
BBBKsKiM
WMEm
■Kiii
E^ISESHIHHil^H
1.5QQ
43.0D0
BBQ^
SKEESSiI^^HHIHi
i.eoD
5?.?
43.0D0
BBbEB
■E@
SSnES^S
27.200
27.C03
26.7
725.000
BB3EE
Bstraisna*
SSSSiEHHHHH
58.300
25,6
^ l.^iiC'SO
17.78
■Kl
lifOTftRIM
QSISflHHHHHBi
40,400
26.1
BBBBU'i' ll'l'i'l
15.07
7023
Ncftn Datea
D30 Nonheas:
127 non
125.700
26.0
3281.000
17 83
S^SSSSIHHB^B
5.300
2i?
144.0DD
15 16
lEunartesls
.. 2003
NcrLh Dakcca
340 West Cent-5l
6.200
5,200
■mil
bgr.klfbM.L-M
■^1
16.nQD
B^Ei
BBBHBESE^
■bh
400
30.D
12.DD5
16.72
24.900
26.1
65T.DD0
17.46
■1^9
North nak!-i3
□50 EasiCerTtrai
43500
41.200
23.9
VKI ODD
17.32
BBSTfSHW
■SI
Ncrtn Dakota
21.iDD
25.9
554.000
16.37
S-l;03rt366lS
20-03
Ncrin Dakota
□so Combined Ccunfee
400
4Q0
Kay
12.0DD
amsi
E'u'caffaesis
2003
1‘jcrti Dakota
390 Scu& east
2&.200
21.300
28.0
5ec.CiD3
16.37.
Sunarfaeets
inaiagt.'Bgi
SSSIESSHHHIH
HHlHIHBlilini}
137.000
25.9
5-102.800
17.58
E-jnarbe-ls
2003
Ofs-arn
l!!!P3HHHH|lil
IBHHHBH^Si
1.400
27.9
39.0DD
■Bq^
S'josrtjests
2003
Oi^cn
330 Nonhess:
1.503
1,400
27.9
Sv.DOD
17.32
SUC3rt>6&tS
2003
Ore-xn
iSSitSSBBHHHHI
BHBBBESM
34.7
16.09
SgoarbeslB
2003
Di=aon
SSii&SISSSHHHH
MBBHHIBSSl
SSSBI^^^^
34.7
1fc.{}D0
15.00
MBiElitBSS
SS^I93MHi
1 l^^i^WB^^MB
bhhhhsg^
5.900
tan
■■■■ss
BB^
Hdl!.^!i'W
iSSISHHHHBli
bh^^b^^keds
t.ecD
41.9
67.000
15.61
IS-gaarbests
2 £! 0 a
k'Vashinolffii
lektibflBIBBBBB— B
BHHHIKlSiS
1,600
41.9
57,000
16.51
S-j'aatbects
HBBHHHEESl
1,800
41.9
HBBBIKySm
16.51
Bb Hem
5.300
BBBBBkB^
■KB
■■BBBiiSl^l
2003
-rsrmn:
1.500
1.500
20.1
BBBBHBESSn
16.DD
Event H7-1
Draft ER
231
Appendix D
7/28/2010
1441
mi[|^y
Plar.^ AB .“wposss
|Th9-JSSR3 Cf AtiSS)
Han.'esied
jThDUsands cf.“£f«)
V^-sfd
(Tons;
Frcductio^
(Thousands ofTons)
S'jcrcse
■Pemsn'.i
■l|i'iri'[ii')"Hlilirj! !,|||,| m
e.ecD
251.&0D
MffKBSSSSSII
lllllli^ii^[bi9Bnn;^H
5,500
27-G
14S,400
wwssm
wmmmsssm
25.000
24, S
515,&DD
17.561
S-josrtiests
1,100
.71.5
23.70-0
IIKIKtSilraSSBSH
300
mw
5,203
wmsml
ffib
KDS
14.3bb
17.11
HamiAWiUm
2,1Ctl
21.0
44.205
1728
IState Total
^.700
27.100
24.5
mumiiiiPipi^E^j^
i7.S6
MT»;i>l[>Flf?ggn!gW
f.'55B
5bi
2b4,C'00
■■iii?iTii'i||''l'lli'''!'il';il''lli
3.1 GO
34.2
105.030
16.27
I.3C0
3D.a
45.00D
14.63
llll"IT'''iTI!SSSfaRK«
2.2D0
2B.1
64.Q0D
17.86
S’-'oarbects
1111 ii'iiiihBingingM
■iiiii 1*0171 mT3:iiRST:i9B
403
4g'b'
■E^
14.0DD
TTTII
iSynartieEls
■n^teRiwmi
ID5I San Joao.-Ji Vof4v
lo-aC'D
16,200
31.S
5J7.DDD
BUS
iiiJ^SRiffSBfngiii
22,000
mEm
■>J.70D
22.S0D
WEE
359.0DQ
16.38
IRHIfHfiSIfiSfRfflll
■MKiOfA^irniiiiiHHi
40.000
39,100
t.4BS.600
16.13
WAl'IiiJilOTI
■BtMAciWSRTresaB
5GD
14.600
15.90
2.3d6
24.7
K-.eOD
15,00
M ii iiir»Biaaiii^
MaaB
&4DDD
■nmnHHHHHBHf
■■■itadBflTiltl
2S.5
37.200
14,80!
iiiKpaifinRrnicH
SOD
ns
13.700
■B^
HMcKMlitflinnHM
■■■■■■■nTnii?!
W,7i5a
302.650
15.31
Mms^iftRlI.UuW
10.400
■^lii
514.DOO
15.42
■■■■■■Rnii
7C0
24.4
17.100
15.72
■■■■■■KCTnn
3.C00
19.0
S'J.TOD
■m^
HMiSiKiriAlMiJliLWI
■IvfiBsnrnSSHHHHi
aoo
26.8
35.1QO
IKSOEI
Np<aKir>l»4k«
M IIIIIIWai.lf4.k^
O.3C0
2B.D
153.500
15.381
M II initrei 1 ' 1 1*111
■rifitilaBTSRtRSIWSIffleS
303
200
4.600
1060 =asT Central
ID.TOOl
B.S0Q
251 .300
iSuoariieets
2{I<I7 iColarado
[state Total
32,000
29:200
MCTW
765X106
HKSEQj
■KemiimiHi
2.CC0
W^M
67.000
■KS
iB.icOO
2$.8
4Di,tot)
l41l>hlcl-44iM
■Bib^llRRISTMH
B.7G0
3D.S
269.000
16.531
incise
3.20D
34.1
109.000
ifi.cwl
1.3DD
46.000
WPnrTR!^
1.400
1.400
34.3
43.000
1623
Ppi-Mf'Uja-*
n^iirs^ns^H
5tOT
sj
WO.ODO
15.88
effi
33.3
23,|!DD
Ts:??
31.800
35.e
1.125.0D0
16.41
1.3CD
45.000
iJerorrs
1Z7D3
12,500
34.S
431 .ODD
16501
■HiZinimrmH
e.ico
HIB
HHHBGbuISm
■nE)
wmi>M\m7mm
5TOT
33.2
1.331 .000
16.181
Bi.'>uirn±idllt
SdElaRini^H^BBI
■■■■■■iiliETSTiin
10.CD0
kh
iklil^iniBISRfflSnHB
105.000
104 OM
34,0
3.540.0DD
16.311
MS^IEEmH
22.7C0
35.S
312.000
15.051
■KSgiBBff—
HHHHBHISIiS
12, Sib
■Ea3
■■hqi
■rr^'iii iTi ■■
3l5bb
mm
HIIESS
■WTirrHiRRnBM
HHHHHEISlililil
1S7.000
34.4
5.745.000
■D^
IIHHHBflKEIiS
1.QG0
17 0.50
■EssatDiCRfm
^^hhhbiesi
11.CDD
HI
231QDC
M iiiiiiflignrw
SSoiSHIliHHil^H
cfib
■EiEI
ioissn'
mwmii
leBS"
—aiP
5? .ODD
iHiaiil
!3ffi«ffSB3i
5CC
iLQ23
l■KB6i!
HHHHHBBSSSl
15.300
327 .ODD
IMO
ait'!!li.|jJM
umiiiiiiiiiii^^^^
3.aCD
18.-t
Te.,DDD
kM
2 Q.e
K13.0DD
17.80
ISagartiaels
52.500
24.6
1.310.0DO
15.10
16.000
M7
335.000
17.90
20.500
2'> 1
453, DDO
1B.5D
3BSM!iH83
gfgQQIIIIIIimillllllll
le.Qoo
25.6
5D9.0DO
15.10
laCSiiB-SjSB
l2=.DjO
127.300
■paa
IHKgQi}
BWBfflRBOi
gISiSSiHHHBBHI
2,250
■IB
masai
HHHHHISiS
500
ns
11 ODD
■nn!
■BiiBiiinm
750
14 ODD
■ni]
I^I^IHIIIIII^^S^
3.500
■E33
T5.0DO
■BE
HHBHHKlIIiS
I.CCO
— gia
23.000
■I^SS
iS-iiaarbests
1.000
i.cao
■Kgil
20.DDD
2,0QD
■HB
43.000
■il^l
wmmmwm
•SQD
7.0DD
I^^H!
Sun^fteeb
SS9S5HHHHII
1^.000
1/a,0QD
23.4
3.4ft7.0l>0
1B.10
Huaarbsets
IQ,50D
mtaas
257 .-ODD
Bm
Event H7-1
Draft ER
232
Appendix D
7/28/2010
1442
CacT/nDiriy
Year
Pistted AH rt^tses
bBB
rTCducian
SucKSS
fTfcaisands of Acfss)
(Thousands of Tons]
{Psreen:}
P-*i ...
lasoa
B.QCD
25.4
251 .&0C
17.69
P»S5
wamm
|||| || 1 1 im^M—
0.5GD
27.G
14S.40D
17-40
■Hil!ISS?ffiRHBHMii
25.rinr
24.e
519.302
17.nB
Gct$hen
1^'
rinci
21.5
■Z’.7r>D
17.04
|eppF!!!!33*
LaiXTiie
300
20.7
5.200
17.72
i.^‘yc«iii>3
700
■ana
14.3D0
HbB
2.100
21.G
44.20Q
17.20
NffTigBnggsa
|| i^n ill—
23.700
27,100
21.5
SBd.OBB
17.5S
wmem
mir^nr'—i
""T;30'6'
“ Md
2!>5.1*L'U
iK^
S2nD
3. ICO
S4.7
iiHorci
16.27
i<irr«
1.300
1.300
K!iS
HHHjjH^ESnSM
KH
teJSBSSSH^a
■tMa
2.2GD
20.1
64 .ODD
17.63
2-ja3rt&5t5
2Cvi’
Califcfnia
D5 1 Conbin&a CcuntsS
400
4GD
14 .ODD
Stiiaarfaesis
IQQ?
Califcfnia
Dal San Joaoxn Va;:=v
15.300
16.200
31.3
537.030
15.72
S;j£]3rfceels
2<:C7
Caiifvfnia
41 0
Btinon
ia3s
Suaarbsels
2C07
CaliPsnia
DSD Scutr^m Caiifcmia
23.733
22.SDQ
■BM
B99^@
SuEiaitseeb
2007
California
State TolaS
40.000
39.100
37.3
MMWgiddninii
■IH&i
■PE^
nri'iii
eDD
29,2
14 .ODD
15.90
MSWtinssi^
W^M
2.300
24.7
55.933
16.00
im.
■■■■■■■nTRI
.3 700
M nr>.2
■E^Sj
mtss!*
1.4C0
■MS
■Ems
liSTRfinSCB
S&xr7/i:k
eco
1i.7Q0
16.281
bisSFinspsCll
ssE£aHi
|||■|||■||||||[|■■B]^^
2B.3
302.500
15.3ll
|S-jo^eets
2S7
Cdorada
D2Q NonheaEt
21.3DD
10.400
■■ES
[Syqaiteets
xm
Cclorart-j
■HHHBBKTiC!
7nn
24.4
1710.'’
■■S
I'lM'l' —
■■■■■■■EE1IS1
3.CDQ
1B.S
69.700
16.21
Hfel^
Washinoton
703
eco
Z6,a
15.100
15.08
-Euosrtests
2C'27
Ccbrsb3
3.300
■BHIil
2CC7
Cclorsbs
3DD
200
23.0
4.602
S-JOartesls
D20 Hast Ceniral
10.700
251.000
■i^l
Sunarbsets
Stale Total
32.000
29.200
26.2
7B5.OO0
15.48
Siiaa/tests
RRi {?!■■■■
2,000
67.000
■l^^l
Saaarbeeis
2Cv7
Idaho
Canyon
11.100
10165
36.a
401.000
15.60
S-jQarbests
1'207
Idaho
6.7CD
BWild
13.53
S'joariiE'els
2'j27
Idaho
3.200
34.1
105.000
16.D4
Suoarbppls
2'>"7
Idaho
(tVKHifjrfllHBHMIHi
1.300
■^Q
■■iSE0}i
Sjoarfaecls
2£i57
Idaho
□70 Combined Ccuntes
1.400
1,400
34.3
4S.000
1623
S-qaarbeets
2C*j7
Idaho
D70 Scufrw&st
2&.DOO
27.500
34.2
MO.I300
15.80,
Sjoarfaests
W.7
Idaho
S6b
HEB
2DJ)D3
■i^l
wn.WiiHJW
Idaho
HBHHHKSEnSl
31.aOQ
35.0
1.125.000
13.41
KfpFTr^cil
wmuri
Idaho
1.300
34.e
45 000
15.96;
mssR
Idaho
^^bsmbbertgh
12.500
■KW
■■■■SI#]
■BS
kpf^JHisca
Idaho
mmmamBSisi
9.100
keh
197,DDD
■nm
h¥i»r-iifra5EB
Idaho
41.&00
S5.2
1.3'9t.033
daho
^^^^^^BEKVTiTil
1D.DD0
wlddd
IS^joarteels
2£>2T
Idaho
DSO ScuLn CentTil
105.000
104. ODD
KI9
■■nsi
wrn?»r!3EB
Idaho
22.700
33.2
612000
15.851
mHHH
HHHHHIBiES
12.S00
Begs
■KB
iS^joarbiits
2C07
Idaho
33,500
53.6
1.225.03D
15.811
staaiMBH
SSSESSHHMIi
MBHW^EI33
167.000
31.4
5745000
ISAs!
'.licrtoan
HHHHBHKliliS
17.00D
■■ss
IBBffrosBi
■e^
BIESMi
SSSHIIHBHHI
HHHHHXEiS
■■■HlS
MtlWI
■■■■^^^
■IBI
S'JoartSEls
2X7
ii>1ichaan
coo
■R<£]
10.033
S^jparbeels
•Itchoan
nHiiiimi^^iig
2.aGD
20.4
57.D0Q
1S.10I
USSISHHi
IS3i!SSHHHiB^Hi
SCO
ns
11.030
^rasi]
■^i
15.300
HB
327.D00
■m
IBHIHHIHB^S}
■EB
70,030
■IlSSi
14.700
2Q.6
302.000
If.BD
■l^i
l2[|2E5ZHIIHi
(SIlSSHIIIIHHHHIi
S2.e0D
■jgS
ISSHBli
SSSSSlHHHHHHi
HiHHKIDII]3
le.coD
. 24.7
.30.4 030
17.801
nss3
20 500
■hbiki^^ei
Suaarbeeis
'uscota
20.0DD
10.900
■EIS
5K.003
Suaarbesis
2CC=7
'.liWqan
DcO EasiCemral
12=,0jD
127.300
23.9
3.D4C-..DD0
1S.1D
iBTOitEgM
■m
SlSSnHHHIliHHii
2.250
2Q.0
45.030
E'jQarbeelB
■l@9
[ffiSHHHHHHHIi
etio
22.0
ii.nnr.
Bn
£'jc3fbe“t5
"50
■lEB
i4.nr<ri
—Bil
Syqartiests
2Q01
MicJrdan
D20 South Gentrsi
3.600
3.500
20.0
70.DDD
17.10
S-jparbeets
'.fichdan
ISSIBHHHHHHi
jllllllBIIIIIIIIIIIIIB^II^^
1.QQD
23.0
23.000
1S.30
BEBBiBrlS-Mga'
1.0(K5
1.C0D
20.0
23.00D
1S.4D
2.000
21.5
4^nnii
iBsn
mss&
'.licJxYisn
DQB Canbin?-d r/slrics
£03
4Dfl
17.5
7.0DD
17.00
Mishiaan
State Total
150.0IH}
14S.QD0
■EiQ
■■■ES113ISI3
■HEEI
BEiSl
Minnescts
114103
10.900
■■■■^Qg^
17.30;
Event H7-1
□raft ER
233
Appendix D
7/28/2010
1443
B
Rffiied fiS rutposes
Harvested
BM
.rroducsiiy!
Sucf'-ss
iThKrsanK of A^s)
fThcusands cf Aj:jr=3)
Wm
[Thousands c/f Tons)
^Percsnt)
e.SGO
■KaB
llllllllllllllllll^^
■HBH
^VSORH
S.gCO
■Si3
PPPPIIQgS]^
fcjKtfeliiSaatJM
?f>flfin
25.000
24.8
616.&00
17.5B
?,ti03fbe£ts
^RSRSnSH
^mumgigiiiiii^ji^
1.100
^ES
23..7D0
17.04
S’jgarh^ts
KSSl
WSSSw^^B
3GD
2D.7
5.2D3
17.72
ks^ratai
tiy^sssisH
rillllllHHH^£13
TaO
14.3SS
17.11
BfJ^Til!33CW
»'li!iM
itWOTm
2.100
■EOS
■PPPPPES^^
2 S.roo
27,100
■BSl
6”5tJu
ismi
■WM
^^^■■■■KCTin
3.100
WBSBi
■ISIE
PIEPPHH^^
KU
2.2CQ
20.1
KBHKM
■■s
ssSBiliRtSI
mim
■itP^i«dmRf!5MMsnnsB
40D
4C0
14,Oi5j
leppsiiniSE*
■lilillidtliRltWUUilVrKm
16.300
51.3
K7.00D
15.72
22.600
4i C
955.0DD
1g.38
■iisia
?3 7iK>
22,Q0D
41.6
855.000
IfiTft
40 DOC
33.100
1.465.050
■KSll
biW®W43C-ll
2'i:'G7
•(atiTra<s^rt
PPPPPPPPjjg^
■1^
■■■■■■■■■fSliXM
■■B
S‘ja3rbe£js
2527
■gEB
■ISM
f-Maarbsats
2*»"
■iISfEflBHHHBHBHi
3700
32.7
E4.DD0
15.32'
SyffarbssU
2K7
1.4CI3
37.2D.1
■EHij
Huparbegts
2017
Cclorsda
■■■■■■■nrTSii
200
1^^
1S.7DD
S-uoarbesis
20*27
Cclorsda
10,700
2B.2
302.800
15.31
3^-garbeEls
2K7
Ccloraba
|D30 Nonheast
21.300
10.400
25.5
514,000
15A2
te0ftKU>l44L-B
700
34.A
i^rns^ca
■CESS
.7.3DD
3.CC0
10.0
■■19
bSRKRasra
K\'as?iinal~n
700
600
Mara
15.100
■m
K»r.ii=l»*^44t-a
o.acD
Msnw
■iBiS
►ajRWi.Wdta
2>>07
•RRJvCSi^B
■tiMibcn.'fjnsiiRninHv
300
2D0
2315
16.25:
*!t!fiarbaEl5
“■'>17
CdoraS's
IDgD =asT Cgrtral
in -nr*
e.aon
■1^1^
Simaitteets
2Qfl7
32.000
2S;2flO
KS
765.000
WJr>K7i*te3Pa
££li9^B
^■■■■■KVTiin
:.0G0
33.=
67.000
15.50
|£9r.Wi444t-rf
10.600
■fetEl
■MWIliEQ
HiSm'
2!>27
Idaho
0,700
■BiS
WKKKttESM
HK^^:
Sunarbeets
2*537
Idaho
rS995I^PB^H^HHi
^■■■■■Kcrn
3.200
KH
HHHHKEES^
■KEES
1.300
KB
4-5.005
Km
Sygarbeeis
1007
Idaho
l(Uii«i4J.iif(j.r*h!n.i(k!.-«
1.400
1.400
ttM
pppEHESEmI
KSI
SnSGESSi
2C07
Idaho
1070 Soutr-v/fest
23.000
sjaff
54.2
^a.DDS
^■iis]
Idaho
eoD
■SE]
BHHBHiimum
Kssa
2007
Idaho
K*!
^■n
Spoarfeests
:i307
Idaho
BSBBiD^
45000
Km
JOTFR.THCa
12,500
EHHKEu^I
Km
1037'
SEIOBH
'■BERIRHHHHHBB
BTiOT
3D.;
1ST,D0D
15.40
mintrmm
2057
Idaho
41.6&Q
33.2
TmToH
i6.id
tBTrFTifraG*
Idaho
lO.QOD
34.1
341.000
leiQ
Txmmm
man ?cn&. c^nw
1D5.OD0
1IW.OOO
34.0
2 540.000
15.31
kiBikli>!44H
Mi/iM
fSiniTH^I
■■■■■BeEItin
22.700
■KSiSI
K&ima
■Fggj
lISiBMHi
MIHHlMK&OiS
12,800
■aaa
■■■■ESH
■lEES
IQG7
Idaho
SSiBSSHHHHHIii
35,500
■■Ml
■RTIFl
ftnm—
1B7.QM
34.4
5.745.0D0
16,131
wss!mm
K^SESSHi
BHHHBBBCGS3
icon
■K
17 055
Km
■l^gl
[lISiSSBB
11.DOO
■ED
231030
■KQ
(JSSSEESHli
S3S9HHHHHH
H±I
16.6S5
2BSES9HHHBHH
2.5CD
20.4
57.000
IB.IOi
I■l^^
;
ISS3SSSHHHHHH
500
2?.0
1LDD0
1710
15.300
H^9
PEHIEPgjll^
KHl
EfBHPHSMI
z^ssEsiim
ehbhhiheees
a.eco
10.4
TO.ODD
IE-60
taSBrna'll-l
■i^a
iSIMBHHHHHB
14.;0a
MgilH
301.000
2007
Mich-aan
o2.e0D
24.S
1.310.003
1B.10
iFTifiarbesls
■51^37
16.000
24.7
305.-003
17.80
:5-5ifi3rbesls
70"7
Midi'opn
20,500
22.1
451 000
IE 50
SESISHHIHHIi
19,900
25.6
5D?,0DD
15.10
iSSSSESHI
IrijifcgBlggBBT— —
122.00D
127,300
3.6
2-043.003
1B.1G
■Bsa
iZ^IEEliflil
SDISIBHHiHHIi
2.250
HiQ
45.005
■Oil
jjBEgigai
ESSSBSHI
5cn
22.0
11.000
17.60
750
14.003
:Km
lSlS3Scl!i!Hli
liElt'iWRifigBgMBM
iimpppimQ^i^
3,500
2D.G
TG.OOD
17.10
200?
[S^^^lifllli
23.C
23.D0D
15.30
SuoafbeEls
I'X*?
Mi'chioao
ID50 Conbin&d Ccunl--=5;
1.000
1.GQD
^^0
23.000
■IliSBSi
E-jaafbsrts
'037
Ml£?.:i33n
2.000
21.6
43.DD3
15.30
F'inarbeste
2017
l.lichoan
□SB Combiriad CisIriKs
5QD
400
17.5
7.000
i7.cn
Sunarbeets
20m
P.lichiqan
Stata Total
1 33.000
14S.000
23.4
3.4B7.000
18.10
S-jparbeels
2017
Mi'nnescls
Ee:l;=f
pPHlHIiHSE^
10.500
24.5
267 .-ODD
17.30
Event H7-1
Draft ER
234
Appendix D
7/28/2010
1444
Sate
Counr/
Placed A8 i^rposK
{Tto-ssnjfe c? Ac?^)
Hari.'estsd
jThCiisands of Acres)
Sucvse
i'Percent)
teSSStSSEH
—
0.900
25.4
251.800
17.60
URitBtSli
hi| 1 1 1 l'|i
3.500
IKQ
145,403
WtKW
ki^
25,000
24.a
518-50D
^i‘jiii.bi
1.10Q
WBM
73.700
17.04
sOD
300
■giH
6.203
^EiB:
|iSF«'PTl!BSBi
■RKi^
—
Ptels
2 L 20 a
7UD
20.4
14.300
17.11
kiSflfeilrtsiai:*
21GD
21.0
44.200
1729
■tti
yjssssi*Mi
PiUl'
27,100
24.5
e&t.ODD
17^6
" tiiJS'
bU.d
j:b4-.Dul>
16.61
3 100
■■h
HHSSa
MM
•ttl rtiSssf^^BI
l.’CO
30.3
4:-.0D3
WBSR!S3C«
lli^
3.2C0
MiMI
■■■■HH
Itfii
iS-vaartjBsts
2C'j7
CailfcmJa
Ddl Conbinsd Count es
403
400
Hn
14.0DD
■g^
Gaiifania
D5 1 San Joasr^-i Vs^>sv
16.350
i^.acD
31.3
5}T.C'0D
... .mZ2
■I^Sii
California
22.50D
mBm
'EEEHHIIIIIIIII^r^
MI^Mi
i2fflnT.SS3^
f IlftTi
Califr/nia
DBQ Sciifeem Calllcmia
23.700
22.5DD
41.Q
?5v,DDD
15.38
MKi
W>li.l..HMi
Slate Tola)
46.000
39.100
■^B
■■■Bftlii-iiliilil
■m
■■■■■■■■■E7119
SCO
20.2
14,000
15.60
KSi5?i?i!K3C«
HSCOl
2.3C0
24.7
fd.0DD
15,00
E’jaarbesls
Cdcrado
3.7Ca
727
MODH
ni^
SaaartjsBls
7'!>37
Ccictrari-i
1.4C0
mm
37.200
^■EES
Suoatfcests
aoo
■SB
12.7DQ
■B
SSBSaH
2S.3
3D2.5DD
Suaarfaetls
Colorado
a^DI-Jobheast
21,300
10.400
2b.=-
514.0DD
15.42
S'joarfaeets
CclorsdD
7CD
17 inr-
15.72
3 COO
10.Q
59.700
15.21
S-Joarbests
2'>j7
Colorado
COO
mm
16.100
■USE!
Sunarbesis
iit-7
Colorado
a,3C0
■Kram
■■■■■[i^^iS
■■Ei
Colorado
DcD Combined Ccwites
300
2CD
■■■■{HElQifl
■KP
Crlnrsdo
DcD East Cemral
in7{>o
0.0CD
mmts^
.?4!nr'r>
2Qa7
Colorado
Stale Total
32.000
2920D
■BIS
7B5.000
S'jgartesls
2037
Id^o
2.QCD
33.S
67.000
KSl7Rnt[44l.-«
Idaho
ifi.SDD
■KfiW
4D1.CID0
mts^
31SrrSBMHHBBBI
■■■■■■■Eiintn
S.'lllfi
MilH
■KggS
K>»l
SSSHH
3.2GD
■gw
109.000
^ESIS
Wte.rr;S,c«
MM
■■■■^KFTilfl
i?nc!
45,000
D70 Conbmed Countes
1.403
1.40Q
34.3
45.000
1623
2Cv7
Idaho
D70 Sculnv/ert
27.500
S4.3
840.000
15.S0
KW‘Mf‘1441*
mmmi
Idaho
eco
11^
■■■■IllgliggJ
Mm
Idaho
sieoD
■■■RK^Ii^
MIEEII
WSAIi.Tlil*
■i^in
Idaho
1.300
■E3S
45DD0
■Effl
tn^.'frTi.iaL-a
MWW
Idaho
12,500
54.5
431.DC0
■IS!
E<jaafbdBis
Idaho
fl.lDO
■EiH
iiiHa
Mim
taWT.UTRM
mmi
Minidoka
42303
4T555
33.2
1.351,000
16.10
2007
1D.C0O
34 1
341.030
1620
13!-.030
1W.CD0
34.n
2.M0.0DD
16.31
IdWSSWSli
Mra
rRnMM
22700
■E^
S12.00D
Mm
fatr»hrt»T^r}i.-w
35.4
453.000
IS.SSI
2C07
Idaho
‘~ 55355
■~Se
i 265 boo
l5.Pll
SunarbMts
2Q07
Idaho
■■■■■■EIsliMS
167,000
■ETEl
■KUS
■^1
1.DQ0
■BEE!
■■■■■li!^
■i@a
11.000
21.1
232.003
1B.101
IBiSM
cdo
20.Q
IQ.QOO
iT.fifil
Sunarbe&ts
2037
Michasn
15S3ES9HHBMMB
2900
mn
57.DD0
■■■Q
S'.fl3fbp61S
:f?r
Micrr'aan
500
■■■i]
S-i/aaflieete
2C-07
Michoan
15.900
MSB
327.000
■■ni]
Sudarbeass
io:-7
Michdan
3.8C0
18.4
70,000
1B.0D
QQSS^QliiH
■■■I^BEISiS
14,700
20.e
303,000
iT.eo
(s^u^iQiiiimii
Q[2S33IIHHBBBIi
■■i^l^^SlS
52.CDQ
24.8
T.31O.QD0
15.10
ISffSff»t5RMi
SS3SS9HHHHMH
■EH
385-000
^^9
[KBSSSSI^B
■■■■■31113
Msn
■■■■■^•^
BS^
2037
Uic^aan
ie.eoD
SuaaibeEts
Michdan
DcD £as: Central
12S.0X>
127.300
■rm
MBSBI
[aO^inili
ggSgJJHHMBBHIi
■■■BBESS
2,2c0
M»liH
45,000
■mm
2037
Michban
5C0
■SEI
11.000
MMB
iS^SESflHIi
SROnWIHlBBB^
i■^■■■i^^]
7£D
15.7
i4.ck:'D
1720^
2C’27
'.lici'oan
030 South Central
3.5D0
3,500
2D.Q
73,000
17.10!
203?
Miahaan
1.DCQ
liffi
22.030
Euaarbasts
•.lichoan
D^O Cor^insd CctTites
1.003
I.COO
MMil
23.000
■l^^l
Siioarfcesls
Llicn'oan
D50 EcuCtsas;
2.0D3
2.000
42.000
■■Eil
■IKI
503
4Q0
IH
7..003
17.9D
■Hi
State Total
15Q.OOO
149.000
m
■■■■ii^li<l
18.10
iESiSSSH
10.900
257.0DD
17.30
Event H7-1
Dratt ER
235
Appendix D
7/28/2010
1445
Corr/TiMtiy
YE5f
State
uounty
Pisi3d Al j^tsposes
{Thoassntfe d Acras)
Harvested
{Thousands of .-eras)
r:m
{Tons)
rn;duc?:iai
(Thousands erf ions)
Sutr^e
{Percent)
raiBSIiSEBl*
[I'nBSISMi
lllsnMBBBHBBi
51.201:
2 i.e
1.1K.4Dl
17.10
ixiRinssaMi
38.e0C
20.-t
747.40D
1B.90
XHniRRSniBMHHHi
■■■■■■KCTTSI
5.=cj:
;iHS
IBBBBHBB]^^
'HB^I
S-.inarbeels
yinnesfib?
^■■■■^pninTi
45.700
22°
5..We.OD3
15.901
SynartsBEris
2007
Minnescta
47.700
Mgg
■HOQi]
S-jqartieets
■KBS
'ARiiife^ilSHii
STEtMBIHBBBHB
99.300
ibmhb^^s^
■is^j
Sypatbeets
20"
Minnescta
□ ID Conbinsd Ccw:«
1.703
i.eoij
25.4
42.6DD
17.60
^5rinaffaeeis
?C07
t.1inne=ct=
DlDNanhn'eSi
302.S3S
299.000
25.t
T.D5I.50S
1E.0D
P.-tnarfasels
2£0?
t.tinnescts
i33BBHHE!!IS!]D
26.0
TM.TDD
IdXQ
fc^FIi!T33^
Grant
lo.scm
10.200
16.8
2D130D
16.90
wmmi
2.300
1B.9
43.500
17X0
wmmi
Z6CQ
28.:
55.3DQ
16.40
■BStE
)*imina4rt^J
5 ten
772
13'-.5S0
16.50
ISynafbesls
2S7
Minnercta
25.5
155.30D
16.50
MSgga
l|i|i i|
b^hhbbhd
20.3
132.900
17XD
Syaaffaeete
20JI
UinnEEcta
‘Mkn
63.603
49.500
20.'
594.900
17.80
Suaafbeels
2007
Minnescta
S'si-cv/ N^iicire
4J03
4.000
27.0
110.400
16X0
-•^inarbeste
2007
Minnsrota
D-Q Combined Ccuntss
mw
900
^■■■■■liDIS
■■Bl
Ssiaarbseis
2'jC7
MinnescLi
D4DWE:-lCpn«t
11* inr-
117.700
^BBBSESSS
■HEi
Syaarbseis
2C-27
WinnEECls
14,400
WHiK'fUTSStS
2300
hb
Syo3fbE=ls
Minnescta
sTSfNICBBIBHHB
35.300
BI^E
IBBBBKES^Sl
■IKI
Synarbeete
MrnnEScta
sfnsnBBBlBBHi
2,100
BI^S
■BBBMESO!^
■■n
-'?-:;narbppl<i
Uinnsicta
2.500
24.1
dl3D0
16XDI
Syoarbcsta
Minnescta
DSD Conbinsrf Ccuntea
iflOD
2.000
■BH
54.700
■KES
■li^
oB.eOD
27.0
1.5=2.700
BBS
■BHHiHHnnnTo
4.eoo
BIS
IBBBBfli^B^
BBiSi}
.=--)nart)BEls
2'rrC7
MinnescU
370 Combined Count es
_. . 50C
SOD
2DI
1D.DD0
16X0
S'jcarbselB
2C€7
Minnescts
D70 Scutr.wEjt
5. ICO
26.4
134 ..500
16fi0
SyoartJEEis
S>27
Uinneacta
398 Combined Oistrica
6DD
600
2E.C
1C.B00
16DD
WmMi
Slate Total
486.0D&
481.000
■BE]
[— Iweirlililil
ISyasrbEEis
2CC-7
btcntana
■ EStf
bibbibis^^
IjJynarbssls
:co7
Mcntana
13.840
■ESI
^■BBi^BI^I
■IBEl
gPFli^qi
fiSSHSEBHHi
i.BSr-
1.620
^■BBBB!9]S3
SyaarttEeU
£Cv?
Mcntana
330Nor.heas:
15.190
18.130
■■■■ESS^
IBESiS
S-^jaarbeeis
2K7
Montana
9.579
■•IXi
■■m
Syoaitieels
Mcnbna
^ SSB
■bbbhb^e^
ili — m
3 320
27.$
62.200
15X7
2C*;7
Mcntana
7.430
22.6
17CvDDD
15.04
IS'joatbeets
2007
fitcntana
32D Combined Count es
189
180
31.7
5.7D0
16.00
BffEEmai
24.393
ii.iSfi
i5.5
614.5D0
15.71
HHssfii
556
25.5
15.800
i?.5i
isnUi-'i-yfn
2007
Montana
1.780
■ESS
41.D30
■■s
2.4B5
2.310
25.7
55.300
■iSSI
Soaarbsets
2007
Montana
390 Scuineast
4.920
4,740
24.9
117.600
15.68
Suoartieets
Montana
47,000
24.7
l.tGt.Cte
<6.67
Suoaitests
2iS7
Nebraika
16.900
474.30D
17.18
J^tmarteels
2C07
‘lebraika
SliitS'Si&^MIIIIIIHII
1800
23.8
43.100
16.80
Syoafbests
2£^37
fiEbtaska
€C0
■uns
11,800
w>PniiTyff»
■1^9
■■HBHHEEEEl
3.100
■BB
73,503
■BXS
■^a
[jOS^ESSHBi
HHHMHMEEili]
4.900
■■■BBQK^l
■iffil
■E^
3^IH3MKSES1
glSOD
— gii
^■BBBE^EESI'
—rni
■MHBHIESiSI
2.400
flBBUBB^^l
■B
IS'joarbEBts
Nebraska
500
26 2
13.100
15.76
ISyqarijeEtS
.- 3>:-7|
l-tebrsEka
010 Combr.ed Caunt«s
503
5Q0
21.4
1Q.700
17.31
42.00D
40,200
236
643,500
16.81
■iSI
[iiSSSSSBH
im3BMIHEBi3
2.5CQ
22.2
55.400
15.51
tKSM
1.300
B^S
SO 200
■nsni
3ISMHB^^^EI13
200
S.6D0
■■as
■1^3
ISSEBSSBIi
370 Scutnv/Est
5.600
4.100
22.8
6Z5D0
15.87
■m
r'in'ri"'iffni^^B^^—
44.300
23.5
t.{W{.0D0
16.52
blWt>i!r»«'UKCTi'
■Bggj
BBEBi
[SISSSMHBMHIi
4,000
21.0
W.0D0
1&.Q7
■■EassEa
^■^SEI
[JRTSRH’SBB
310 NsrJii\' 2 sl
4 inn
4.CC0
■BIO
M.DDD
30.300
25.5
TS^.POO
■■Bfil
!gHi'lii'»H'!SM'
78.200
22.6
t.76TX'DD
15X5
■■■■KSlLiSl'
43.100
^5.*
*-.O*.4.Q0O
is.ie
isajirit444?W
■Si
liSpti'niiSBi
154.Q0Q
151,900
23.8
3.5:5.000
1S.17
3BHBHKES1S!
1D.4DD
.''*!• 7
257.DDD
15.80
■ES3
im/aiBW
3-0 West Central
10 sm
10.400
24.7
257 ono
15.66
■i^
BBralSRIiSM
3B^3MHElIIiS
23.800
22.5
535.DD0
17.46
■ISI
■icilh D3k«a
^^^■bbbbih
■■■(■^■EliS
300
26.7
B.DD0
16.53
trfWitcfUliSilBi
iSUBIHHHB
■iBBiili^^£I3
2fl,eDD
24.1
641. ODO
17.66
HR^i'
HfsssisrsfB:
320 East Cerufal
52.303
50.700
23.'£
5.i54.r>Dri
17.56
Event H7-1
Draft ER
236
Appendix D
7/28/2010
1446
B
S73tS
County
Pitted ^ l^tises
{ITtaussn:^ cf toes)
Hanesled
pTiousands c-f Ao^sJ
Y^sid
iions)
rraducticn
(Thousands of Tons)
Suarcse
■;?€rcsn*.>
iSygatbssls
.IDJ?
U^nescts.
51,200
21.6
1.lCe-,40D
17-1Q
Mssa
36,500
HS
SlfrRf!BSE®ill
■■■■■■HilTiin
5.5G0
■ni!]
RRIKTHUS^ta
45.700
HHHHEISSSSS
■Cl^
IS'Joarbeels
Minnescu
47.700
1.150,403
WtESB
is(n::Tc!t>i44<ta
WtmKKBs^sm
■Hgil
S'jnaitaeets
2Cv7
Minnescls
D 1 0 Conbined Count es
1.700
i.eoo
25.4
4:-.6DD
17.0D
2--inafbe£t5
2''27
'.linnesots
DIO Nanhirest
an? 5D0
2e?,ooo
.2.3,3
7. 051. BOD
15.00
H.yoarbests
2537
Mlnnescts
ChiDDSr/a
30.6DD
25,0
704.703
16.20
S-iaaftssls
2C-07
Minnascts
GfS-'ii
10.300
201300
16.00
S-jaarbefite
2>37
Uinnescta
■■■■■■EFtii!
2.3QD
■n
43-500
17X0
Sucarbeets
2'jG7
Minnescts
26.3
&s,3D0
1&.40
S^jaaibsEts
2C57
Winnescts
istavsns
5.I0J
SBBHjjjjjj^^
27.2
13= .SOD
1550
6. ICQ
.25.,5
155.30D
15.50
6.400
2D.a
132.&DD
17.20
BaRfflSfiSS*
^■KBSn
40,500
■BBl
SW.eDD
17.B0
Sunarbests
2v2?
Minnescta
Veiicw Mscicirs
jHIHIIIIIIIIIIHIIII^^
27.5
110.400
16X0
5;rinarfaeEt5
2'>:'7
Minnescta
D40 Canbined Count es
603
600
MgHB
21.100
■KBH
?t!nafi>6Els
7V~
Minnescts
□40 West Central
11-5 15.3
117.700
27 5
2 65-1703
17.00
ByaarfaSEls
2C57
l.finnsscta
IISSISliSHHHIIIilH
14.400
26.3
37B.OD3
16.30
S-unartieets
2537
Minnescts
2.3CQ
27.0
62.DDD
16.00
■■■■■KiEniil
36.390
27.4
e6$,£D0
15-00
SyoartifiBls
2537
Minnescts
■■■■■■■STni
2.100
20.Q
KJ.ODD
15.50
Suoarbeete
2'307
Minne'cb
2.500
24.1
^0.3^JC•
16.20
Suoarbeels
253?
Minnescts
050 Conbined Ccuntes
2.QQD
27.4
54.7-00
15.00
SuaafbeeK
2C57
Minnescts
□SO Central
58,600
37,0
1.531700
15.00
BSl!S!I!!33gi
MetiSitei
ftfitlft-ccd
4.600
4.600
27.1
124.503
15.70
2307
Minnescts
D7D Conbined Count es
50D
cOD
20.0
10.003
1BXQ
2537
Minnescts
□70 Hciitnvjasf
5.10D
6. ICO
■EiS
134.500
■ngU!
iSyoarteBts
2307
Minnescts
609
ecD
2E,a
15.800
16.DDI
ISugarbeets
2(107
Minnesota
(State ToUl
466.000
KQ
■■EESiMil
mfmi
■SB
53.500
■■HIS!
XBitSTTHHfl
13.&4D
■BEI
■mEj
■BiWJ
1030 Conbined Ccunt'es
1.639
1.020
41BDD
imaml
S-joartieels
2C07
Montana
1030 Nonheas:
11169
18.130
23.6
427.&D0
15,05:
Syflartoects
Montana
0,570
26.C
S7355I
15.40!
Syaarbeets
2007
Mcntsna
^■■■■■oETnn
3.530
Msia
bhhhksissi
■KSBai
2C07
Montana
3 320
IBS
07700
■K^l
Sunarbee-1&
2007
Mcntana
7,430
220
170.000
15.04!
SuoarbeBls
20v7
Mcntana
1030 Combined Count'es
180
180
, 35.7
5.709
16.0flj
kBT.WilU^Wi
Mcntana
(libiiKnnTirnsmBBi
24.360
24.130
■iSSl
Montana
650
16.690
■B^
■1^
iTsa
41DD9
■niiS
L^onarbesfe
2C07
Mcntana
IDSO ConbLned Ccimt'e-s
2.40D
2310
25,7
55.300
. ... 15J3I
ISuaaibeels
2007
Mcnbna
1090 Scutneas*
4.029
4,740
■Kgl
|||^■■■C9BSSI
■m
m^mi
i?.A6d
■Hnq
■■■HQKI
■KQ^
fri'i 1 ^
1 1 11 III r—
10000
■KEW3
HHHHKBIE&SI
[SSScSSMi
5iS'SSB9HiHHIH
IHHH^HEIiEI
recB
■1^
■■SEni
5515531
li95i^Hllill^HIIIHH
eoo
■ns]
■K31E
[Z51IS13BH
I35SSHHHHHHi
HHHHHHSiS
3.100
Tfi.SDD
■BSB
(SSIcSSli
ISSZSIHHHIi^H
4;06o
22.e
111.700
15.63
K5H
taangaaPn^B^^— i
ft.cfifl
55,1
iM-,fef)5
15.S8
SyaatbSEts
2-337
llabraska
2,400
23 0
55.203
13.54
2C07
fcn
■nis
1.3.109
157fl
S'joarbagis
TOO"
l-tetsi^ska
ID to Conbined Count as
500
500
21.4
10,700
17.31
SyoarbeEls
■■■’2057
r^tebrasics
iDIfl Nonhnesl
41009
40,200
&45.500
Syoarbeeis
[■tebraska
2,500
212
55.400
15.51!
■SSi
QRgSBI
1.3GD
mesa
■■n
F-r;oart)eEt5
2C’j7
300
15.17i
Syoartasts
2'X7
I'tebrasks
|D70 SouhWBSt
5.50D
4,100
msaa
02.500
■^5
Suaartaets
2007
tjebraska
istate Total
47.500
44.300
23.5
1.041.000
16.52
Syoarbafels
2307
'jorth Dakc3
IQESEBHHBHHIi
■IHHHBQirg]
4.000
■Hlil
B4.D0D
■■s
2207
4.1DD
mtm
2007
[TOaiiTfi
iisnnsiaRRnHBii^B
■IK
2307
Mcitn Dakc^a
IPecnbtna
7&.1DD
210
1.751.DDD
. 15X51
43.100
23.3
■m
S'jnarbscls
2007
Ncfbi Dakcca
ID30 Nonheas:
154 -QOD
151.000
23,e
3.555.D0D
1-5.17
Fnnafbsets
2007
Nonh Dakcra
HHUHKnSilD
24.7
257.090
1S.80
SitnarbEEls
2007
'•tcrtn Dakca
iD^OWestCent^
19.5DD
10.400
24.7
257X-SD
15.60
Suasrbeete
2307
t'lcrn Dak<?3
migd^i^
23,300
22.5
5S5.0D3
17.46
2307
4ca*t Dakota
IgSBHIHm
28.7
^ESs^Si
2C07
■'Icilji Dakcca
rrail)
24,1
HHH^ESOI^S
H^i
20O>7
Mens Dakota
beo East Central
5130D
23.4
i^f HtaiAk!
Event H7-1
Draft ER
237
Appendix D
7/28/2010
1447
mm
P^iBt) AH naposes
Harveslad
jj^M
SucresE
wOUj../
{Thsjssjvds c? Acres)
{Thouands of Aoras)
iPercent)
51.200
■BS
■■Bi!
P4SI«P!Ji155C*
36.000
20.4
747.400
1B.90
IS-joarbests
2*-v7 iMinnescta
5.500
23.C
151.5DD
17.80
'Syaarbests
Z']"'? Iwinnescta
■■■■■BFTXeTS!
•sn.inn
22.e
1.045.000
IB.fiO
HHHHHE13E11?I
47.700
24.3
!.l5v.40:«
■IIIBQSI
00.800
25.e
1553.400
tA RiTiSSffHHBI
iiriN^nfffsiwsfnsB
1.700
l.flCD
25.4
4D.SDD
17.90
OintlanhiwK;
3D2.53D
203.000
23.6
7.055.500
1b.DD
30.600
2.4.0
754 .TOO
15.20
(3ra!®5C«
■mnagsHi
Srar.l
1Q.3(E3
1D.2Q0
io.a
2D13D0
15.00
MSsamaggM
2.300
10.§
43,500
17.20
kgsBiaigi
r—i
HHHHHHEEDSl
2 ,eco
28.3
&i.300
16.40
Suoattissls
■BtSSiimfinsfMH
5.100
27.2
135.5D0
16.60
S'doafbests
2"€=7 IMinnescta
B.ion
255
155-.SOO
16,50
■ll0SSi(X!!!f!f9nMl
6,400
20.a
131&0D
17.20
^BtscraiAtinn^E^H
4Q,c0D
wmmi
■■■■l^ll^g
■HS
«dt»ilAOn3?aCHi
4.000
4.CC0
27,8
nu.400
—H'l'l
POO
SCO
■Kas
OMHO
■nn
D4D West Centra]
110.103
117.700
21c
2c-f-2.2D0
17.0DI
iSyQBifae^
i&y? iHinnescts
<3n.-3:#oh:
14.400
14.400
26.3
37.=.000
1d.30!
|ty|.'[!;'i!i’{t!ma[
■■■■■BKCIiai
2.30Q
£2,000
wsriWiT-fSiH
35.300
&K.50D
■iSOli]
2.100
20.0
&0.BDD
15.601
fagisr.'iH5gi
SnnrBBHBBBBBi
■■■■■■Bxnrn
2,cQD
-24.11
&0.30D
2DDD
2.QCD
54.703
■IBEi
isw«W»*w4u-«
■RBgivnTrv'iM
oCSBS
tMTil
■m!
4.SflO
■an
nOf)
SCO
MiUil
10,000
■IIII1S3
isSffrtSiteBftill
270 SciidT/jest
5.103
5,1GD
taa
HHHKEEl^
nm
liiW>kl<il44L-B
IHS^EltMtli^^EUll
i.iw*tiw-jii*nfiiai
BOO
eoo
■mil
■Em
WniFIt*T43C*
mrmMmmTm
iBt.aoo
»ii»n
■■mSiMI
■■Q£i]|
lotiiRinTISiV
1 A
2,3SE
'■wa
53.500
13.84E
KEI
331 .500
WKS^
[S-uffarbeets
D30 Conbrnsd Ca'jnL-=s
1.030
1.S20
■K^
Is-yflaibesls
2K? iMcntana
lyiiAnmnsHHHi
15.103
16.130
tmw
HHHHESEEI3
mm
BTI
■^!S
■■EES
CflfiTtl'lfllJLV
lS3t)
■sag
&3.4fi3
kgfiUnTJjlM
3.320
M«WW
P2.200
uRrrwssi
7.430
170.000
iSuoarbeets
ISO
180
5.7QD
■m
Isutrarbefirls
HtbikfilArTiTTnT^H
DSOScuth CenL*3l
24.305
ii.iSD
25.5
61S.SB0
hmi
HHSSl
[A
ficO
25.5
CTJ
1721
1.78D
23.6
42.000
1S.07
■kliWilXItB^H
1403
2.31D
2S.7
53.300
15.53
■i!iii:nn:iE!in?BHHHi
4.020
4,740
24.fi
117.&D0
is.es
wnfP'fSra'^l
.'iiTtrsRtRHBHMMi
47.503
47.000
m^i
WKmmmsm
■mm
Mdis#ii"irn' nil
19.9DD
23.3
474.300
HMlil
riHHillllllHKllIiS
1,800
KE
43.100
Hl,l,l.l
eoo
BBTl
■■■■BBIIjSSI
■KKI
mmmm
■I^S3IIQ!!SS9Hi
HHIHHiBIiSI
3.100
25.3
78.500
Him
\:pnmmm
HmmiQgg]
4.900
22.8
111.700
wmsM
tuC.lUliW.JMMHaH
6.500
;3.1
tH3!!
■nar;!^
BHIHHHiHniSI
2.400
■Kam
55 200
500
mm
13.100
HMJ,I
lF
500
IP
10.TOD
mm\
g^SSiSSSi
□ lONarhrt^r.
410D3
4i5i}il
945.500
H14(:I1
g^Susm
■i^aSSI!c53Mi
1500
Msaa
■■1441
mmiiniiiiiiiig^^
1.3CQ
■nra
■MilgSgEgl
300
mem
6 POO
■■SB
IiVjiE^'BVPRBMHHi
5.500
4. ICO
■pas
■Hiili
ggiHESO
State Total
47.500
44.300
^■■nss^iQ
Maw
54.D00
■■Mth
|S=ja3rbsr-ls
2lCv frJcrft Dako3
D 1 D ‘Jorrfift'SK
4 ino
4.000
^BI3
54 .ODD
■Hki^
SSSSSSHHIHi
■HHIIIII^OIiSI
30 500
25 5
7f>D non
17.95
Pmbina
TP.100
78,200
22.fi
1.751.000
1525
M^jiggagHgaB
43,100
■■Beta
hk
ISuaaFtseEte
ZCOTINcrthDakc:-
D30 Jilariieas:
154.030
ISI.SOE
■■ggi
'(SSSSSSBHHHBHI
|||■■■||■||||||ngJ^
HHHHI^IKIDISi[j
24.7
257 ODD
15.89
SiSESH
losfin
10.4DE
247
257.000
15.69
ISuoa/feeats
2C'27|Mcriri Dakcta
BHHHHSEES
23.800
■SE
535.000
ISyaaibe&ls
— gBgigBRBItHeSgl
200
■tiifc
£.000
laHBHBBBB
26.600
24.1
Ml. ODD
If. 66
52-303
30.700
t.l54.OD0
Event H7-1
□raft ER
238
Appendix D
7/28/2010
1448
Corrmoi.ty
IHH
Pi^ed All PiBiHises
{llsojssnds cf Acres)
Han.'Eslad
(iliousands of Acres)
By
rrcduraai
fHiousands of ions)
Sucrose
•Percsfi:}
51,200
■0£1
■■■■BSSs]^
HraQ
^iiiiiiimiffiMaai—
SfSSnnHHlMMMi
S5.MD
36.600
IHS
■BBHBBSE^!
iB^lffil^^AIIIII
IlfIfSffRMHMBHB
s.oon
■E^
■■■■KEB^'PIII
^BBPI
2K7 IWinnescU
45.700
22.B
1-C4C.DDD
15.00
Neman
-4S.3IKI
47.700
24.3
1.155.430
17.70
■Hfe&fiMIXtftRfS'SfWi
®OJC
15»,e3D
s'g.aoo
25.6
15X0
■Mill ii|ll|i||| III"! "'M
Dio Combined CciirA«s
1.700
1.600
25.4
43^5
17.00
fri^nfxlBTSffgn^il
DiONordiiwffi
3(2.503
203,000
BBSoill
ChtDoev^
SD.600
30,600
■fcJsirf
■raa
bBfB=|{iT44{--B
HmaaiSH
10.303
10.200
■OS
99SB!^^^^
■BH
iaH.Mi44AE«
mmmmsssss^
2.300
■■■MHESSS
iS-joa/tesis
2Cv7 iMinnescts
zecQ
■*1^
■■■■■i^Eis
■iBa
iS'jsartsets
2’I<j7 Minnescta
5.100
27.2
135, SOD
16.501
B.lOO
■■■■B^l^l!J
^E^Oi
■■■■■■KITi?]
6.4D0
■EIS
■■■■K^i^^
BBBBSi
HOMaiK^TRISSSH
I'iJitkrn
PD.eOD
40.500
20.1
17.BD
S'e/cw ^feyci^>5
4.D03
4.000
27.6
1TD.4DD
16X0
Sudarb6£ts
2-]v7 jMinne«cta
GtOO
SCO
23-4
2t.1DD
1T.0D
D4nW6srC«it-:«!
119.100
117.700
Mtsaa
BBH
■KSSSlfilfRIRini^H
14.403
14.400
Mati
■■■■^^^^10
BB^^I
|(y|4i:'l}roiU|
lllllllk6^tXh7r(3n!E^H
2,300
27.0
62.030
15.DQ1
UyiiklfihUbH
Mifeei«*iatARnifS?S^H
BBHHHKouiD
MtHH
■■■■Iw^^a
^BS
i■■■■■iEIT!!!1
2. ICO
■■m
■■■■H^E^S
9^1
7.5DD
Z500
53.300
■■Sil
Syoaiteals
ZDOO
zcco
HES
54,7DQ
BBBii
S'jdsrtjeets
■hff^iiXOTTRrPBM
D£0 Cemral
5S.70D
58.600
t,552,70D
BBOS^
i«rarac«
Redfi-ced
4.eDt;'
4.500
154.5'3'5
15.701
D7B Conhined Cciint'e*
500
SCO
■@10
10.000
i6xd
2Cu/ iMinnescta
07(1 Sn».t1h'«fet
5. 103
5.1GD
131 .500
SM
iaBn?!!33*
i'#Hmiimr-iniiM
600
eoD
■blSil
le.BDQ
WnTFJif^t®
State Total
480.000
4B1,Q00
liii
11,448.003
issrnrfiJfJ^t^i
2.360
Ma»H
53.500
^BBiS
sJSSSEMHIHI
llSiO
24 0
331.5DD
i5.ini
IdWMi-lJJu-B
1.030
1.920
H■■■■ES0Sffl
BBniS
030 Nonheas:
15.1B0
18.130
■ES
■BUS
^g!7^-rog<l
■KEiSiaixfRnre^H
0.670
m
257.DD0
mm ii'i'iiiAWttfig—
3.fS6
■rm
M.4bi5
BBa^
\;msm
SSESSSHIHHHi
3.320
■EBS
■■■■■^Sw
■KBiB
■KEsmxTnrrcMH
7.430
iMa
BB1SII5
tjRPftJpRm
j ifl rosnr^^^H
!«mKBTa.iBrsw4i.t!im
IBS
ISO
■IBHHEEOal
msmi
iKKRt^nr^H
auiKTJiisItQTlIPHHH
54.566
24,130
eiS
16.603
■Eoai
caRr;if!!#ll
HUfekVrlfAriK'^AtVW
1.720
■■■BB^SiS
l•tI•I«pra!^l!WI•rra«a
2400
2.310
WM
BMMMBE^SiS
BKI^^
EBrniTnr*
4.02D
4.740
24.9
117.000
16.68
47.500
IrOTir
24,7
l.ifii.ftbft
16.87
t«i?raci
1 1 1'l III 1
10,900
23.8
4T4.SSS
17.16
Chsveone
1.800
1.800
23,9
42.103
16.80
■I^SSSlIESSBi
□euei
eoD
HIS]
U.6D3
■m
^SSESSU
:HES9IM!EIS3H1
ISSISDHHHIII^I^H
iflHHHHHSnEI
3.100
2S,3
7fi,5DD
16.87!
UB.klt.!..UJ^
ilSBISHHIlHHH
4.900
■llu
fagiy-RirnM
IK^SCBaai
iinmniiiiiiiiiiiiQjjQ
elds'
■fcwn
■■■■Bil^ESg]
HD^
23,0
55.200
■ms
l■llll^^3[ES!5!SIS■■
500
■kS
13.100
■m
D10 ConbriSd
500
SOD
IKG
IHBBBBH^^
■KSEfl
bgr.HI[.?J4m
O10 SJortiiWSl
4l6cS6
4b,2ab
— gH
l||l■■l■■ES!^£]
Ha
kffgggSM
HESSIESSSSMIi
[gOg^imilUHIHI
liHHHHHIES3
2.500
■l^§
55.400
TTII
1.300
■BS
3D,20D
^■n
iSSSiSHBIHHHIli
30C
5,eoD
HSS
l■li^^lM!!cgS■■
IliVi'iiniinflTBHHiHi
5.500
4. 1 CO
■pan
BBHBB^SSE
■ram
iSugarbests
2007 INebraska
State Total
47,500
44.300
■i@s
■bbbbusieis
HE^SSlSalEEISSH
4.000
ftBE
flBBBBBS&^
■IBIKIiKa
DIDNar^nresi
4.1DD
4.000
■BIO
BBHBBBSO^
■ia
MB5aigSl^lii?l!BigB
30.500
25 r
75i>X>0D
17.05
BWH?!!95IM
Pembina
70.100
76,200
22,9
l.ryf.ODD
15X5
kgMtli.l!iiaili
iaiHBElSIS^
43.100
23,5
1.014, QOD
1B.18
Suoaibeels
li>y7 I'icilh DakRa
□30 NorJisssi
IM.DDO
I51.S0Q
23,0
3.5;.5.0DD
15.17
!^'Jfjait5BElS
2'*27 North Oalica
McKsnze
lonno
1Q.40C
24.7
257.002
i^BBiSl
2C07 Ncrth Dakc-a
D40 West Csnrsl
10.500
24,7
257.0DD
i5.eo
S-ioartieels
2C>:-? Ncrth Dak.ss
IIHHBBliEEIlS
23.800
23.5
535.DDD
17.46
300
200
28..-
6,000
15.53
iBBSSj^ngB
IBSilH^HHHHIIIi
! ■nmmiii^^^i^
26.500
24.1
641,000
17.66
|faWHt4J4l:W
52.303
SO./Od
234
1.1 “4 .ODD
17.56
Event H7-1
Draft ER
239
Appendix D
7/28/2010
1449
■
DB9
County
Ranted AH Fwptses
fThsussn;:^ f€f^)
Harveslsd
(Thousands of
■rrcduciisn
(Thousands of Torts}
Suircse
•Percent)
20,400
1&.7
5&5.OD0
17.0B
■Hiissciffistiimirisi
/□il*
eoo
25.7
le.ODD
1o.71
S-UG3tt65!S
200/ iNcrb? Dakota
DSD Ecuftsast
SI. IDS
30.000
19.S
5E»5.0DD
17.07
1 rifi n jjunjjn
Mtfl
S.TDS.BOB
■■m
iMBIHHHKSTtB
HESS
&1 .ODD
■BSiD
2C*j? 0rs-2cn
2.000
Hi@S
■■■■^Hi^
5-ua3rbesls
2C>37 D/5-xn
■SS
■■■HK^l^l
■Dggj]
f^^inarteels
2007 Of^-mn
□30 Sculnsasr
S9n:*
0.COO
S3.3
SCO.C'OD
15,09
Suaarbeete
2037 Oraoon
Stais Total
izota
11,000
31.9
351,000
tfi.SSl
USTiKt^TiiTan
2, SCO
■■■■■ESlIm
■im
f xi 1
Z0D2
2.000
IHMMKEESS
■mu
iSugartieets
2037 l^asbinoton
State Total
Z.0GD
iooo
4ZQ
imigDiigigig^
18.33
Bio Hem
6.70D
e.cOD
123.033
1S.83
KBsrnitnBss
1.-SCD
taa
34.000
17211
MHBBHBumQ
■BS
254.000
1S.07
l|l| M 1 I'i* ^— —
- e.eoo
155.0DD
15.83
26.600
26.100
■■
570.000
16.83
1.200
23,s
25.200
■ms
SCO
■EEli
16.900
■ims
2.1CD
20.4
42,903
17211
DsO Scutheas:
4.200
4.10Q
&=.QDD
■mK]
Sunai^BEts
30.200
218
B5B.003
18.811
ISyaarbeets
11,000
31.0
241 ,000
IS.Dcl
3.000
■■ss
id9f.fclt>l4:dS
1.700
■Ka^
5i>.nDD
Hi^S
MMWiM
2.400
KB
■■■■■IIIII^O^
■KSE!!]
oQO
SCO
15.000
tfiSRThlilTaat*
t*Fin
Do 1 Ean Joaaj n Va^-sv
le.eoo
i^mmmiiiiiimgi^g]
21.3
65<:<.ODO
15261
t MniT??nTFc^^^H
imr-snat
23.7D0
■■■■■DSSI^j
mm^i
WMisMMiSiSS^M
DSD Ecutn=m Calrfcrnia
2.4 700
23.600
4D.1
9461500
15.501
Sugarbeeia
203& jCalifornia
State Total
43.300
43.100
■m
■■m
lE^aarbs&is
snsamHHiHHHH
700
n.t
7.BDD
16.45
2.700
■Dig
47.000
rnmi
4.cfi6
■Kom
■■HBEdwIS
■HE^
■■rSV^DSIffSCClMB
2.300
■■■■■ES^EI
IS-jflSfbeeis
2C<e ICclorads
42.300
■■B
man
■BEm
►aJnK?iil44l-#
□20 Northeast
2&.63D
24.800
■WiM
wmama^ma
WM
i^iiii infacgeg—
505
■■■■■■IgEEE]
msm
eoo
HHQ
17.200
m'Hai
4.0CD
27.7
113.500
15,70
mimimm
I.SGO
228
34.200
16.S7I
wrawi
k^SuUHHHHHHIl
SMS
wfmn
mmmm^B^
■H&a
igasia
■ [M UKEtcer jfirFfHHHI
15.503
1135
■BCW
waaml
38.000
23.4
869.001)
16.05
28C0
KMil
93.000
17.65
WFTR'infS
■4-!»r.ll!!H!r—
11.300
34.6
361.000
16.45
»ggafrm—
IHHHHHSili&l
ifi.sii
31.2
33355
16.83
na«;i^li«rhv4il
2«« Idaho
BHHHHKEIi&I
4.?56
30.4
143,000
T537
S9?E!!niS33i
1.800
SBSSB^^
MBS
20:e (Idaho
D70 Conbin&d Ccunt-as
1.5DD
1400
mm
■■■■illKBGSS
■■BBS
iSjoaite&ts
2K€lldaho
D70 Southwest
33.000
32.500
mm
■KSi
MlgJlEESSMMM
iiiimiii[iimii^^jjj2
33.600
■Dig
■■■■BE^^
!S3S9HBHBiilH
15.103
15.000
■DSB
■ddhhk^issi
■HKS
BRSIPSSlSi
SSSISflHHHHBH
5.000
28.1
In?- 000
■■BEE
kg?il:ii.U4l-M
SSSsBSHIHHHBi
474DD
■BH
■■■■■[iS^I
■■EEl
EucarbeEis
OKe Idaho
SSESSHHHHIi
12.700
32.5
413.00D
■BBTS
Suoarbes^
20Ce Idaho
fiklil«nSlRlilJ4l>IJII.ILLH
«
2.600
35.4
S7.0D0
Suoarbeats
jUCt Idaho
D20 Scutn Centra!
IIS.DDO
n7,£DQ
31.0
3.S43.QDD
17.331
Srjaaits&ls
Idaho
23 2QQ
33.6
756 000
■KHEgl
BP!ff!nH59
■ 1 1 III nil —
13.800
tiia
■■■■■SIE^
S7.0QD
37, ODD
33.4
1.235-.Q0D
17.16]
P!ffRl»!5SW
■EQgSiiSESEIHIIIIII^H
Stale total
lU.ODO
167.000
31.7
5.928.000
bin.saii
2206 IMidi'oan
D3D Combined Countes
ODD
cQO
■U£J
9.00D
■IQ
tl=4in3fb»sts
"'026 iMichoan
l'tkliiJlB!!i'?gSM—
l9HHHHEiE!
H[|||||||m^^^^^|gi[!]
13.C
9.000
17.50
EjiRS!rS3BSB
■BsaD^Bsm—
||9HIHHCnS3
1.000
19 0
15.DDD
18.5£]1
■E^tlSSCSSBB
:gggg|9HHIIIIII^^H
11.200
■HD
■mi
BBSHiHSigB
S,0CD
Miaa
75.000
ia«i.fli«iJ=igi
005
600
17.3
Ir.ODO
1720^
ISuoarbaels
■i^^issssnv
17.0QQ
1B.8
323.000
17..00i
EB9SIIBHHHIH
3.500
Hn
74.000
iSSHHHBHHHI
14.800
23.3
2K-.002
1S.1D'
Huron
fo.50j
WmSmi
Event H7-1
Draft ER
240
Appendix D
7/28/2010
1450
Corr/no:!.?/
Yea-
Rsned AI! Fiaposes
Harvested
|HQ|
Sucrose
iHtaj^nds cf As^&)
(Thousands ci A^res)
ggggl
Suqartjesls
2037
f'Jcftt Dak«s
2e.4DG
1&.7
5&3.00D
17.06
S-ioartesls
2027
North Dakocs
i»i!iii«><TBi>ltn3:iM>U:>t£-ll
7£e
eoo
15.000
■■^Sil
S-uaartJesis
2027
Ncfti Dakcia
!DSD Southeast
SHOD
30,000
10,9
5^-.000
17.07
Suaarbeets
UtR
North Dakota
Is tat* Total
2^008
247,000
i^I
mm
2.oeo
MijH
■■■■II^Q^
■lEam
MSTSfSSBH
liklitiltffiiTPBMHBBMI
2.00D
■Ksia
■ms
l488SIS3aSI0i
i^ssnriBH
9.0C10
WK^S
■■B
2K7
OrKon
joao Scuthiasi
ooo:<
a.Qon
313
3C‘3.0DD
15.091
WJfflR.ISSi
IStafeToUl
12.000
11.Q0Q
31.9
351.000
18-65
■Ki^
2,000
42.C
&1.DD0
ta
2,000
42.0
64.0DD
wKmi
tJSBfflrawi
tooo
34.000
■■Bl
wrSKSII
MWH
518BSJBBB
0.500
10.9
123 .ODD
1S.B8
W*B5T5^C«
KU
IBSfli
1.4D0
24.3
34.00D
1721
kWifiiilWBi
WM
llllllllllllllll^^
21 .6
254.0DD
15.87
■BtTia
VP^SS^^nHH
6.7K)
6,600
24.1
IS-IDOS
1C-,d3
KsnSUfJSiat*
Meii5W
26.600
26.100
2i.a
57-3.000
16.83
2027
rt'TOinirvi
■itSITIWBHBBHl
1.200
2S.200
KSS
^■■Hi^lBIF7i7l
SCO
21.1
ie.000
15.141
!:SR3s'lii!44L-«
■■■■■■nnTii
2.100
20.*!
42.000
lewillcfliflJISilll
42JD0
4.100
mem
■1^
W'iillil'M
S0.800
30.200
21.8
(■■■H^EISEI
16.81
2‘2C€
Califcfota
It. 000
31.0
341.030
15.06
iSrjaaifcEEls
Catif'Cmia
SfSnHHHBHBMMM
3.000
*34.000
14.75
MIlEuiaBi
SnSBHBBIBHIHi
1 700
2B.4
52.000
11 oa
l.'^rifiaffaepis
20Ce
naKf.-mia
IIXBnmHHHHHHi
2.400
7'2-.nr!.o
■KSSS
500
500
IH!3
■■■■■IIISE!^
KB
l9qKTiiT4iaoa
Bblii!fcl
ID51 SanJoaajfl Vs'ev
lO.eOD
1&,iDD
31.3
61Q.900
1528
wm^
23,600
42.1
945.030
16-50
»aaf3
2altr-:mia
iDdO Scucncfn Calitcn^
2S.rDD
25,eOD
4D.1
£45, OK-
i6.sn
SuaarbeEts
20 QS
Datlforma
Istate Total
42.300
43,100
Km
■Em
!@(l?RT5Tf33M
•raflTSTSS^^B
lsl7ll59SHi^HHH
700
n.i
7.BOO
16.45
loze
Cciora;}9
FRSntnBBHHHH
2,700
17.4
47,000
17.33
fcjitThri'ii^aty
mmtm
IITB&IHHiHBHHl
4.:CD
20.2
0355
15.53
2,300
23.9
55.500
15.86
1,900
fija
42.300
12,700
■BW
267,000
KH
teRfriiRgc^l
ColaraSo
1020 Northeast
25.6DD
24.800
517.000
■gsa
£00
'id
12.000
Kffi
2'>:e
Cciorado
riiiit'if'^^1— 1
ecD
KB
■■■■HH^I
4,000
KH
■■■■KKSOESI
Kn
•nprrdi^^H
IVIMillilll'i^—
1.600
1,500
tar.i
keh
\mimm
SSSSMI
6,600
30.Q
1&7,6D0
l&.OO
23^
Cclorsdo
1060 East Certrat
15.5KI
252
372,000
15.85
2Q0S
38 OOD
23 d
8B9.000
4B.09
ISLinatiieels
2026
Idaho
2,800
35.0
KOOO
17.65
Isucarbeets
loce
idalio
■■■■HBSEI
11,300
34.S
391.000
1fl.45
2C’!-5
Idaho
10.500
■KW
16.96
IS!iE!iuS9i
■1^
'daho
30.4
142.000
16.77
iMBuESgii
daho
lTO!fgBfB8SMHMMB|
i.aoD
2K
MS.POO
1M2
■PIS
ifgmM
1.500
1,400
HHBBBKQOi^
■BI^03|
kgBkfi.;43M
2c-ce
Idaho
|07D ScuLh-7/6it
SS.DKt
32.500
■ESS
■■■■EEsn
■im
bBmi'mm
EEEBSHMI
33,600
30.5
i.OiS.Ooo
17.42
■K^
SSESSHIV
IQ^QIjgiligillllllllllpg
15.100
Sbi
45^it-6
17,43
28.1
165000
17.62
EiS!IS59i
2C.Cv
Idaho
IlSSSBIBSBBHHHHH
HHHHHK9^3
47.^00
31.3
1454.000
17.31
S'jcarbeeis
2CC€
Idaho
Twr. Falls
12.000
12.700
315
453.000
17.02
S'joafbeets
202c
Idaho
□20 Combined Count ss
_
2,900
314
97.000
Idaho
□SO Scutn Cenbz]
11S.D3D
117,500
MtWtl
wmm\
23200
mem
T55.0D0
Sunartefels
2-yy.
Idaho
SESBHHHIillHHHI
13.300
32.5
445.000
17 15
ISS23HHI
STJOO
37.0DD
33,4
1235.000
17.19
^jSSUSSi
■n
wsitnyrgEt^— —1
187.000
31.7
5.32B.O0Q
17.11
2*2-2€
UiM'tian
500
■iSQ
9,000
■KS^
&iaartiB£te
juCc
‘.licrt'oan
S999!9I^
500
wmm
■BEE■■||||g|!^l
Kn
“••joaffceetB
jyys
Idichdan
HHHHHHXlIS
1,C0Q
laa
19.000
warn
Suaaftsets
2'>;e
Micrtgan
UBiiHlIlHBEIiS
1UDD
mm
21CJ.0D0
nmm-f
Sugafteeis
2'Xfi-
Micntsan
[SSiiESEH^HHBHHi
2.QD0
■CB
75,000
■Kami
S'jaarbe&ts
22*26
i.kchtoan
ID5D Conbincd Count sa
ooo
6CD
17.4
15.000
17.2DI
IBBBHSBB
IfiOnERRBIBHHHBHi
HHHBIHIiSSiS
17,000
■im
■EoEi
S'ioartieets
20Ct'
ISSESHBHHHHH
3.5GD
■an
SuoarbBEiB
2036
'.licsioan
HIHHHIIHEEIS
HBHHHKSillO
KiKI
■■■■^^^
HUE]
Micntoan
iHurori
55.600
■■■■■■■liQilj]
...gf,!
mmm
Event H7-1
Draft ER
241
Appendix D
7/28/2010
Event H7-1
Draft ER
243
Appendix D
7/28/2010
1453
CorrjTiDnity
Bim
County
PtsniBd All rtspBSBS
tThsasan^ Acres)
KQI
H|g|
rrrduKian
fThCLSands of Tons)
Sucrc-se
-;?src5n:)
S^jQSfte&ls
10.«OO
22,4
378-000
■miMi
20.100
24.3
432.OD0
17-3DI
21, COO
24.f-
514 -ODD
-- is!2D|
BRseRJiSEnai
see ll.!ich''csn
360 Has C&rflraf
is.rcii)
131.5CD
mBm
MSB
1.ECD
18.7
2S,D[jD
■■B
KWtk)i>I4:f}ba
£CD
■a
It.DOD
■im
IIIIIIIIIU>S^||<(^^
acD
20J]
le.DDD
17.801
lading E»
2.SQD
2.300
■i^
5f.fir«0
WKm\
-■^'^.tisrhseis
■BllElIBniHi
QCD
24.4
S.ODQ
17.301
Si/asftests
2CCe iMietioan
oeo Ganbinsd CcunLss
1,300
i.acD
■■■■|||■[ggg
■m
Sitoaffeests
see Micsican
2.25fl
22.3
49.DDD
■■■il
WriKTiiT^a
154,000
23.2
3.573.DD&
1B.10
0fiBS!ff?5SB
e.3E0
27.2
2fe BOO
15.40
52.700
25.6
1.357.1DD
15.10
teSiSKRfrac*
33.100
22,5
6S.300
1&,DG
He6^>iiAKnf5!rE^H
■■HHBHBSHFil
4«'fia
24.1
105,930
wamil
41.500
S.9
&4&,3DD
15.501
42.100
26.3
t ice.’nn
17801
^■■■■■CiFtilfl
93300
wtsm
■KB
IHKei^lllKFSItlSSS^I
1.700
MaaRi
■BBH
1^ 1 1 ^WitTai t1l«^J3« ff ffTTS
400
400
wmm
6.eOD
WKSM
310Nw*i\«K
3!J?4J3D
281.CDD
■TTl
■■■■^^^
Hi!!
'SniffiiWiWHBIBHHi
■i^^^HHKEXSSn
HHHHBHESsil!l
■udy
747.3DD
16.50
i^nsiniSEi
H r nrjrtwrrwy^B
23,4
263.400
16.60
■KiS£i[7ll7f!f9!mi
4.300
27.4
11S.DD0
16£D
iSuoarfaeats
2i>Ze IMinnescta
jSeHHBHHHiHi
3.300
24-e
5?.4DD
Too
KSiicrtiTjam
4.100
25.5
1MJ0D
17.QE
UtaMifUiXnifnSS^H
■■■■■iHETrm
S.90D
23.2
• 140.700
IB.fiO
B.5C0
mess
■■■■IIPSI^!
IKB
^^^■■■isrTni
SD.iOD
MCTi
■HB
^Bdril&IIASTTtTSilS^^H
3.800
WKW
■■■■I^lgg]
wwsm
H«iiU>llARXTS3S^H
■Mii«<<TNi>TiiiiidiiV>re>Sr^4i
1.100
i.iDb
■BS
S.2K'
laiJiajJTsaM
3-D iVesl CantraJ
137 OM
126.200
25.0
j 155 eor?
ie, 0 D|
16.300
4ie,BDD
■■EEEI
ISugarbeels
iKKfTii
2.700
61,DDD
WPSffTSBi
T^irrflllllllM
'2.!ai5
25,5
5Si5S
iS-Sbl
BU.MliWrJi*
HuMiMIKOIT’CRSHHi
^envile
3P.40?
WM
KEI
■■■■dogs^
■■■■■HKEliSl
2300
wa
5? .530
■mu
2,100
KH
55.000
HRSKlfMJISPPfSrBHI
■ u >
85.000
25.0
1.025.100
16,70]
P«>kli'l=l4C«
s.soa
MtHH
■■^■■11^^^
■■B
KPT'FTiiT^^t*
l■MlMlla.■TO■m!lg
603
eco
—gw
14.S0D
■■HQ
370 £cud'.v;ast
4.4D3
4.4CQ
■PH
1D3.0DD
■R
3bfi C.onhhftrt r4Slricls
403
ion
L2B2
■■0^
k’lHIRi'R^r^
Statf Total
SCi.OSO
477.000
^Esa
wwwmEam
■E^
^■amiiARTTRT^^H
■IHHHmrSFS
2.320
MiWH
wwsm
IS^joarbeets
HHfHHKEE^
15.^50
■Bara
357.000
^■K
Ij^joaites-ts
■ 1 iirrrrm— 1
HHHHHBIS
mEM
2C0e iMcntana
330 Nadiear.
KIS
■■■■■^^
■KB
H^3IlS3S39Miiii
sia Hem
WBS^SM
31.0
245.0DD
msmi
BSBOlSSi
BB£SMiniHii*=iiflW^BW
Carbon
BBB5^^
■Kara
112,000
WMSm
KfTTProSBI
■KSgiixmigg— :
HHHBHHBEISl
3.060
31.4
67.000 '
IS./D
ssissmssi
BlKSCTBHTOffBBBI'
7.220
28 2
220.50D
i5,ai
3S
230
wmss
E-.2D0
16,32
SSjESESB
27.660
23,590
Te.Q
5S3.7DD
15.71
t:g!.|t!i.!44f
OSiSESiEIHH
Curer
i.iea
1,0 ID
3M
27.402
1S.64
SS^ESS^SB
[JOSESSHHii
^rare
1.600
1,570
■ana
■■■BEgl^lg]
■■H
■llll§S3[^59i9^l
iHi^^HHSE£SI
1.900
32.4
61.60D
■■B
1 Sn/aarbs-ls
lliH@3l!SiIlB!9Hi
4.-i30
Mgg
123-SDO
mmi
ISuaariiEats
1 ip^'irn'M— — 1
48,500
WEE
■CB
■[|^3IS1[!EIQ3IMI
^^— — — htm
700
■i^
■i^
■S^jlS^ESSMi
S.700
23.G
521,7-30
17.511
i^m^s^sam
SSSiSBHHHHHl
HHHHHHBOIiS
2.9G0
24.4
7U.9DD
17.961
H^^SiSilaSSHi
aoD
■kS
iv-nnrf
BgHr«rBBi
(gj^TgOHEEIEim
IHHHHKESS
4.300
■BE
91.300
liza
ISugaitesis
2eee iHebrasfca
iSSiSHHIHHHHB
5.100
iib,7k:
■^^OSSScSiSBI
iSSEEBSBHHHHi
23.0
2S1.51®
16S|
iBKBtnBBHIi
■H^^SESciSlHi
HHHME5I9
3.DCQ
22.4
67.100
iT.oel
iS'joarbests
i*Se Il•l6bras}la
DID CombinFd Crtml*^
1.000
CflD
■0]
23.5DD
DIONanhissst
53.70D
50.500
T1
■iSD
BiESHHHHHHHi
iiiiiiiiiiniiiiPi[imQij3
3.800
■Els
Mreg^
■H
Siicarfaeets
i.eoo
■1^
37.700
■1^^
Syoarbeals
see iMebrastes
PstinH
1.900
Ji-l
45.70D
— m4oi
Event H7-1
Draft ER
244
Appendix D
7/28/2010
1454
1455
County
Pts^isd 3UI ruiposes
Harw^siad
HR|
rrcducdyi
Sucrcss
{TTiaasnfe cf AerasJ
(TliDusands cf Aires)
{Thcisands ofTons)
{?erc=n:i
ICCe l.fich'Oan
16.&0E
378 .ODD
■■Bgnil
S'^aarbesls
101^ Mis^iaan
20,100
24-8
49=.00D
17.30
S'joafbepl^
?v":r; l.lir^-nan
21.0013
24.5
514 .ODD
1S.2D
S>jaarbs5ls
2£-‘::a yi^i oan
360 Has Csnira!
IS’JEJO
131.500
219
3. 140.DD0
15,10
SusartsESSs
2CiC<5 '.licjiitjan
l.fCD
16.7
2=,0DD
1S,30
Suaarbeels
500
22.0
11.000
21.10
SaaartieEts
iKe|Mi=n'i)an
aoo
20.0
15,000
SaaartjBEls
2DK iMicri-oan
330 Scnfc CcntTsl
2.80D
laoD
■IBS
■■■■■ESISS!
Syaabeels
W^KnHi
SGC
22.000
17 30'
S'ioartiesis
SGCa teaan
DSO Cambinsd Ccuitss
1.^13
1.3DD
Ki
:|■[|■||||■[^
■■B
■■■■■■KKJiK]
3,2'CD
—tMH
;■■■■■g|J@
MB
154,000
232
3.573.000
18.10
8.90E]
27.2
2EC-.630
52.700
25.6
1.357.100
15.1Cj
|aS5IFfi!I33»
Kittson
SB.dOO
55.100
23.5
S25.3QD
19,001
2i!Ca IMinnescta
M III 1 '1 M —
4.4C0
24.1
■—■mg^j^
41,500
Sis'
&45,300
■■SI
S-doaitsEis
SnfIVRBHHBHHHIi
■■■■■VRCin!
42100
26.3
■KlOi
StjnarfjBBK
53.300
24.S
2l.3!4 500
■mi
S-jaarbesls
2C*M l.tinnescts
1.700
22.8
35,700
17.701
Suaarfaesls
2^16 WinriEscta
3 1 D Cooibiried CcuniBS
4D2
4(5'e
223
■■■■■■[^S
■■HIS
Suoarbeets
2C-Cc Minnescts
010 Norijft’es:
S37iKrD
2S1.GD0
24,8
5.982.600
lejlRFTJraM
■■■■■■RBSS1
32.200
232
747.3-20
16.5Di
idstesrasc*
■■■■■■Bmilfl
11.500
■^S
265.40D
■KH
2C£6 fWinnEScta
4,300
■BB
HS.BQD
13.BQ1
i«siri?rn»r33cw
PX3-
S.aOD
3.000
65.4DD
mam
BH^HHHniTi^
4,100
■■■■■gsigggi
■■BIS
sBUjHHHBHHH
5.000
■■B
6.500
KS
■■■■Ksnp^
50,400
26.7
1.343.4DD
1720I
S^yCarbsEls
2'j:Mll.^inne5cta
Yfe'icrt Ms-iicins
2.003
3,eOD
■EE1R
£5.700
■E^
^joarteEis
□40 Combined Counts
1.100
1.100
25.203
S'joartjsels
KCS IWinnsicta
340 West Central
127.003
■■■■h^kIs
mm
■■■BIC^^S
■■ra
nSRRRSBHBBMi
1B.3DE
■■■■KESSiS
■IK!
CT.tr!i»TrHca
■K4M[ximnMi
■■■■■■33(13
2.700
223
61.000
i&eoi
HKtiy-.iiitRnSEH
!!?■■■■■■■
■■■■■■BRiin
2200
■■HHIIIII^^
■narni
fenlhii.i-44i.-a
iTTinraBHMlBH
36.300
■BQ
MB']
HrKVl [TEnms^^H
^^^^■BEXTiSI
2300
2S.4
55.500
■IKi]
W.Mt.mi*
2. ICQ
MiH
Kjog
fe«|.Ml.ir44L-«
350 Csnirtt!
65::dd
65,000
■iara
■Dsn
fejitMiiprata
^^^■■■■KfTTrii
5S.6DD
■KQ^
BffWJfOTi
'M'K=a-iMTwnitfi
603
5o0
■EH
14355
■■HE
070 Scu&iv/sst
4.400
4,400
WrEI
Hn
¥H;iigfgfBBgfriUI.IJ.»
403
400
■IBEI
Laos
MB
State Total
5Di.00D
477.0DO
■BE]
■■KEsn
■BQ
5,82D
HiQ
Oi.OC'D
MB
i4i!'«ii'i'i.n^piii
IK^IiSBBSiElWII
alESSEBMHI
■HBHKSSS
15,450
25.0
367.000
17.56
■■■■■■snis
2.1c0
26.4
57.00D
17, B7
2C<ld iMcnlana
330 ^Jordteas.*
20 043
20.430
■BE]
i■■■■g^g[1S
RffR't'igSqi
7.500
31.0
245.000
15.511
■BSSSSSHiSHHi
4.450
■@}
112.000
(:3r.'f3»lTi!Hl'W
mmoR
K.OOD
IHII^
KBTTi'.'gggi
5S9!^SSHBMHHi
■■■■BK)^]
7.830
■ERP
■■■■Iffig^!!
Him
■IIII^SSIZilSISESHi^
»Bmmr.Bri!ig«
S."?!
280
P2DD
■KSgg
HSS[S3SS9Mi|i
020 Sc'jih CenPaJ
27.B0D
23,560
■■atn
■■■■ESQ
MEMi
Effnr»RBWi
■IIIII^SSQSStlSiBHHi
■H^^IKK^
1.Q1Q
27.1
27.403
I6.&4I
Bff.k'li.fiH'HB
■lll|||g£g][Q3tS3SHHi
fg^gniiimiiiiimiii
1.570
21.S
34.30D
17.7B|
2C'l^ l.Icnt3na
1.9GD
32.4
51.830
■iSIjS
IStJcarbEsi?
2C-Z‘ii lilrnana
4.430
I-^ISOD
SunailiEEU
2(10$ Uonlana
stale Total
53.6OT
48.500
■■■■S1!1M!I
mmsml
H^^SSSESSHI
■■■■■■PUS
700
1tt.4
11.530
.....17.761
IjglrklHHiSM
■■■■■iSEliS
22.700
521 .700
Mfm
Sijoatbesls
■I^^ISSScSSHii'
SS3!SiC9HHHi^H
2.500
24 4
fiO.QDO
■■H
SuqarteElB
fll^SSIISSiSS^Hii
SSlSHHHHHHIi
■■■■■■EliS
200
23.3
15.0DD
16.66!
■BS30KS9MB
jj^tglllllllllllllllll^^
I^H^HHKEiiS]
4.300
21.2
D1-3DD
17.70'
S'j'narfceets
2026 INsbraika
I2[Q]BBHH
5.100
■gs
■■■■■■^
■KEinjl
IB■■■■EBS!SI
■■■■■■pSIM
23.0
231 .5DD
1622
■ElgSQinS^BH
SSSSIHHHHHHIli
■■^■HROiSI
3.0QD
22.4
67.100
17.06
S’w-oaite-ls
2D“6 ji'}.ihraska
1 DID
900
■■B
.’InrHi
20'2c jHebraska
310 Nonlw\'ssi.
52,7133
oD.cOD
22.9
t., 155,500
17.11
3,800
23.4
1D8.10D
15.4Q
EESLBHHBHHMHi
■■■■■■CK^
1.6CD
23,e
37.700
15.76
S-^nartiesls
5ESS!!9IIHIIIIi
i.pon
■■■■■■1^1^
24 1
■■■■■■i^
1640
Event H7-1
Draft ER
246
Appendix D
7/28/2010
1456
Corrmyi^
1
■
PIsated AU rHlfpcses
Harvesisd
Hi|
Sucrese
wmS^
{Thoasantfe cf Acsbs)
niwL’EandE cf Acres)
S'^aarfaeels
2C-;e IMebraska
D70 Scofetvifesl
"iflS
7.3QC
■Baa
■■■■BEQg^
mtsM
Suaarbeets
2I18S {Nebraska
State Tots)
6i;kio
57.800
■BS
■■■■SlSOIi!^
hb
lagtftiiiTaaicM
4.500
23.a
107.090
17.08
^aqartieete
Hn#’. Dakc!:a
D 50 NoribiS'SS
■4.a)D
4.500
23.£
1[J7.000
17.88
Mcftn DakciS
Gfarc Forks
32.^0
3^400
27.G
S210DO
17.65
Hcfti Dakota
Penbtr^a
7&.70D
73.200
■ESi
■■■■0^^
■iii^l
SanarbeEls
■BTOaiiBTtaijjtgai
41.500
■l^g
■■■■B^9^|
■■ESSfl
S’joarbests
D3DNsnh»3»:
155.233
145.200
25.0
3.7C8.DDD
15.S4
Saaaifaf^ts
2025 North Dakota
254
277 ODD
17.78
S'jaarbe&ts
22-^6 North Dakota
D40 West Central
iq.sk:<
10.70D
25.4
272.DDD
17.7B
Saaarbsats
2Ke North Dakota
24,700
26.4
65t.DDD
57.84
Saqartieats
20r-e Mcfth Dakota
20,^00
27.1
rSC-.ODO
17.5B
Saoarbeeis
"226 Nftrn nakr^?^
D60 Cor^bined Ccunles
202
too
3D.C
3.000
17.74
S'JQSfbeeis
2CC6 Wcrfc Oakcsa
DcO East Central
50.1D3
51.700
20.8
1..S:4.DDE
17.75
laSFTiJfSG*
HiKimiemfl
ICO
HiB
3.QDD
■iB
Rich and
3l.3[Ki
30.8DQ
25.4
7B1.00D
1d.B9
2D';fi tNerti Dakota
DSO Ec'Jtheas:
30.500
25.i
7K.0D3
15.89
■'hlillMH Hill’ll^
|[||||||||■■[^^
■■■■SEOOEIIEI
■K1E9I
kSflSfiffSHi
■EiafBggg!— i
^■■■■■KETiin
2.300
'■■■■■^lE^
■ISP]
20K (>5-3cr»
030 Nor^eas:
2.300
■Si
K-.300
■EH]
2026 OrKcn
Klaltieur
1OJC0
io.aoQ
31.3
337JC'D
16.08
ISaaafbfiEis
2K6 Ofsocrt
DSO Scutnsss:
13.803
10,800
31.3
3S7,7DD
15,08
ISuaadieats
2006 Oreoon
TTtW'^BM— —
13.100
11
■■■■EMIREIll
■ram
^^■BIHlHmiTial
2.000
MRin
74.000
■rasii
teteti«ra3M
■imCimnBH
2.000
■ESS
■■■■■jKllg^
■m
ISuaarbHts
2.000
»yin
■■■■H^SMS
wiitfm
tetiii'ktMtJst*
■■■■■■EBiTS
11,300
■E^
■■HMilSSi^
■KQig]
WffSiiTtfiE*
2200
4t.2DD
teiliRini-Jdt*
I^Ki^^l^IRRSfFPS^^H
■■BHHnBTil
12.800
■i^^B
■■■■E^l^l
■Bi
|5PfIF?5»1SE»
8,100
■BS
■HS
2K-fi lyVtfomiM
2 !□ Nonht\e5:
37.4DD
35,200
2Q.D
703.0:>D
17.1D
kEffSTiiT3rJE5*
i^au
■BB
30 .630
■nis|
wmsmmstmaam
HHHHH^^RtTnn
6Q0
20.7
15.800
■■EEI
2.800
■Bi
4‘^.8DD
■BUS'
OfO Scuthear.
5.403
4.SQ0
18,4
ef..DDD
mm
rnn mn
40,100
19.9
tsB.bco
■Bmi]
10.700
■E33
3SJ.0DD
■■E^
■|■||||||||||||||■^
<0.4|
183.00:'
mam
Heli^ [enil^innBi
SCO
■U;W
ll:55!i
■E^:
inSRSMBHMHHH
3800
MtWI
112030
|:*IT.hr,.TJ3Cil
^RSS3 FSRRSnR^H
003
800
■Bn
25.033
■KS^I
21.033
2D.7DD
35.4
733,003
14.6SI
eE?s)sa
■^KuaH
53.4b&
M3,DDD
■iSI
ISuoarbeets
2GC5 ICalifomia
iUtlsffl!li!Pi!l*n»'V.'iti?*
21403
23.-iD0
3S.C
KJ.iSB
16.601
■KTtTtHfBRrrTmff^H
44100
171
1.83803D
. .. 157.81
■B3H
■■■■■I1|i|i|''l
S!®2S33I
ESiSHHHHBHiH
HUUIta^^^SlS
■ES
■■B
HHSuSSi
4,300
■BB
■■■■l^g^
mum
—aseawffn^FCTM
5.5(56'
■K3W
5?. IDO
■iEQ]
^[SElEOHli
HHIHHill^BiliEl
i.ano
■313
38 400
^BESn
■IBHHiinilIRg]
13.200
25.3
ssLDoa
. 1&.13J
iSr^oarbeau
2CC5{Ccbraio
220 Nonheast
25.330
24.600
Mgfl
■■■■Q^ggg
■^SSSSHli
466
MtHH
5166
mmsi
gmsa
ISBSSSHHIHHi
HHHBHBSiS
fCO
■Bca
■■■■■EESi
■■SE3
SSSSIHHHHHI
2 sen
Mgin
67030
iS'ioartests
2C-2c iCcloraM
1.3CQ
25833
GSDSBHHHHHl
HHUHIHiffiiS
4.400
113,033
15.45'
rtTWiK^dilSntT^^^H
13.533
8.400
•24.6
~ 233.053
15.57'
Hl^j^SSSEEEEBH
E7RTV?:n?mH^^^B
34.606
■■■■■^211^
■■HIS
■ilSSIMiSIHIBi
2800
mEm
HBIMHHEEISS
0.800
■E^
SBSEIS^HHHI^BI
T.eCQ
warn
1K.0DD
mm
^HHHHESiS
4j0S
20,2
140.003
mmM
kft.yi.T44L-B
2C-2S-|ic!3ho
1.3GD
28.e
57,033
15.221
iS'jqarbe^ls
2C-C5 Idaho
^SSSESSBHHHI
1.400
30.7
42 non
15.32
liWiMMSItflUnMi
200
4 ODD
2Cv5 lldaho
27D E<!iithY.i25t
23.000
20.6
£30,033
■i^^E
SSSIIIIIIIH
jllHHHHHI^EIIlO
tmm
S17.03D
SESSjSHHHHHI
2,000
■Bam
■■■■■SQ^
■■Hi
2C-CO ildaho
ISSSS^HHii^H
13.500
mm
■■■■ESS^I
■m
BBBngHai
Hi^^OiSiSHHIH
llSOHHHHHHi
7.600
24.0
IFTHOn
17.851
S-joarbeels
2025 ildaho
itinidoka
42503
42.400
■ES
■■B
1D.4DD
1.H
■■■■ESiE^
■KBS
Event H7-1
Draft ER
247
Appendix D
7/28/2010
1457
ComT»Di:;y
Year
Bi
County
Pkr;:'^ All rUlpDESS
(Thousands Acres)
Harvestsd
{Thousands of .Acres)
YeJd
(Tons)
Sutrcss
•Percent)
■Essa
18.9DD
msaa
37E.D0D
■Ki’
i!(iisaiTFmH
20.10Q
KB
KKHEglEBI
■KHi
M9RFR«raiB
Bsaai
SnRRWMHl^^HI
2i.nm
24 5
514-ODO
1S2D
2025
yic^iinan
D0Q =35*. CernraJ
131. “00
3S..6
.T140 ODD
■■Sil
■Ka
KRmH
1.SCD
18.7
22 .ODD
15.30
Wib£il
5CD
mem
bhhhhebess
■PiKPlI
(‘iii>«k>RiiHHii
aoo
wmsm
■■■■BBOig^
MHUB
kwiitiinSCB
■kUtftil
luikmKiinfsm^H
2.80D
2.SCQ
ipe
sf-noD
1B.70I
tw
600
24.4
22.000
17 .30'
SttQjrbests
2cce
Micft^csn
180 -Conbinab Ccunl.-35
1,303
i.aoD
BEaa
HKHKE^
rnmSml
S^narbesls
ic-ce
Micri'can
ISO £cut?!«s:
2.203
2200
213
4V.DDD
17.20
SuRarbeets
2QQS
Michigan
State Total
15S.OOD
154.000
Z3.2
3.573.000
■m
K!^
BBIIIIH
27 "5
2f/“-.S30
16.40
BTnBBHHHBi
BBHBHECifin<1
52.70D
25.0
1.357.100
Kn
1&M
•iittson
35.503
25,100
23.C-
525.SDD
le.ool
NPr-MfSTOdil
MinnescU
il II! 1 1 II
BHIB^^BrVP^
4.4{;£|
mem
wmKmmmsssi^
■KH
^BTSRIISm
BBBBBF^Fi/i]
41.500
22.9
&42.30D
16.50
ieIRffiilPn
42.100
23.3
1 1G82?r>
17.80
b!|ltt!i}llt.t44Lll
SlSSSSSHli
I^BBBBRSB^
24.3
1314.5DD
15.D0
Suqartects
2c-:6
Minnescb
1.700
msm
K.TOD
■mil
Biibsrbssts
2026
Mmnescta
IIQ Csnbir^d Ccuntes
403
400
msR
5.9QD
mm\
Sunarbeels
2C'€e
Minnescte
ItO Nsnhisest
3u7J)DD
281,000
24.8
e.S32.SDD
15.20
32.200
...23.2
747 .500
16.50
BHBBlMnfiTnil
11.500
M3cB
2d?.4Dl'
16.BD
iBUitsa
■KM^I
BBBBHEBi^
4.3G0
=7.4
11S.02D
msB
KWiKnsnsca
3,000
mtse
&r.4D0
mmBm
Svtjaitesis
AHiTtTSifr^eflH
^^^^^BKlTTItl
4.100
1M.7DD
SitiarbeciB
SimiiiMSSBBi
"irtif!
5 m
5.6CD
M-|-ff-|
140.700
Sucarbe&ts
. soza
Minnescta
SSSSSHIHHiiH
9.500
24.e
254.0D3
KH
S0.40D
26.7
1.543.400
172D,
2-:c-a
Minnescta
Ye C'rt fvtecicirrr
3, BOD
S.eoQ
23.8
&5.7O0
16.701
icca
Minnescts
140 Combined Count es
1.103
1.1 CD
S-.20D
XF1!!WI5^^B
127.033
126 2ED
2^01
3 1f.=.ED0
16.90
Mt.'ll
Kand vnh-
16.^03
18.300
MMil
415.500
mem
AtTtTTrnT^Hiil
■■■■i^Bnnnil
2.700
KS
bHHHEE^
HH
WI9S
BBBH^BXTnil
l3Ci)
5:.S0D
Miffi
IWT:riT-73r«
KiW>!
39.300
24.B
575.40D
ie.“fl|
UnnBBBBBBB
^^^HHBKErm
2.3D0
25.4
52.500
16.B0I
2 100
KTB
■n^
HBffiTBai
55203
85,000
KB!)
rdsnnTRB^BBi^B
■BHBBHmtilfl
3.S00
23.3
^.50&
iS.Sd
Kirnr^Tac^^H
■UilK.’i.i.iiai.MirrfTftiR:.*
603
eco
BKfH
-.4000
■Kini
S’jgarte&ts
2o:^
l.iinnescta
170 SctAnwe.*!
4.403
4,400
.23.4
1D3.DOO
16.B0I
‘5*xa
WInnesch
106 -Conbir.ffl Cislrica
403
400
■Esn
7.3D3
■KID
Sunarbeets
2008
Minnesota
Stale Total
501.000
477.000
■BE)
■■■BliSlilili]
■EH
S^gaibeais
2C*:d
Ucntana
2.220
HjQ
51000
■KH
Suaarbests
20:0
McnQna
iHSESSHHHHHH
15.450
■aara
■■an
iC<Y5
i.lcnlana
2.150
KIB
wmsm
SB>ES3^^9BHHB
20.430
24.0
503.000
mem
■e^
jtoHcm
9.683
T.eCD
31.0
245.0DD
15.51
latbon
4.460
24.^
112.000
16.29
ISSuS&EHHI
BSSSSHiiiBHHI
MHHHHBE£S
53®
KiS
iim
mm
7.330
28.2
7n.n f;nri
15.B1J
■Kl
mmmm\
"BiBsiawaiimrai
323
230
9.200
■DBS
2o:a
^<e^tana
fcl.fcRlia.lSffi^H
2756D
23,560
Kgn
■BBS)
[Sugarberts
20ca
Montana
^HHHBHDES
i.iJifi
■BSO
27.400
S:;garte&ts
202 a
Montana
1.s7£1
■ggi
34.300
—Hril
■^1
1.SDD
51.600
■■ns
4.430
:-.=
123.500
1656
■EB
[SSESBEHHI
StsteTotaJ
53.600
48.SOO
i^&l
BEtRitIBSBI
■ll^il
imasssiM
IgQgmHIHHH
7CD
msm
11.500
mm
RffifflllHimi
2o:«-
•lebrasks
22.700
23.0
521,700
17.5i
S'joarberls
iioe
■•Jebraate
SiE?Sili9HHHHi
2.8C0
?4.4
Tc-.oon
17.98
ISlSHBBHHHBli
HHHHHHKIiSl
aco
23.R
is.noD
16.66
4,300
21.2
61.300
17,70
[|^5>||^|j||||||||||
[i|]!(lg|||||||||||^
5.1QD
bBHBHIB^I
mwmm
BBBBBSSW
■LlIU
i-tebrsika
ElgB'ffll'SWa— —
10.100
■gfiT
■m
SSScSSHB
HilHHHE5)3
3.QC0
224
67.100
17.03!
2C«
tiebraika
no Combined Ccunl«
1 .D 0 D
800
msm
—ea
iSiSRSSBH
iiiiii^Ecinffmi^^^H
BHHBHEiSlin
Khfei
■EBl
gjl^lllllllllllllllll^^
flBBHBHEEIIS
Mtl;B
i3!^H33!M
MHHHBHDIiS
tmsm
■EH
EBBHSBB3B
lan
■■■■■■ESBi]?
■KOil
Event H7-1
Draft ER
248
Appendix D
7/28/2010
1458
CarrmM":/
Year
Stats
Count/
Planted All Purposes
(HtBasaftds cf Acres)
Hanreslsd
fThauMnds (?f Acres)
HB
ProduKiy:
(Thousands ofTors)
Sucnse
iPercen:)
7.902
7.3GC
28.2
10t.5DD
15.01
iSunarfeeets
2QCI6
Nsbfaska
S7.aoc
■SB
?uo3rbe=ls
Mrrfb riakr.-a
4.500
'IBB
■■■■Be^sos
HBi!
bMifggl
gratiiUHftgyy
DIDNonhissst
4nR.n
4.cC0
23.3
107.000
17.051
:S‘j£jarb6Sl3
2‘X8
iJorct Dalkcts
GfsSd Forks
32.000
3D.40C
S22.O0D
17-65!
■E^
waiHBai
■■■■■■■ISiiSl
73.200
■ig^
SRR&lil?!ISni
25.3
1,054.000
13.44
^BSli
im.
D20 Mor.hst?:
145.30D
25.C!
3.7c'5.0DD
15,34
Magg
■■■■■■Bniio
iD.7nr
25.4
272.07-7)
17 .7R
SuBarbesis
IQCi
Wonh Dak«2
D4D Wast Csntal
1D.3Q0
1D,7DD
25.4
272.000
17.7S
Svitjarbests
25C8
Mona Dakota
24.700
2B.4
951,000
S'OQarbeEts
im
Herth Dakota
■■■■■■■QiSijrBI
os.sOo
27.1
rK'.DOO
17.58
.^-oarbeets
Suce
.lil.l^!H!B!ItBII!llgl
200
ICO
KE!
mmsmi
Sri/aarbeets
2K8
Mcdh Dakota
DcO cast CsKral
RRIOD
51.700
1.S34.0DS
■las
JHtSaBBSBSE
■■■■■■■■RTIil
ICO
2D.0
3.000
15.63
triTiaiB.ra-j
3D.200
25.4
763.000
15.00
Suaarbeets
20ce
t-lci^ Dakcia
D60 ScuLi-aast
31.40D
30,900
25.4
7K..D00
15.00
Suaarbeets
2Q0S
!RH!Ii!aH?I
irf%i"H—i
243.000
2S.0
8.318.000
16.01
IRIflRHBBHHIHH
2.3fl0
24 4
56-.3DD
17.60
S-jqarbeets
Oreccn
2.300
2.3Q0
24.5
K-,30D
iT.ec-
bgiii'faaa
Malheur
10.800
10.300
31.3
337.700
16.08
|£uqarb&&ts
OfSGcn
DSD Scutnsast
10.800
1Q.8D0
31.3
337.700
16.00
ISuQarbeets
20C5
Drecjon
State Total
i3irai
13.1(10
30.1
3W.OOO
17.15
lari!!tll33ac«
SiiSSSilSSH
74.000
■■53
ii'Va^binatofi
D2D CsTTJa:
aDI!3
2.CQD
37.0
74,000
15.401
i^ashinolon
State Total
2.000
2000
fim
74.00b
■iffil
EoftVii.Tiyc*
»ii«i
11.300
■uni!
^■■■IIISSS^
■■iSi
■OB
4t.?rtn
■■E
KIWI
i2.eoo
222
2&0.DDD
17.101
MstSinca
KiSiSH
Q.1G0
17ca)Q0
nsrin.naiiL-w
3T.400
35.200
M«ltlri
703.030
■■£]
1.400
■raa
K,8ia
■■Eg
900
20.7
15.BD0
17.481
UOflFTiJra^
MM
CWHfflHIMH
2800
wnn
■KI^
raSFR»T!3I^
5.400
4.500
■09
■iHWBWlElD
MUII
WO^
state total
42.800
40.100
WEB
■■■BEHil
■BSS
•^tiPSTnm
1D.7D0
HE^S
TltM
KR'hli'lW-B
4,700
HiQ
HHHHHESS£SI
■KES
^£UTIi3l
wmmi
SCO
wmsm
23.000
■■ss
kffBiiSSi
3.600
mi
HPTOfRPi
:Kii
California
D51 ConbinedCcum-es
ODD
5C0
■CTl
25.030
■EES
California
25 1 San Jo3b.t.V*''s\'
21.D0D
23.700
■s
722.030
HEED
STBS
«aH
003.030
■HB
miTtia
Wi»^
*Firiu«>lF^^^I
thjiitwisprwmsnrea
23.400
23,400
■KHH
buS.oiS
BffRPI533
B’!il!!ii
44.100
37.1
1.838.000
■KS^
isa
KB
15.230
ISSgl^HIIIIIIIII
2.7D0
MBna
5S.100
■■n
■Bsa
4,3co
fna
S4.;aa
■Bn
■^1
SSElSSHii
ISBTESHHHHIH
2,200
WM'm
57.100
■■m
i.eco
■BD
^^11391^1
13.300
1^^
aw.ooo
■Bsa
Cclorab?
D2a NorJieast
25.000
24,500
M.l
£.[>3.033
15,08
1W1
SSSSHHIHi^^H
HiHHHHBSS
4fl6
21.C
055
16,51
600
23.2
11.000
15.34
^^^^jjBjjH
2.300
25.Q
6>oori
15.77
itX8
1.300
33.8
20-600
15.28
^SuISS
4.400
25.7
113.000
15.45
Ccioraio
D€B =as! Cemrul
10500
RM
—gH
HIHi^BE^SSS
msm
■m
Colorado
SE23I3SQHBIHH1
34.300
WK^
Idaho
SSHHHHHHHIi
2.300
■Eino
■■■■Ellis
■■ES
HHHHKSIiS
0.500
MKHPl
2K-.DD0
|^S3S9
■I^SI
KBHH
7.800
25.3
105.000
17.431
ISBBMH
SUSSSSHHI^^Hi
4.800
20.2
140.930
i&.es!
M6a
dsh9
BBHHHHBS&3
1,300
37.000
■ms
■ISIS
rishn
l.-tQO
■RijB
42.0DD
BBBfnRBPB
200
2Q0
IHslO
4.D0D
■■n
usm^m
Idaho
□70 Scuti'/rsEt
20.003
28.000
28.6
&&0.D0D
16.72
E'dCarbscls
Idaho
2B.a
S17.000
17.84
HHHMHISIiS
24.Q
45 .ODD
17.10
Mji-
Idaho
ISSSSHHHHBBli
BBH^HIKEliliS
13 5(30
25?
3K-.OD0
17.00
Idaho
!5i5!I5^HHHHHi
7.300
24G
IFTOnn
17.85
Sacarbeels
2ZC-5
Idaho
IHHHHKSSiS
42,400
23.0
t-1C4.0DD
17.82
Idaho
SSBSSBHHHH
■■■■■■ESIil
I0.4DQ
■waa
274,000
Kmi
Event H7-1
Draft ER
249
Appendix D
7/28/2010
1459
CoiTiTlDj'ty
Qjfiimiii
Courtly
IQI
SucTCse
iPercsnt)
BsriKnrF33M
H
16.800
■bibbebs^
BBKIi
WKiiiTSSII
■
ZS
2C.iO[5
24.a
#r.6Q5
lr.30
bRSRfifSSlSil
21.000
514.00D
1520
ESWIt.TfiftSi
1S3.m)D
131.5DD
taa
bbbbeessses
flflISIlSlj
WBKTSJSaCB
^^^^■BBBIEfil'T
1,500
■IS
2=,D3D
HEilj
iSwoarteeis
lllll
^ ■BBHBHHI
■■■■■■■■PTFrn
500
■Bail
11.000
iaiRERfnHE«
■ 1
■■■■^^■KTili]
acD
■ iiiiii
le.DSD
17.60:
kSI!KRJI33M
■i 1?!Iff!ISI9rem^H
?Min
2,SD0
■aa
BBBBBK9^BS
BBESBi
900
titti
BBBBBB^QM
BBSoE^I
1^3
1,3QD
■m
27.DSD
1720
KSTtFRJ^^SSIII
Hi isAnti^iz^lHHHH
22,3
49.D0O
Minrnin^aci
1S5.0C0
BBflBBBlSSEIil
bisb
3,573.000
Ban
baSRisra*
. S
R.ano
7n5-.B[)0
is.4n
(sSTRSSRSIS
■~n
52."nn
2S.G
1.2^7. 1013
15.10
WfJSiSHSSli
■1 1
33,100
BES
525.300
BbBI
wjrainyatii
■i ' '
4,400
24.1
105.600
1520
feSTSSiSBEH
f/m 1
41.=DD
22.9
646.500
15.50
IdftWitiSBIII
■P^
■■■■■HnEnsi
BBBBBBESGiS]
26.3
', i-i'"-7ori
17.BD
■i
■BBBBBES^S
24.9
2.514.50D
bSTRirarei
Hi "icftSHHIBHIi
1.70D
■B
55.7®
■ffil
»OT^i!nJ3C«
403
BBflflBBBB^Hil
BIBS
iSBIB
KPnFIiJRgP*
■
,1 “gj
DIO
337,033
iBBBBBEl&S!I9
mism
■BiBil
0RH!1BEnSi
■
ChiQDS>1i3
33.2r'D
BBBBBfll^SilO
23.2
747.300
■B
l4S?fiSBSil
I1.5DD
23.4
205.400
— H!
ggmgiglgglgl^;^
4.300
lES
11cJ30Q
■m
HH 1 T7**”nBH ^«i»r^|||||gggm||g^g
3,300
■mra
BflBBBBEI^&
■BB
4.100
flBBBBESi^
feS!RS*fS!'f!li
■1
■■■i^BBif?m
6.900
■*yy
14S,70D
issKFiiJra^cw
■BHBIB3i1Tf3
B.5C0
■ggi
234.000
■n
■1
—5
50,400
2».?
BBBU^^SkEE]
17P0
bwiRi;r'3ic«
WM
3,eDD
E5.7DD
mmmi
Kt»iHi*T44C«
H
1.100
1,100
2ia
25.2DD
16.90
feSffPlsSfHfill
.2C«
Minnescts
C340 West Central
137 000
126.2D0
■gin
BBwl
kSlAliilJja
16.300
25.e
414.B®
16.BD
toAOSl
RSTTSfSJ^^^B
■■BBBBERiTil
2,700
ii^a
61.000
■IB
MWTFTjiTTlPB
■ri: n
ftftflitSflScHHi
■■■■■HHcKTiin
2.300
26.5
16.80
IsSIWTiSTSSSi
mmi\
winiT3TaS^^H
553S
24.2
PES®
iFfii
WM
RfftT!TS35^^B
2 300
5!5..6an
■Hilili
iMl^J
mgUggigillQ^
2.100
26 2
55D3D
wrniTnra
Mnn^iH
D5D Central
65.203
53.000
■aara
BBBBBl^i^
■m
ax«
libnnescis
3.300
wm
■ffii
ISucarbests
2cce
iibnnescu
■n>M'<i..i.ii.ij.im7aFjga
eo3
5{!b
TO
HOT
■■w
2c-:«
Minnescti
tWil^9R9!nHHHHI
4inn
WmSG
16,60
'•^innpecr*
4DD
5Q0
BBTT
BIBBIilKiEliS
lL2fi
WTTO9!nici
W>l<»
State ToUJ
SDi.D00
477.000
^^^^BH:flAt|ili|
^KB^I
bWWtiTJic*
»»y.i
■IrffedrBHBHHHHi
2.320
Hi!]
55.000
HEB3
SSjlSjQHHI
ia!^
25.0
SsTS®
■m
gffpgjigfflB
WK^
I33IISS3BMIii^^H
2.ieo
26.4
57.DD0
17.87
Mcntana
SSESSISSMMBI
20 430
24.e
5D2.0DD
17.56
USSSSIHI
HHBIBBEE^
7.800
31.0
245.000
16,51
ba.m..!rHL-«
[iSHiSSEBMil
■^bi^bbess
4,466
t:4.fe
112.060
162?
—gM
[2^3IS!t9m
3.090
31.4
£-1566
tSTo
■Ml
[S]9S3t9il^l
7.920
28 2
2^-. 500
1561
D20 Conljir.fed Ccunl •»
.1?0
390
6.200
■C^l
S'jcarbe&ls
2CC6
Mcntsna
□90 SculT Cental
27.853
23.560
26.0
B52.70D
15.71
2£K<t
iicnsna
^^■■■■■B
■i^l^^KlESI
1.0 ID
Man
27.4D9
BBKIj
^eeiss
20:''3
'•Icr^na
1.3/0
T13
HH
fcg.MiJ4AU
^.ice
BBII^B^^EES
1.9CD
KEB
61.600
■HOSl
2D:fl
Mcntsn.i
■BBSSKCiSl
4.490
27.5
123.3DD
16.56
SuRsrbeete
■BUS
BiQSSSBB
48.500
27-0
t.3lQ.DDD
16.50
Sunartesis
ilebrsalis
7Q0
Ifl.i
1 1.500
17.76
Sucarbesls
2o:^
I'leboska
SSQSSBBBMHH
BBBBBB^SSiS
22.700
■Paei
BflBBBIBiS^
■Bill
Suoarbsris
2cc-a
Nebraska
SSSSSlilBHflBBB
■fll^IBHSEIiS
2.6C0
HW
TD-POD
BBBIil
S-Jcarberts
icm
Nebraska
IjSSBBHflB^^^I
acD
B^
BBBBHBIEI^t
BH3^
■ESI
SiSiSHi
{■{■■BBHIHi
4.300
21,2
61.300
17.70
iSiicarbe&ts
2CC«
ilebraska
BBBBBBB3313
3.100
fll^S
112.720
laiiiii'itsBai
I'lebraska
irfsaaiBS— — 1
I^HIHHBKSSiS]
10.100
23.0
■HBI^
Bil^
MSgei
Nebraska
.SR'BBIBBBBflIBI
■BBBHIBIiS
3.0C0
BBBflBHOSI^
BBEI^
■g^
BHBfl^BBIiliS]
■bihhib^^io
tin
22.5D0
WKMS
Sugarbssts
2'22e
Nebraska
ilitli'MlBItffBBBBBM
53.703
60.500
taa
■BSD
SugarbeslB
23=2g
'iebrasks
igjg^BBHBBBBfll
BBBBIIflBlSSI
3.300
■BS
105.10D
BHSii
Sunarbests
2CCc
'lebrasks
:S9QBBBBBBHi
i.eoo
23.6
57.700
15.76
Mebra^ka
Perkin*
■BBBHBIEIIS
BBBBBBBnl^
.ns.rcD
15.4D
Event H7-1
Draft ER
250
Appendix D
7/28/2010
1460
CDmnio2"::yr
Year Stale
■Zcvnt/
Pisrnsd ^ rurposes
{Thotsarsis of Acts)
Harveslsd
nboiisandH of Actcs)
My
B
rjOD
7.3e[
26.2
Hii'ini;'n'>"i>.uii.H
IKfFIEVlTVCl^BMBM
23,3
1.S47,0DC
■BES
F'.iaarbeirj'S
2C-C-€ Msrw Dakcja
l/Villians
4 50.'
4.500
23.3
1D?.00[
■nsoi
S^jQS/beels
SCC-a Ncrtri Dak.yJi
D ID Northuest
4.500
4.5C0
23.a
107.002
Sanarbesis
NcrtTt Dakca
Gra.’-id Folks
32.900
30.400
27.0
522.O0D
HH
Srdasrbe-ts
?3,2D[
25.S
1.Sg2.{H:'D
BBS
4!,e0[
■Bsa
■i^
1K.S)D
145200
msm
gmggg
10.700
■bbm^^
IIH^
D4D West Cental
10800
10.70C
23.4
[■Bii
Cass
26.700
24.70E
26.4
651 .092
IBBS
iSuaarbe&ts
2iX!^ [North Dako"-3
Traill
2920D
Sa.ODC
27.1
TSQ.DOr
IHI^
ISuoarljests
2K§ lucrth Dak.i3
nSO Cnnhined Cciinr-r^
2Ql
100
ann
3.000
IBE^
IKOTSWpilJdt:*
M li'i' IIPM llill'f '1 1
Dfin Esc Cenlnl
5510!:
51.7DC
ae.e
1.354.000
'BBS
1GQ
Biiia
3.000
IBSl
Miasi
30.800
7S3,DD0
■■B
iS-jasftiests
ZuCb (North Dakea
}05D Eculreas;
31.403
30,900
25.x
7K-.0DD
■1^
iSunsrbepts
243.000
Barn
iiiiiHiimiiiggg]]iii^
Hum
^^H^HHIiKETiSI
2.3Qn
BBiil
2300
2200
24,5
55-,300
■KH
^^■HB^HBrauTiw
io.aEH:
31.3
337./0D
■■B
■HHHHBKIiinTiil
10.800
31.2
337.709
BiS^
HffS'iRnHHIMHi
lIBHBBHBCCriTn
13.100
WXI
3S4.0D0
BBl
IflBilllfilEI
2.000
37,0
ZDOD
2.DDD
^Bil
14.000
Bll^ra
W'liMmsi.ii.TaHii
2000
■fcWil,
74.000
■IB
i£t;Qarbesi5
11.300
■nan
imiiiiiiin^^g^
BHi]
KfESpriiTiHCW
3I9!9R9I^BBH^H
2.2D0
MSI
BKSfE!
12.800
■BIBi
2£0.0n0
BBO)
8.100
19.6
1T3.00D
tsiikMm
37.4Q3
35,200
20.0
/to.osa
■HE)
giTSTiiHIM
1.400
■BW
Sj.SQO
|s-,n3fhepls
800
liH;
1S.BD0
BQ^
|4R.Mt.l44l-l
■SZSKHTIRnnHi
2 000
BESI
■■■■BESi^
H^
4,800
wKm
ebbb^s^
HSU
Mii»r.n»i-:-3t.^
w&itBitiini
40.100
Bk^l
BHBHH
1*{<11 1 iVS ilFHI
■■^^^■nfiTiSI
10.700
BE^I
■BBBE^ES
HESSB
■KifiSsi
■■HHBKfiilil
4.7CD
■BBI
HBHHBDSIISH]
^■ees
MFFSqi
■ 1 IMIlli 1 —
8C0
KBI
BBHHiSGiEI
amaw
■k^s^iisai^u^Mi
31.1
112.09D
wma^
RipniAi^^
[•ft
800
31.1
23.030
14851
21.0DD
:0.7DO
35.4
722,030
14.68
BB'WW t*M 1 1 wii ' PWH
■■■■■■BnBnii
23,400
■Hsmi
BBBHIMi
BBXQ
yi/iRITBl-'B
23.430
23.400
■kxii
BBM
wn?B5J51ii
44.100
mni
■K^
HfflBia
Ml IMIII n'M
1 iiii 1 1
ecD
■ndkll
BKHS
BH^nlBESiS
2.7Q0
linini
K.TOO
HB
umimmmQggi]
t:?®
■BBI
MZ90
15.061
Hg',|:ri»TJ4t-li
SSHEEHIHHIHB
i^HHiHiiS[!S
2200
KBI
57.103
HB
BBBHHHHSiSl
1.300
21,8
S8.400
■mam
H^^3S5SS9iHi
S9S!9HHIIHH^I.
13.300
335.033
BBE
amtmmi
■SESESQHIHlii
25.PD0
24.800
Kn
&33.03D
HSM
WSSS^M
BlBHIBEiS
400
HE
S.BOO
BBD
kgfiifflVTyjl^W!
m^^^ssssami
SmSBHHIiHHIi
SCO
■Heg)
n.BDD
MtUfiaiM'
2 son
58.830
gS5nS39
BlHBHHKEiS
1.300
WK335
27.620
fcSff!!”f!3l!.li:
HHHHHEBS
4.4G0
■Hi
BHIBOSi^
sssnjssi
aOus Ccloraos
jOcD EOStCeriirol
-.0.530
8.400
B5B
ii^^bibsi^s
BBSS
iSuasrbefts
2{]QS Colorado
iHFigTOFl—
HHHIK!3£II3
34.300
mzm
S33.00Q
BBS
;S-;ioarbe£!s
2iKl-5 Iriahn
Kda
2.300
HI3
■HHHBSE^!
BBSS
iCaniiOT
10.103
BHE
■HHEIBSE^I
BlHB
||lS53HII^IHBIil
7.703
BHHBKIiESi
1&5.DD3
mmm
WSWilHMi
liSZSSBBHHHHij
4.300
mm
140.090
HB
liiii^^^lSEIiEHHBl
BBBHHEBiSj
57.099
BEB
l^fSTSOTli
■mRBH
iSSSSBSBHHHHlj
HHHIEiSi
1.400
■EiiH
43.DD9
H^
E-nDarbesls
20K lldaho
ID7D Conbined Ccunles
203
Ban
■HHBHEOliEII
mmm
28.003
28,000
■gs
BiBi
30.500
HE
■■■■IIB^S&ll
■BiS
iGsxiitfl
zoos
2.CCD
24.0
45.DD0
17.1D
iiSSSHBHHHHIil
HHBHHBEIlSI
13.800
25.'’
350.092
17.80
HE^3!SSi9Hi^l
IliSISHHHHHIliil
7.300
24.0
157 .£>03
17.65
42 503
HHHHil^llDI
BiSfai
BBBBISl^l
BIHI
hhi
bhI
Event H7-1
Draft ER
251
Appendix D
7/28/2010
1461
CDfrmo^Ty
iglllll
MM
Plan^^l Fispo^
Harvsslsd
BBI
SuES'CSS
(Thousands c? Ae?ss)
fHiousands of Acres)
Bq
(Percenti
Sugarbeeis
x-:o
daho
DaO Scu&J Cent:^
107^00
107.CQQ
26.G
ZTSO.Ol'u
17.70
Siiasrbesls
2i>25
idahu
18.200
26.8
541. ODD
17.69
E'jaarbesls
Idaho
13.200
30.7
4D5.0DD
17.59
MBMS
ITBinaBBB
32.DQ0
25.6
1M6-.r-r<D
17.65
lill'I'IISfSSSSai
.'irtaAtet ■■■■■■
1^.000
167.000
KS
■HSSII
2Q0s
Mich-oan
320 Combined Courses
BOO
eoo
mam
13.000
■■BlOlj
!£-j03rt)esls
2G>js
Michpan
ikiiUBtSiTSSSMHBHi
eoo
21.7
13.0D0
17.10
iSansrtiesls
Mictflan
SSOnnHI^HH^H
1.000
23.0
22.000
i7.in
1Q.SQ0
20-4
22:'.DDD
17.10
IbRSl'iHSt-ll
Mili'i'i
eoo
20.0
1S.O0D
IS.Sfl
W*KH»l55a«*
tifei
_llll
3.200
lfl.,‘
53,03D
1610
S’-tjarbeela
2525
Mich'pan
1.100
22J
25.0DD
■■SSHI
Suoartjssis
Mit^tcan
dcliirf>!99nBHBBHH
17.000
2.n r
345.003
16001
S^ioarbests
2C-25
Mich pan
3.7C0
bhhhhesissi
■KB
S=jaafi36rls
252C'
Michpan
14.000
MM
■HHHBIESS
■■llliSSi}|
S'daarbKls
2-2€c
Mich pan
Huron
54^03
54,000
■■EBBS
S'jaarfesels
25j5
Michpan
Sa;'naw
15.300
16,200
20.1
525.0DO
16.80
S-jparbeels
r-5'15
Mich'oan
10.800
22 0
43^- non
IhflO
25jg
Mich pan
■■■■■■KlfiirEt
20.eoo
20.5
423.00D
16.90
Si'carbeets
2525
Uich'Dan
D50 Has: Cerrral
130.005
12S.3QD
■EES
BBBBB'Tnrtn
■E3i}
Mich.oan
■■■■■■■liTfK]
1.2QD
ii).4
S5.DD0
IT.oD:
“tV-*
■■■■■■■PfTlii]
fOQ
■KHi
5.DDD
"fV*-*
€00
Msia
15.000
■KP
25I!c
Mithoan
nsn ?niith nentraJ
3.3flD
3.200
W3]
ei.0DD
■BdI^
iSioaarbests
2DC3
Miwaan
^g^yilllllllll^^
■■■■■■■Rnii
700
■EiE}
■HHBHubEsS
■BSi
S^inafbests
2515
Mtedan
■■■■■■■■TiTilil
1.CQD
■K)ra
BBBBliiii^^^
wmm
i:5PFR!ri3E*
mmss
1.200
■ES
9SM
Bil9«
SffSfBxIiBBH
itfiitci AllilM-
2.0OD
■EEl
■■EBj)
WrSF!?>!33Sl
■EUSE
154.000
152.000
KB
■aaa
10.000
■EiB
■B^
i^riFn»y5acw
ft(nTiT3TOlHBi
aO.iOO
■K^
HTCRRBHHHMBB
18.300
11.3
216.300
15.50
pciiiikUiUjn
■ECS
TSfSPBI^B
KRinCRMHHBHHl
5.eoo
215
125.ftD0
■KEll
■Wa
XnCRIBHMMHHB
426DD
15.4
655.500
■Dsnil
man
nSnSRHIHHIHH
42.700
21,2
90:-.SD0
1T.70
►WFniTHca
or.eoo
101
t.-?74.40D
jSISSHBBHHi
■■■HHKiiTnn
1.100
msm
20.300
■■U
fcffllfcl.llltjl*
likaKi
.||.I«!!I!IWI«!B*
400
400
Tffi
7.4QD
■■OQ
275.C0D
Msm
5J225.SD0
■nsii
25C5
Minnesota
•fSfflfllSRiiHHHIHII
34.200
6».00D
■■SI
ARiTimaF^H
10.000
^14,5
145103
ICTl
KmTRta
AinnT^^vHH
3.100
Ha
WMMMMSW
■■n
MinnescU
2.2DD
54.300
■KSSil
Atfffrnap^™
3.S0D
6A400
■Bril!)
lyjFgHttgUH
■K^
5.500
25.6
1E1-.TD0
16.101
IS'Joarbests
20v5
MinnesQU
8,100
■BSD
wmnmra
wmsani
xiRmronBi
45.400
iB.a
£22.700
leSDi
2.800
1700
■mta
75.20D
■m
iSuoarbe&ls
2525
Minnescta
D<Q Combined Ccunt'Ss
m
rCin
■JiH
21.10D
■na
1 S’jaaffaesls
2525
MinnescU
WMMMBB^
116.200
■ES
■■a
IIIHHHMIBB33
13,100
25.3
34MK)
HBm
mmssm
1.4CD
23.0
il265
■■£@<1
QtSiSBHBBHIHI
1.800
24.8
44.700
i5.eoj
isns^Hi
H^^^HBESnS]
41 flnn
-25,8
1 [IT4.5DD
15.40:
3.600
■■■■■^^
■m
BCTTliiBfTCBI
tea
HHIHIHESiS
leoo
23.7
6T.e0D
IS.OD,
toW.Ht.lJJf
I£S33^ESSHMi
84.1QQ
25.7
1.517.60D
^^^S^9|||||||B
3 300
MSB
K-.1O0
■■S511
BBBnRHTBI
■jjjj^m
(SliSESsSHH
800
MS^
■■■■■■SE^
■■§353
S-yoartjeets
2525
Minnesota
D7D Scut-.y/est
4.200
4.100
■■■■ESB
BK^D
S'jaafteels
litCS
MinnescU
■liW:iiWill'i!!'U!l.l»!'f-U!ftJ'*
703
eoo
KS
16.700
Suaarbeets
2505
Minnesota
IHfl’lifiWiBMMMMWl
IjHHHHEEIliHi]
msm
■KiEIS
DakYsan
?.eprj
2.33D
20 7
4C-.2D0
IROI
■BSSI
hhhhhe^s
16.150
344.0DD
15.69
[SSSBEHHIl
Rcosevei
2.140
2.100
■IS
41.700
BBUS!
iS^jaarbeeis
{SQI^IjQIIIIIIIIIIIIIIII
2i850
20.220
L'1.U
43t.0DD
15.501
—gBSi
Q^J^QQIIIIIIIIIIIIIIII
gS3S3u^^HHHHii
mmniiiigiiiigi^igi
6.750
227.600
2225
l.tcnana
SESSSHHHHHIH
4.120
■KB
03.703
Euoarbe&ts
SVg
Mcntana
BSSSSHHHHHIi
2.5S0
Mgill
7S.D03
HBS
Siioafbeeis
2525
Mcntana
ye'CY^sssne
5.610
6.460
24.3
2K-,0OD
■■B
Siioarbc-cts
2525
Montana
DSD wonbh&d Ccuntes
200
2CD
6.000
S^/oatbe&ts
2K5
McnUna
DSD Scuft CentuJ
25.5BD
24,eeo
24.C
811.300
Svioarbests
2C=26
Mcntana
1370
■m
26.400
Event H7-1
Draft ER
252
Appendix D
7/28/2010
1462
m
Ranted AS rw|»ss
Hatvssted
EH
SucTuse
•rrhb^nds c? Acres)
(Thousands cf.4£rES)
(Percsn;)
Mii ii'irri III
|D20 ScuEh Cenfcel
26,0
27cDJ30u
17.79
HIHHHHBTSBniil 1
■BRSiaimiRiHH
^■■■■■KCTiTl!
13.20D
HBI
■HbI^I
32.QDE
«g!B'
■lEI^I
SuQarbe^ls
js tats Total
tQ.{K>8
■BBSl
S^joarbe&ts
2CC5 Ifr^icT-ian
!D3I1 Conbinsd Ccuntss
■BjBBiBjii^
■|g3g:
13.D3D
17.10
HcnGiRfliRiasaH^^M
eoo
13.002
17.10
MMMHmnrnii
icao
23.0
23.000
1720
■■■■■MRIiliSI
iD.aoc
iHn
HHIIIIII^HE^bBSji
^BlE!
■BwiasBaM
BHHHK^Kinn
600
IHB
■iSl
1i!feilA'ICTKff—
3.300
1B.7
ea.oDD
■BggOl
icSRiTisaiii
t.lQO
2r-.DL'i}
16.70
2'j2c- l(.!ic?T aan
1050 Csrjal
17.200
17.C0C
2D.5
54-5.0DD
16.501
ISWJSRiRSSlI
3.7BC
1^^
■BHHHIiSEisI
Ktm
BWSSKEII
l«ifS!!RB*l
ll^SSIIIII^HHiiHAH
14.CD0
WK^
■BB
■ClfSRMHMIMi^H
54.CD0
22.6
1220.000
17.10!
15.200
23.1
325200
16.B0!
iB.aoc
22.0
4.15.000
rassiiJES^
2D.eDE
20.5
423 .ODD
16.BDI
wspcn*!®^
It* M 1 KdvTtKTTTST^ HHHi
132.0SD
125.300
21.5
2Jc'3.0DD
■kb^lXKKnRHI
iraTBTSRMMi^MMl
i.eofl
ie.4
33,000
■B0
S^/aarbests
MCibfjiXigaiwaaM
c'OO
■KB
6.000
HBiS
mmjffnBMMBMi
6QC
IMil»lil
1S.0SD
WK3M
loao Scut-. CenF3)
1300
320C
6t.DOO
HBSWSHS
700
■EiB
14.000
IMiliKIl
2j.DDD
■BBS
■llll^£iifi;^SS!illl
i,a}o
!■■£€
21.0DD
sss
ixiif^RSIWSHHHHi
3.80E
laima
154.000
152.000
IKE
■iS
lO.CQQ
■IBS
■liQSSi}
M III imii.!iiJiWf
54,1B6
IHB
HHHKSBSE^
■KiSD
INTasnBHM^^^M
ia.30D
IBDE
Hii^
nmnifCfSPiMiMMBi
5.cQ[
IM^
■i^li
SRRntfRn
ISSE^siHBHHBHi
HHHHBSQSI
42.eoc
IKH
■BHIi]
Ml ll'll ll'l'l llll
m'~'i'(
42,700
IKE
HBHHCSiSS!]
WMSB
t:«:FI!ST35CS
■HndteiixirnTf^M
67.500
IBBIH
■IBM
W.tntTrjjM
Mflll HKI.I.I-LMIlM
I.ICO
IKB
2!0.3DD
irU/.MoltlrJL-l
[■llilalTSI.IRTTtliRnTTIV^
400
laiiffi
H^H^BHEEniy
HS
IniDNanfsN-sst
■iBB
BHBBI It'*! 1 ''H
■KBOID
■iii^iSi^ixnitrmsii
IHKB
■KSl
lO.COD
IKS
■KSI]
{spr.vruHJcH
^■ttlCISIIAOiTTTKSH
Stoff
IHBU
45.500
■KEQ
IHKSEiixrsr^bSSI
■■■■■■■Eltlil
2,201
IKE
54.300
M^^^BBKrrrn
3.S0C
23,5
R'54r.0
■n^
riUHHkitariBSIlB]
5.500
IMiaH
151.100
16.1QI
^■diSiMIAIf(T!T^?Clll
i< 1'"
&.m
IHBaO
114.5DD
■HSU
JWIffi-TTJCl
MoeeiixtirT^Ev
45.400
18.3
52S.7O0
■BSl
mmwsammm
2800
2.7CC
IBESB
ISJ22
■nEU
ODD
SOC
I13B
KjEU
iMgggmgw
115.600
116.20C
HBi
■in
SBiSuESSli
SSSSSHHHHH
i5.i68
I^BE
HBHHIIII^ESB^
■^n
SSESSSSB
iSSSS^SSBI
SI^^HHIiHllliHi
1.400
la^
jSSiiSSl^l
i.aoE
IHKE
44.700
HEMil
SSSISSHHHHHHi
HHHHIKSI19
4i.eD[
25.8
1.074.5D3
16 An
ESffB-HSHB
HE^SjESSS^^^^I
SiSBHilHHHi
HHIHESiS
3.600
24.5
£•5,600
15.DD
§l!^3u9I^^HHHH
2.r;co
23.7
61,600
TOP
fcflSklKIJJM
iMKggaffl'HitffjHgei
IIHHHHIli^SIlS
^ KlQO
1^^
1.647.600
EBBfCTSBi
!3SR93I9HHII^^H
HHHHHHEEiS
3.3QI
Hsa
HJiE,
BBHTBRHB
lllllll^^^l
SSI]IS!SSS3£l33!S!S9ii
BOO
SOI
IBEB
■BSiii!
IH^^SZBSSSSSH
likuildSliSnf’Rl^^HHi
4.200
4.1CQ
l—BB
.■KB
;il’J;i»gT5l.!l.!J.I*lt-ViiBMi
j^^mmiiiimgig
laBS
iHIBS!]
iHHHHSmmi]
,■III^^■■■^]GQ£
IBBiEI
l■■Ki£S^
WtKSM
2.331
IKB
46.2D:
[SSSSEHHBHHHI
li.lOE
[■BE
344.DSl
l■■IK^
i&JslMcntsna
jumumiQQ^
2,100
IKS
41.703
IHIB
22.833
2U.C2U
L_2in
431.533
16.58!
i ISSEOEHl
SFBSSHHHBHHIi
B.76D
iBBSS
i [SSlSSHli
SIEISHHHHHH
4.121
lEB
62.700
16C[
WBXl
I■HHHHHE9!1S
8ffPi»S^B
IHESSSSlSSsSjH
HgBWganil^^—
5.610
B,4fiQ
IHEB
l:S5K!i»!J4M
lihtti*gf5till.y«l«^4>.iT^M
20D
jfifl
■ 3D.C
5.dd:
16.43
SSSE&S9
2vv5 IMcnana
1080 Scuti CemrsJ
25.530
24,560
611.330
[■■Bl
1.37E
25.4DD
Event H7-1
Draft ER
253
Appendix D
7/28/2010
1463
Corrmoriy
B
Rsg^il fiS Rirpases
fn»usarKte fx Ac?^)
Sucrese
\?erc=nt)
HK^
i07.a)i
107, GOG
17.7B
ae-sa
Idaha
Birvdtam
ie^[
18, BOG
28,21 54T.ODO
17.S6
ISuDarbe=l5
Idaho
POrtSf
IS^D
13.2DD
30.'
I 4D5.DD0
17.50
imMHH
32.5®
[■(■■iHEiRSIO
26.61 046.0®
WU!^
■■■^■ETi^TitiTil
167.M0
HS
{■■illlK^^E^
MBSII
2',v5
f.lifiii pan
D3Q Gopbir.ed CciMit-sS
eoc
■EQHIIIIIII^HHKOPl
■Bm!
Midloan
eofl
■SI
■BBD
♦:9r*-n.733E*
wmm
ISiillllil
■■■■■■■ITftt?
1.000
23.0l 23.DDD
■1^
[TITITM
IHHHHMMBll]@!l!!
20.-
22‘"-DD2
17.10
20.G
[ la.DDD
■jj^ll
Mich-ean
Midland
3.20:
3.2QQ
Bi^
{■■■■[liggligg
ISuoaibeets
MiciirQan
t.tcniiain
t.io:
1.IPC
■^1
l■■■||^^^SI^
■KSSi!
sR'W»-W4ll
17.200
iimiiiiiiiiiiiiii^ig^^
■RE
rviyono
:W.W,.W:5C«
Bjjj^^
2.3 r
57.000
1720
14.GDD
16.
255.DD3
15.50
■ii[i!if'
iXTin-n—
■■■■■■■Efcnii
64.000
22.C
1..223.DD0
17.1D
K£
■■■■■■nXTifil
16.200
Mat
■im
OTKTiiiaa^
rniRlM
18.200
■1^
IHHIHHKIS^I
■KEOi
SKuMuTstSt*
T”
iR99!!SVHBHHiH
oa.eoQ
mssM
W»MnlJjL-|||
060 =as; C&nira}
130^0
125,300
21.£
2.760.000
■IK)
W«^
I.®!
l.gfiO
16.4
35.DD0
fflijaiasaa
£00
18.0
6.000
17.60
®D
MB
MSB
3 3nn
3.200
■Ei^
1 1 ii II
700
'SBSSS^ffl
■■E]
tltailHM
1.C00
1 2Q.00D
■DoDig
^•Wi444li«
n ii4i*i • K
1.200
17.C
1 21.000
17.30
iS'Jaafbeeis
Mtedan
■i9ii»!TiSEVnBHHBB
2.C0D
||^^^■■l^^l!!^|
16 ■’0
Wi]<^
Slate Total
1S1.000
152.000
■BE
■B
yil!kii>144‘^
Altl1ilJ4>lB[Hi
E&:ii=r
10.000
MWE
■i^i
^l^7i>144l!li
mn^
57.0®
56.100
■Q£
IBMMKSSSBjSI
■K^l
18.300
miif
\mmmmBam
■KBSH
l4fcsir»T43t*
mm
AibirgnsnTflHBHH
5.eCD
■l^i
■tSE
■39S
ArfrtifySSBH
■■■■■HnVTilil
4? eon
■IK
■nxiii
KW'hh'WVr®
MM
■■■■iHnciSttt]
42,700
2U
1 BD5EDD
17.70
gBkli.lJjH
■4^
07,500
IBE
^^HHEISEEESi
■BBdl!!
w'i*Mi‘i44l“‘4d
Mitea
■■i^^^Breniii
1.100
WKM
^■■■■^g^l
■Kffi!]
Minnpsftla
DID Cnnhined Count'^s
405
iOD
■iS§
{^■■■HBSilSI
IS’joarb66t&
l.^itinesctJ
210 Nonhiws:
.3.0V4D0
275.000
■DEE
■■■^^^QiS]
■■3^
l4*1<Mi>1414
»g5g
iraSJWiM
34.200
25.C
—11111
■i^
ni’iiii^i*il^^l
1D.QDD
14.£
■■■■■EC^S^
■lE&B!]
R»^•Hi•^44^■
3. ICO
15.3
■m^^HESQSSI
■iSCQ
tpf-T-TiTTJcii
fflSTtWSS^M
iHHU^BHKETnil
2.2C0
K6
■■BHIBE^
■m^
3 200
mm
■■H^BESEiE^
■BSH
ffliMiBSa
MM
6.103
5.600
mm
HHHKEEiEEl
■m
nNlll<-44*l*1^H[
6.100
■■3
wmmms^M
mSEEil
i£;Mt>[44n
MW
■naa
■m
MWM
lAdS^S^HriH
2.003
msm
■B!
Mtia
'.linnaects
3-sO Conbinsd Ccunies
POO
HG
HBBHMBCIiS
■KiPl
MWi
uBu^SSHH
iiv.eoo
HHHHHDBSiO]
mtm
■■^■BESSES
BS
^SSu&SSI
ISSSt^^lHi
Sl&!!&3HHHHBHi
HUHl^^lHEMlilO
wmm
■■■■EkES^
■WTT1
2£XS
Minnesota
HIHHHHSiS
mm
|^^^■■ll[^^g]
rntmn
“'.snarbPfiK
2^05
dinn*>;rf\
■EQQ
■m
Sunsfte&is
dinnperta
lenvMp
42.100
41.600.
25.C
1.074 50DI
■B^Stl
Suoarbes^
2CQz
Uinnescts
Sfoey
3.700
■»aH
■Eilll
S^4CI3ft£$SS
2v2c
Minnescu
Steams
2.700
mm
HB330
64.100
25.7
1.647,600
■■1^
lESS'EloSS
^ed»TCod
3.400
■B5
IH■■■ES^SDI
2205
370 Conbined Cttont-s-i
Ron
■ES
|^■■■■l^ss]i
■ssn
S-uqaiteeis
20C5
Minnescb
070 Sout5«5St
miiiimii^H|Q§^
BB
S-joarbeets
^COs
Minnescb
7®
mm
BSil@
Sugarbeets
2flOS
Minnesota
StateTota!
49f.000
mm
WEM
2.003
wKm
BB
tiiifk!!i,'‘lMWi
■E^
■313
i£5el
^|^|[|[||H
■IQggll
WBSSSB^^Mi
mm
SS^jEHHUi
Bis Hem
0.293
8.700
2a,6
■■■■^raj^ij
■■^Sil
mssami
Carbon
4 2R.7
4.12D
227
fi?.7r>n
16.B2
Suoarbeels
220-:!
.Icntana
2.600
261
7S.00D
Syqafbesls
2€>2c
.tcntana
Veortssns
E.81Q
8,460
24.3
201.000
15.56
Euqarbsels
2-J>z
>1cnt3na
200
20D
3D.C
6.DD5
16.43
£-:ugarbests
.Icntana
D30 Ecur. Csnt^ I
25,5®
■BH
Blt1l|
S-joarbssts
-Icnnna
Cus’.er 1
1.300
■■■■■■■1(^1
H
■■■■■S9!^l
Bf^l
Event H7-1
Draft ER
254
Appendix D
7/28/2010
1464
ContmDi/ty
&Tak
Planted Al ruqHises
j^H
{iltKissn:^ Acres*
S'jaarbesis
Idaho
D30 Scuih'Centci '
107 jOO
1D7.0Q0
26,0
2.r3G;.DD3
IT.Tt,
Idaho
tB.SClD
mmm
■■■■Eil^B
■BMI
KSS
■■m^iHiEiSiiji
■■B
■■■■isra
■KB^I
Wditii
mCMMl
32.000
?0.e
Wc-.QDO
17,65i
Wr!ff*!T330
WltiKI
ITPTRIBBli
State Total
10J»D
1S7.0DD
■HD
■■■E^SIM
Wmm\
■rfiWd
isiiiKnsnnrssiffanma
SQD
eoo
21.7
13.DD3
17.10
iW^
■idiURRI^SBBBH
fifio
21.7
12.DDD
17.10
:S-jaarbesl5
Mlcrtaan
cPSVn^^HHHBH
I.COD
23.0
23.000
_ irj2D
X^SItinBHi
spsneniHHBBHHi
iQ.aoo
■EiB
■■■■■^^^9
■nsEii
i4K>k)i>l44Ca
QGD
2D.0
13.Q30
15.80
AdartStRIl'^Hii
SJflfi
1S.7
S3.DDD
gBaMi
TTIini ll
ncQ
22.7
25.QDD
16.70
Suoartieets
2’235
Mi^'ban
17.0DO
■■■■■iiga
■m]
&c5arbeels
Michban
3.700
■■B
FJ.nort
■BgI^
Srjgarbests
2C<S
filitb'oan
■■HBMHRIETrSl
14.000
IKED
■■■EDBSEI
lassiiffl*
■iS^
SIRTnHIHBHlHi
■■■■Effl
54.000
■HS
■BSi
iwiaiiiiPia
tmbi^
iS.5b'6'
■Kill
■m
WM
dRBRBHHBHHHI
tO.SDO
433.000
I6,a0!
SlfmSHIBHHBi
2D.eOO
20.5
423.0DD
le.BOi
lsRBS!iJR2(^
■as
2BS9Hi
(t>)itd;e3«>9R9!nB*M
1S2.K>3
125.200
|^■■■■ggE^
wtmm
IOjc
Mien oan
1,500
■109
35.033
■HU}
Suoarbeste
2'-l€-c
Mic?i qan
Ionia
500
500
■GQl!]
■■■■■DSIsS
■m^
Ptmarbesis
7s:^
SSnPRPBHHHHHi
SCO
■SB
■■■■■SO^
S^jnsfbefiis
2'>’-g
Mici pan
f bj 1
3.200
■HI
ei.noo
■■■■■■■■fTiSI
7CD
■B
14 .ODD
K{i?ncTjiYij^l4
lUSfi
KB
2:-.D00
■KBiS
WS?=!»*I4=5l.-«
xiKrmHi
1.20fl
17.5
21.QDD
17.30i
Has
iTiliUnnSVR^^^^H
2.fiC0
■BB
■■■■■ESG!^
HI!Si3
mim
154.000
152.000
■■■EI^X^
■IS
WKSSiA
IO.CD0
20.4
202,600
11:20
AhtTtTifdHBB
■■■■■HnTnt&l
58.100
TTI
■■■hd^^hi
■KBB!|I
|l5Sfr?r»5t#5Efc
Wi;i!i
All' 1 1 1 1 1 ^
Sb.eOQ
■■■■HEM!]
■DB
■■■■■[ggggi
W4«l
xei.TCTsrR^HHHIM
Min
■■■■R^l^
■nsE
tegfiEntrascM
Minneseta
42€DD
15.4
65? .Gr*!!
mfi
iS^joarbeets
2C«
Minnesets
.12,700
■BB
■■■■^gQm
koEQII
B?!p?nR5ni
Mi^^^H3iXTni1
07.QDD
2D2
1.674.400
17.B0:
WR»iMr3’^t-w
All 'I'l^lM^
iSlEISHHHBiH
i.lbb
■lEB
S.5bb
■KQ^I
iiiiURTSHrinsi
403
4D0
1S.S
7.400
17.BDi
HBffligCTI
DID Morhtv’s^l
33T4DD
275.D00
HBQ
■■■h^s^
■nail!]
biir.klt.144l--*
M’TW
AlTiTiTrEffl^^Hi
■OSYiBVnHIBHHi
^■■■■kucIsq
342D0
25.0
65S.ODO
15.801
Ptir.Hi.I44L^
10.00D
14.:
H5.203
18.10I
Kt«Ib-Ii'r=Wt«
2^
Minnesets
S.iCfl
■Kgs
■■■■■at^
wir.Wi.iyW
2.200
■■■■EE!^
Minnperht
■■■■■■KPliSI
3.SOO
Mil=H
■■■■■^EMl
HsEil
IS'jaarbeais
2C’jc
Minneseta
5.60D
25.0
151.100
■KSQ
wnTFTiiraca
AHiTiTTRS^H
B.IOD
HOD
■■■■DEBiS
HSai
S'.ia3rbeets
iSic
Minneseta
■■■^■■iKnnisi
45,400
18.3
522.703
16:SQI
S'jnarbeels
2'Xc
Minnesets
Vfe.bi’/ W5-:icirtT
'»GDn
27nc
■■■■■|||^(^
■mi
5<in3rb»is
•'.rrjt
Minnesets
Din -r/^nhiried CeiintP*;
003
mm
21,103
20,5D|
S'jQarbeets
2CC5
Minneseta
D40 Vi'esl Cenl-a)
115.803
20.5
2,314.403
16.2qI
2ZCz
Minneseta
■^S
■la
IHBS3
MK3SS3
|■■|■■■QgiS
23.0
32.200
15J0I
laoo
■say
44.700
i^KSOIill
nasa
Minneseta
41.eOQ
25 P
t.0?4 500
nm
lE'jgarbesls
22C5
Minnesota
IHHHHEBiSI
3.CGD
£3.633
■K
Syaarbe&ls
22-’lo
Minneseta
■SB
61.633
ea’6ttu.H3KJ
^^■■■1^^019
25.7
1.61?,6D0
15.30:
i^BSinBsa
■sbba
[?niStB9!nj^B
■■■IH^E&iS
3.2CD
27.3
63. IDO
■■SBil
£u<13fb6=ts
I’JLi
Minnpsnts
D7D ConbiricdCcunt-ss
eon
aoD
24.3
Iv.'DD
■m^
SyaafbBsls
2C\.z
Minnesota
D70 Soutny/est
42:03
4. IDO
■■■■■£ 3^9
I'lW
Suaarbssts
22^
Minneseta
l■{t{;l^Bta^^.!3tlllB^.wMi
703
sai)
MtHB
■■■■■s^
■■BB3
■E2£3
State total
491.000
4G0.000
20.4
3.384.000
17.001
p!SBi
2.2.in
■EiB
45.20D
■■P
'i.'.’VB
Montana
ISSSSISBHHBIH
^^■■HBES^l
1B.10D
im^
344.000
■m
|S‘jgafbsEts
ISISjS^SHlii
F?cose*‘fiiT
2.14Q
ziao
ie.s
41.700
16227
Is-joafbeals
:|SI32S!i3BMii
D20 JJonheas;
22.853
20.520
MHia
431.630
1S.5B
■BBSa
'SSI^SEimi
iSlIilHQMHHHMI
8.700
25.6
227.603
16.44
Msaai
nii^^
SSSSSSHHMHHI
4.I2E
■ISS
&3-7D0
■■BOSI
tmam
iSSSsSSIBH
2.seD
26.1
73.003
16.53
ISSSSEHHi
s.eiQ
8,430
24,3
255,000
16.56
■ecu
likiiblRI.II.U.ItUllilljEfll
203
200
3D,D
6,000
15.43
2C\^
Montana
DSD Scut? Central
25,583
24.-00
611.333
KB
1.370
■S
36,4DD
■B,64i
Event H7-1
Draft ER
255
Appendix D
7/28/2010
1465
S^ate
Count/
^ rurpo&es
•Tbajsands cf Acbs)
Haa-sslad
fiTiousands of Acis'a)
ITons)
rroduKiai
(■riiDusands ofTorts)
Surae
^Pen^t)
2CC-5
f.fcnana
1,530
15.2
23.300
15,34
iS'uaarbsets
2£^:s
'.fcniana
1,520
mmm
■iBI
ISvaarteeis
-<v^.
Montana
4.320
20.7
85.8DD
17 nn
MBiliB
State Total
53^Q
49.$00
22.9
!.143.00D
17.4,1
2005
Nebraska
Sseiner
800
1B.S
12.O0D
16.70
SyQSfbSBtS
Msbrasks
2D.2DD
IB.3
3?3,4DD
15.70
Suaafteets
2'K5
I'iebrasks
2.600
18.C
52.100
17.40
E-:jQ3fb==1s
Nebraska
SCO
10.4
OCDD
15.60
'Ji’V'-
Nebraska
2500
22.4
55.BDD
17.20
SBSBtSSBl
mmme^
XBlfHHBHHBHBBi
S.0OD
19.g
Tl.ni'O
15.40
(cSfJSTiilKlH
e.7GD
22.G
-47.100
13,00
WRIFJi5!3S£il
uraflsssaMi
2400
1^^
mmmi
mTSiVtl^
603
500
MSB
10.700
■m
laWRftJracB
40.000
Mgna
SDj.DDD
*6.51)^
3.DG0
■■■HmO^
■HS!!
1.CC0
■■■■■I^BI
■■B
tottwiiiSruai
Nebraska
1.300
hes
ai®
■HBil
iS'jqarbe&ts
Nebraska
5 POD
5.3Q0
■■■■■Ig^^
■Hiil
JiTffflRSHSl
■niiin
State Total
48.400
43.300
20.4
924.008
16.40
WSI5PRJR3S*
i.SGQ
20.0
95.000
10,14
DIO Nanhft^si
5.003
4.SQ0
20.0
8- ,003
10.14
»:fll8Kfi»6SSi
tm^
tlRlSenHHHBHi
100
■iSg]
l.aOD
■ulE
Biioa
MtliH
■■■■Eau^S
■IBiS
Biilie
■■■■HHBRiVTnn
74.700
■IS
^■HDBEESS
■■n
nuEH
lUMMilMESliEI
42.000
20.1
644,000
16,40
fsPRERJ^BHB
SPHnltRIW!*
ilililSSRSfSSaMHHii
147,3D£}
1T.S
2541.000
15:13
IHiSliHS™
tD.eoo
■^B
■■■■11111^3^^
WnMitEHEM
IWi^
1 iM 1 UAn? vaPiTrSH^^H^H
10703
2:v5.onn
■Km
lI'!T»atl!l!iSM
^IHHHIIIIBEi!3
23.CDD
20.6
4K;0D0
■m
liiJliAt|r|!fAj.W
SIS9HHHHIH
^^HHHIHKI^
100
HIE}
2.DDD
■Eg^
ItiMliHiKgM
ScSHHi^Hi^^Hi
28.400
■Kiia
MEElJ
liWtSliHggM
53.70D
31.500
2D.e
l.D75i5D9
17.QD
2Q-;s
ilBjSfiWBSW
2B.700
HEeI
516.003
16.41
flHIwligmijM
20.700
isn
51; .003
16.41
SS^ESSSSI
■BIE3
niaiiiiMwi
EISSZISliHHBHi
255.000
243.030
18.8
4.SS6.DD0
18.00
^SSDSSR
SIS^ESHI
SSQiHHHHHHi
iiiiiiimiiiiiiiiimi^gj
—taa
51.500
■hq
fai|.HI.!-!!3M
SISSHiBH
2.GC0
25.8
It55&
■KEE]
ISISSSHIH
^^^ISSSSSSSil
BhBBBhI^^s
7.700
.33.7
255.500
16.31
Ofs-oan
I^^HHHHEEOS
7.700
255.500
16.31
200S
Orecon
state Total
5.600
9,700
H31
311.000
^■QSl
iSuoartiesls
kVashinato^i
1,700
65.000
■Has
kiw-Hi-njai
hhhhhhbis
1.7C0
IHQ
J5®d
wmw
EffSiSS
liJU^.Ii.fin.r.M
SSSEESKHHBHHI
HHHHHDQiS
1 700
■EOS
6S.OOO
8 200
22,3
163203
■nsEEi
ISSS3S9I
EiSESS&^^H
SSiSSBH^^^^I
3,100
22.8
TO.BDO
l7.flB
GSSQ^HH
BHHHHiSIiH]
12.100
222
265.0DD
rf?5
«i&T1
QSSSISi^HH
s.eoo
23,0
565.56fi
17.27
siRsismi
32 000
22 2
725.500
17.63
2^:-5
1.200
160
15 200
1623
@5553!SSB
2CCS
AVccniftj
EESS!83HII^^HIHi
eoD
■SB
12.300
■iS
Bff»STT»ro^w
diJJSJSSHI
BESSHHHHHHI
2. ICO
■DS
41.6&6
■KBiSi
■HKiaa
cns9Hi
ri'Llil.'Sfll.TCR^^^^H
^IHHHEKlIiS
535
16.6
75355
ITBT
RimPHTM
— j»Ea
CZSSSiSHi
SSSISlIlHHBi
33,900
50
801,OOD
■KBSI
Event H7-1
Draft ER
256
Appendix D
7/28/2010
1466
CorrmsiTy
Q
Pktied ^ Pt&pases
tThojsa^ds Acnes^
Har,estsd
iThousandz of Acr^)
BBl
Frcdusbn
{Thousands of Tons)
SuCIKr
{Fercsn:)
Sygarbesls
■Hiiiti
AV^StlleVHli
1.530
15.2
B.33B
15.34
S^joartieeis
AiilinKiilcVHHi
1.92Q
,2a. 1
52.10D
i6.ea
S'joarbeeis
■1^
DOD Sc'jth-as:
5.4K-
•4.32D
20.7
SS BDD
17.56
Wn«FT»»n3Ei
State Total
S3.StK)
49,300
22.9
■■■mEn
17J1
IS-iioarbeeis
Msbraska
■■■■■■■■ninfi
acD
wmm
12.5DD
ISiigarbssls
Nabrasks
dntRcra^BBBi^H
■■■■■■Ennni]
2D.2D0
tB.3
3&140D
16.70;
■■■■■■■snTrsi
o.acD
52.10D
l.'ituiTarfaesIs
2rr:^
ffebni'ka
son
KB
6.2DD
BHOSj^jl
IS^jnaffaeets
tlfibraeka
2,5CG
55.0DD
172D
liSSBH
3.6Q0
19.9
71.70Q
15.4D
Siigartjssls
F'lebRiks
6.7CD
MffiW
147,100
13.90
Is-jpartisels
2!?a
riebrasia
dISSHEmHBBBHi
■■■■■■BBRiTfl
2.4CG
ItMl
55,4I>D
16,60
BEJO
SCO
21.4
10.700
16.10
Syaarbssls
2\j05
Mehrask;;
D10tJDnhvi»s;
42 5tID
BBHiHHS9@!!!l
.?n2
SK-.DSO
16.50
StiaarfaeBls
2CC-5
Mebrasks
3.0CQ
23.6
7D.B0D
15.40
S’jgsrtseels
2S'r'5
NsbrasKs
l.CCO
23.5
2i,5i:<S
IdjO
S'jQsrfaasts
2S3
Hsbfasks
1,3G0
1B.2
23.7DD
15.10
S‘2aarfaests
7.>yrt5
MebrasKs
n'D SoiithvrfiS't
5.&D0
5.300
■■■■■■B^I^S
■IKSI
inil.W<i!x!4Cl
■RiliP
7BSH?*
Slate Total
4fi.40D
45.300
2D.4
524.000
ie,40l
Suaarbeets
2205
4.600
20.0
63.DDD
19.14I
Sanarbeels
20>::5
JWililiiMSit*
4.600
Mgtia
■me
5‘jQ3rtie6i5
2005
iRraroiBfi
100
Hi^
<.500
■ms
si9!nt?i!esa
■EiB
eZI.ODD
15.031
|S-jQart)eEls
sjnjsiiFisii^s
■■■BHKPETTS!
74.700
15.7
1.174.&SD
I622I
Is-jpaftiefits
42.000
MgiW
■■■ebesi^s
■IS
raSSiMpSiai
traaiBigai
147.3DD
17.G
2.541.000
1E2SI
W,5I.HR*»
10.700
lO.eOD
■ESS
fcwnwiggatrM
1D.7K)
ID.0DO
22.3
23f-nnn
IftfiRl
BIHHHSISiS
23.KJ0
20.6
4&:=.0DD
■K^
iiBiaififflB
Steele
too
too
■j!|!|
2.000
BBSS
SSlHHHHHHHil
2B.4DD
20.6
5&3.00D
.. ITBIJ
WKS^
[EBiuBESSH
53.700
51.500
■EiS
SEEi^^Qsggggi
l4H'ii.'i»BBSi
HHH^HHoESS
20 700
i4.n
5ie.0DD
16,41
29.^0
m
515 .COP
16.41
Sunarbeets
2005
North Dakota
5 tale Total
255.000
243.000
18.8
4.5S8.0DD
18.00
:S7jQ3rfae£ts
Ors-scn
[ijjlEQSIIHBHiHii
iiiiiiimimiiiiiimigQ
2.000
35.3
51.500
1S.30
gj^SSHHIi
□30 Nonhessi
2000
25.8
15,30
2005
Qrsgso
HUHHIHiEEES
wmmmmBm
33.7
255,500
16.31
ysliKiHjgi
7.700
33.7
255.500
1B.31
■BliS
QSSSHBI
SSS^OHHHBi
S.70D
K2I
31I.OOO
■KSZI
snssEs^B
lai
sn^n^sBi
[^S33HHHHIII^H
HHHHHDBIS
1,700
HiB
&5.000
»3ga
1.7QD
tiW
BBffi
BlJJSJIEISI
1.700
MTin
69.000
2.V5
ti'Vvofflifw
HHHHHKBiS
8.200
22,3
153200
17661
IBS
SSSiSH^H^H
BHHHHQnS
3,lQQ
MBEH
70.BDQ
■Ei^
SISISiSHH
HHi^l^KSSiS
12,100
igw
555155
■m
iBga
QS^SSSHB
s.ecQ
■Bam
205.500
WKS^
Mm
S^SSSHH
□ 10 Northwest
212DD
32 BOD
MaUH
725.500
A'vccnitft
SESiSBHBHHHHi
1.2C0
■EEl
19 200
■n@
SSIS^SHH
S!Sx9HHHIIiHHi
HHHHHIEiS
fiOO
lEB
12.3DP
QS'SiSiSHHI
SESSHHIHH^I
HHHHHHIB&S
2.100
16.5
BHBBBEBQ^
17.321
SSSISZSHHi
^I^HHIill^KllIjB
3.600
■S9
nm
BBEES
ISunarbeets
2{H5
Wyoming
state Total
35.900
Mt.Ooo
■QSi
Event H7-1
Draft ER
257
Appendix D
7/28/2010
1467
Harw^sied
s<m
rrcduccioi
Sucrese
{Thoussr^ csAcs^s)
nhotisands of .^c.'es)
{Tores)
(Thousands of Tofis)
•Percen:)
1.530
mSm
22.,9-2d
£=iq3fl3ests
lUontana
Rcsecud
Z330
i.sio
BO
KE!^
Snioarbeets
2075 {Montana
D9D Scubieas;
S4er>
4.320
20.7
66.BD0
17.551
State Total
S3.9t»
49.900
■@E1
■BKEEn
KEm
aoD
■lOi
BIBBHBBBli^^
BBIS]
2T1D0
20,200
16.3
3&;’.40D
1B.7D
^Bs^mststsmm
IChevsfins
2.B03
2.3C0
i8.e
52.100
17.40
HftteRsnsi*
liil'ft^l^-ligB.-TflliilM
iBHHHHIKtnil
500
1B.4
B.2DD
IF. fin
IfeaSiSSISmi
15C0
??A
55.SDD
17J!0
:S-aa3rfcest5
limFHHIflHBflB
3.eco
■i^
■dSi
iS'jqaitesls
2iHiD INsbrasKa
{Scans B-'jjf
6.7G0
bbmbbhbs^
BBiSOi
®l!SrfPS3i
niiaiTrrrrT—
2.405
Z4C0
_3iii
55,400
■liB^ ^7?;iS5SHB
! 1 1 1 imtThI tmitf
fl05
cDD
im
1D.700
EIMEI
4D.QDD
»gna
BBHBEBBln
BBE^
ISiioaftoee-te
BK${^f}M!lRSSiMI
^^^BHHBHREn^
3.CD0
23.6
70.BDD
15,40;
UaMclitlddl.-*
■■■■■■■VTiFil
IIIIIIIIIIIIIIIIIIE^
BB^
ebbbbbh^^^
BBsElij
BWiSfiWHi
■llBE*!>F4l?Stn!BSSMi
1.400
1.3Cd
16.2
23.T0D
16.10!
[D7fl Hculr.v/rSl
5 000
0.3CD
■EBB
BBBBHBBuBI^S
^■^!}|
SuQarlieets
2{ICi5 {Nebraska
Stale Total
4B.400
45,300
IK^I
llllllliMI4>i«iNatn'fz;^
■■■■■■■PlITiFt
4.SC0
20.0
bbmbbbbeb&s
mii
l=9T!Stiij&3Eil
■KSSMSHSliEma
4.600
■giQ
■BBI^HESggll
mm
iK
■ma
EES
<5! marties-K
3D.CDD
BKS
BBHMBBSSiSjS
®'!n3rt)“j£
■B!^lilgl!I.Bm[
74.700
13.7
1.174.539
EB
Suns/befits'
42.00D
2D.1
M4X'DD
15.4D
H^aartesls
2025|Hcnr:Dakc<3
|03Q Nsnheas!
152.703
14/', 300
17.6
2.541,003
1523
bHiiRFifTHISEn
r^fS9?ST39BBHBBiH
^HBBHBBBuuSiS
22.3
25’:-.DDD
iB.ea
10.700
BIHHBBBBElSiM
■BHBBBseSb^
Mgg5i[!H'.ia'»B!BgB
SSBBBIflBHHIBH
.74 nOO
23 DOa
2(35
459.009
EE^
BBSiniBfBi
SSSIHHHHHI
too
KID
EES
TTIinTriHVB
SSHBHHHBH^H
2£|.1DD
2S.400
KQ
BBHIMBS^I^S
WK^iMSEE^i
IDcD Eas Cenral
53.f0D
51,500
20.6
I.O.'-S.ODD
17.80
gSSuSS
I^SSR^^IB^HBii
jlHIBBflBflBKCiniS
2B.7DC
15,C
51£.0Dn
16.41
2CC5 iHcrtrt Dakwa
|D90 Sc'jtT’easi
31B0D
2a.7DC
wsm
51= .ODD
E[EI
■EUSIBESSSI
SSS^OHHHB
a^.OOD
2a.ODO
■dO
4.5S8XD9
EEn
SSSSSSS
QfiS&flHHflBHBBB!
BBBBIHiBi^&liS
5355
BS
5t,5DD
Bim
|ijgWM44f
BBBSS^El^BiSBBBi
ii'kiiUggarn— —
BiHBBBBH^SliS
2.0CQ
mmam
Sl.6!}D
BHm
SSSSSHHI^^HHi
BBBBIBilBiBI^S^Sn
7.700
33.7
25? .505
16.31
BB@i5SS!f!?SI^HB
BBiflHBlili^^^Ii3
7.7CD
KB
253.50D
BBMI
05152833
■ElESSIStSmi
9.B00
9.701)
32.1
311.0Q9
16.71
gI!5ES33i
1>^lK7-L.-lalltl!IW»M
^SSBBIBHBHIIIHI
BIHHIHHfiiHl
1.7C0
WKSE
65.DDD
KBSj
kwyiPf^.n
— T:i!iRigreir.Tro5M
HBBBlBHiflEEi^
1.7C0
ABES
bi.QOb
mmm\
2005 IWashinoton
{stale Total
1.700
170C
■CIB
69,009
Kai'
kB?Blj!4.4W
!3^^I!5SiSgBB
lEiaHcm
R.ODO
8.20C
KiTI
1E3203
g5!5il^Sli
■b^^isssss^h
SSSSiBHBBHHH
3. too
3. IDO
iKJj
70, BOD
EQES
tdlfflnEHTM
BBSSSSSSQiSBB
[^^^HIHBBBHBI
12,100
IBB
20’?.D0D
pgrrn'HJLM
BBigs^snsM
BBIB^^^^BBBQBE]
B.eOD
23.5
2bl5DD
Bn^i
lilTiRIRtfffRHHHHii
3?.oo:i
32.DDC
22.8
72;.5DD
17.63
umiffiga
HHHBBBKMtSl
1.:CD
16.C
lv.203
1623
SSSSIHBBBIliHHI
ecD
BES
12.300
BBB^I
BB^SISSSSSISBI
HHHH^BSIiS
2.1CD
1B.C
41X50
KEiS
kW.tj!li4!!OT1
’BIII^^MiSSBBBH
l^■lll[ll[■lm^^g^
18-6
?2.55b
17.01;
m!mmm
IH^HHHH&SSS3
33.9i3fi
Z^3
BDt.OOb
~7^\
Event H7-1
Draft ER
258
Appendix D
7/28/2010
1468
HHl
County
Rststsd rt0|ȣes
{Tboassnss cf As^eS)
Harvested
(llvMisands c^ .Acres)
Frcdiictian
(Thousands cfTons)
Sucrcse
Percen:)
1.530
15.2
22., 330
15,34
S^JOaftests
2Cv5 (Montana
1.920
28.1
52.100
1S.60
•MlsSiSRFR^^^HH
■■■■■■Kn??
4.320
20 7
95.B0D
17.53
l.-BrJBIi'Wii!.!
Stale ToUl
Sijm
49,900
22.9
1,143.000
17.41
lii'i i'i"i ' 1 sr^ifSBiaBH
000
mmijg
HHUjumi
§^^^■■■■0X17(1]
2d.2DO
msm
t!l!?Stl^*ttlllllllHi
MHHIHHHRiVrn?]
2.8C0
18.8
54.100
1/.4Q
:'?=iaafbeels
BWii!BI lll^
300
500
18.4
9.2DD
15.60
msm iiii m —
2.500
22.4
55.8DD
17 20
Suaarbesls
2C€c-|Msbrask3
3.800
iQ.e
71,70D
BIS
S^aarfafiEls
2^25 Nebraska
fi.7GD
■k@
147, 1DD
&ia3rt}e&ls
2.400
23.1
55,41}0
16.B0
2-K5 jNphraeifs
SDO
500
21.4
IC'.TDD
18.10
Sil-Co Mebraska
Dtn Nonhrte'S
42500
40.003
20.2
805.030
18.50
T'-'ii'inriM
Chase
3.400
3.DC0
ifflill
ieUTtl^i'^SI
1.000
■1^
hhI
1.300
18.2
23.fC‘0
16.1DI
D70 £cuthyj»Et
5.90D
5.30Q
Ili.OOD
■KSig
Surtarbeeta
20GS (Nebraska
State Tota]
4B.400
45,300
S24.D0O
■ElEg)
S^jaarbeete
4,900
■BHOi
jjimiiiiiiiiiiOB!^
MBiS
SrjQarbeets
IQCSlNcrtb D3k<?i3
□ (QNonhfte®
S.MO
4.630
■BTin
SHHBBESSSS
wmmsi
£-j-Q3rbecls
Mill 1 iigrgtawtaai
ICQ
WKM
IBHBBHHBSsIil
■liBiB
■i|"ii lli'l li iHM'I'IB
Gars Forks
31.30:<
3D.5DD
20.4
621 .OOD
■B
ISffRntESRS
2K-5 Ncrtn Dakcr-s
74.7D0
15.7
T. 174 .500
wm^
fcitltWMl44i.-B
42ilDQ
20.1
E44.00D
1B.40I
aggiiBei
■llbMi&ii3r7;^iciiE9!S
iEriVBnrmai^^^H
153.7Da
■1^
I^I^BbeSG^
KSSrai^t*
^ISS6re9BHHBHl
10,800
—gga
■i^i
DiQ West Cental
10 /ori
10.800
22.3
235-,ODD
IFOfil
^^KiB3[yBRCT?CT88r^[
23.000
IKB
AE-O.OOO
■ESSSEBSEII^S
100
■eiq
■ISi
SfiHlHHHHHi
26,400
■EiB
Mga
ili^iECRSnXRn^H^B
53.703
51.5DD
wmm
WKm
■i^SI
BPSSCTBM
2C-Ca (Ncfft Dakota
DSD Scutreas
3V0D3
mm
■nSEQ
State Total
25S.000
■■■CSiESl
■■n
2.000
H^^HHEfillaSai
HBi!]
Iciio
mim
■■n
i[SESS3SHHHBHHii
iBHBBHKE!>S]
7.7CD
M3iH
wmm\
irtWiLflWlggB^M
7.005
7,700
■QSiSSIS^QSHHI
9,705
wem
HHHil^BlEES
■B^
^S5!SIS3li
■■iKglKfky^j.!.|iJ.M
1,700
—WiFi
69.000
@5Si3331
BHHHHHBIS
1.700
IHBIS
.^WipgCITgtiffBTBTMl
1.7C0
»llll
l■n^
'MFBaSSBiBMBi
8.2CC
mm
'HHBHIiSlSilliS
l■■B
iSS^BIHBHHIi
jj^^HHilKlIIS
3.100
'■iB
12,100
222
265.00D
HE^SESBISiS^H
fe.eoo
HKifi
usmmm
32.200
32.000
WK3M
IfllSSISTSESlII^H
1.2GD
19.200
iHm
S^^SSSSSEHli
Iesssshhhhh
8CD
■ES
■DtB
'■Bais
■ESS^BSSSIH
HHHHHBEmiS
IStlD
■n^
■BSiB
pT]^ir!-Tri
mjssi^sssssHi
state Total
36.200
35.900
2Z3
SOt.OOD
■ ”-5'l
Event H7-1
Draft ER
259
Appendix D
7/28/2010
1469
■
Siaie
F'anted All Purpcsss
iTho-jssnds of Acfes]
HcP^^ted
fthousanda of A:?s)
Free per Unit
{Dcitars per Ton)
Vs'ye 0^ prodjccion
•iTTpcysands cf Cellars)
Wfp
wirr'n'iii'M
a'Bcaj
llllllllllllllllllll^^
WBiMtAHy
W>ll»
ilSBISSMBM
Wiil>
imssHi
147
WiRi
4Ar,
W'i!>
42
I
mm
48
K'l!>
tJBSiH«t
227
11
ISuaa^-eets
201C
United Steiis
U74
■9
22
iHUtmuiiami
I
Witi%
laPtRiTiniSI^I
55
25
m^\>}
3£
35
f
fa#feS}d|
W'kt!
riR!!SBMH
184
IfiS
1
5.581
^ t*7 1
[imnn i wm
)3d
13&
MiTffcJwaS
W'i'I’
484
44?
mamm^^
IspSFi^ci
■UiK?
3a
S4
HHHHU
kyi*»!r>Ksr5«1
53
53
.y. 1
1,28i
■NiKi!
~33
215
4.70:
Ji^?>F533aa
Hilt!
■i^^^HMMnn
■■■■■■rai
7
285
iWSWSiSJS
W#
i.iae
1.14&
BigSl
■MHIIIMI
fcll'l'ilc»MW:J^
22
26
jg^Egi
875
rip.ht^4!3
W'14^
_
OEM
i.5S2
544.80
S4T,13D|
34
2&
26.50
756
£47.80
S36.232I
K<init*icH3
WlbVi
iffinnHBH
ns
icnea
3.8 1&
J41GD
■Wite
WUlE^Mi
3.SD3
S44.D0
5171.732!
:£u3s:t«ets
20DS
Minn^^s
44Q
■■■■■MMKfSSi
Bwa
0,835
mmmmimsmi
Rr?5^3ia
■81?$
■MBHMMMRII
KIFB
823
«nn.8n
S41 806
Wr?S5S33S1
45
Bang
843
S42.834
BOT
icntntBnxi
797
1P7
5.102
551.00
5280202
«ir.Mj<«£.-i
20Ds
■HMMMMHR
■■■■■Bli
gang
105
i43.QD
S5.19D
Suaataett
2DD:
Un<'(ed Slates
1,C9!
Bana
26,881
J48.CD
■■■■BE1E5I
t3If*VWHR
KTBiHiSS*
■MMMIMK
Bra
67
£42.00
52,8141
Mikb
30
27
jglEg
eS
waaaam^s^i
40
55
■cwtai
1,386
S63.517
!£uasft«ets
20P7
Cobisdo
32
25
l53Ba
765
WTSS
k?J*i5StSa4^
Hffi
lec
167
ISS^
5 745
5211.001
KII:F5^351
Bffi
lAttinRTnMH
150
145
Easa
3487
S125.632
Kilifi
498
441
fcMHH
n,44S
2^
S517.46D
Wn.l-WJJH
wit*n
htortiarj
4a
47
KIHa
1.181
S45.306
fOT'V*?iI4r-1
■dilth
ifwnnBi
43
44
1.041
540,40
S42.0a&
WriM«4:4Ll
Wttcfc
mrn*jiwi
■■■■MHMiBi
■■■■■BBI
RWIil
6.705
»tktt
••rmmm
HTgg
35i
S 12.0531
H>l!U
lies
1247
Eg^
3i.a^
■■■Essn
n
“5
ecrnn
84
S36.0D
31
30
655
£40.20
32B.452
kH»fckj44?l
Mh»hm
[S3£I3uE9Bi
■MHBHHHES
43
leiilM
1.c55
J4? ?n
SBslH
■fflg
Co^a'jdo
.. . ^2
BPa
886
£42,30
337.616
^it
imBa
S.51I.
jae.sD
5234.155
g^iy;i-.v^i:i
■giia
QlSiSSli
15c
154
gKa
3, c/3
5135.774
■glia
OSSHSEEBli
;c4
All
KnpM
11,877
548.70
■ RFCTgHJl!!.!
mi^
54
KHTna
1.3i:
541.80
fegr;l-j»«M5^1
Kiia
81
Hian
1,347
$44.50
Wi)»!^
281
245
ltfl«M
8.315
■■■KiiPI
5ff^355B
■gj^
HBI^BIIIBIIHIB
mmmmmmai
BiTO
304
230 50
315.5831
B*FKr4-?^!Mi
Wijina
i.iee
1.334
Kang
34.C64
■■■BSSi}
KIBCT'j'a
IllWiia
OIHiSSS^H
2
tsnlud
74
■gga
ESSE3SHB
43
45
iBBg
7? 5
546.80
S37.345
iKigH
lij.liinlinl.MM
44
t;Bni!l
1.656
541.80
S85.355
:£ua3±«ete
2dk
Coisrado
38
54
IBFffl
833
540.70
S33.0D3
■jag|=^^a
■a’iwa
EESS9HBB
iiiiiiniiiiiimii_i___
157
Kang
4.626
544.40
£703 B54
gggg
154
152
KKa
3.235
534 40
5111.3177
wsm
451
460
iijnBiil
e.3P4
543.30
5411.010
wsim
ESSSJSHHI
5i
50
igna
1.145
545 30
351.775
■B«sa
4a
45
KSEg
024
S3&.S24
■8883
tggHiat^^
HHHIIliHil^S
■■■■■||||■|gSI
iniiig
4.C85
£224.746
■flisa
@17[Slili
10
iO
Kam
311
544.40
S1S.S05
msm
lllllllllllllllllllll^^
1.243
iqra
2/. 433
543.50
31,103.151
■Biaa
KtaSitflggigMi
EfflESl
e?
I44.4D
S3.D84
■giSS
^^SSSSHB
38
36
13333
2D1
£42.20
S34.2Bi
Event H7-1
Draft ER
260
Appendix D
7/28/2010
1470
im
im
M
y:€!rf
(Tens)
Produston
fnicu?snds cl Tens
Pros per Unit
PDr:5rs pgr Ton)
Vs'ye cf pn3djc;ion
{Th:u£3icls cc Cedars)
jgsg
g^yiBBBg^SBg
30
*?£
2!Siga«lfegg. i gSB
■H
iSnSCBBBMIi
■■■■■■■■■li
S4(**v-(rLSaife.. !•
LtiSiS
Rip
Mai
' g
Rip
lAfSRSSSSr^h
,i B
Wib
42
-«— y sg-g^
BfUliBfeaa
n#
46
i«se
WHWSi^lSi
Kill!
llB,iMS*l
227
■ ■
Util!
1!
iSugaijesis
2Dia
United ^iss
1.174
i ' •« i'
1 ■ "1
:SUQa±€EtS
2010
Wwrrino
32
^aw'-jyS^iSSKaft
^-TM]
35
pn
• *1.5 ?»■* “as--
RB
lei
16S
Fira
5,581
wssraei
136
136
giCT
3.215
ffcjiiti^
464
440
BaRg
10.541
R^*®4!4M
Hip
!iil*!rrPIS^HI
28
34
mM
1.00
iIIIIiiIiiiiIHImIB
mm
sS
53
IBES
1,294
■WiWB
2005
{iGflhDskia
235
21&
4.?0n
binirw^aaB
RB
■
11
11
KHTR
295
S "T^rsisS.
RB
1.186
114&
fgfia
RB
32
26
pggpg
R#
[•FlRnTilc^^B
26
25
pfrg
S47.13D
wm?33a
34
20
Bragg
755
S47.S0
SS5.232
m7:mam
13I
tie
fcnsii
3.519
S42.C0
3-151.895
mm
137
136
3.g03
344.00
5171,732
■M
4iC
3'eO
itfirffl
IIIHHESiES
t4B1.7B5
RB
iftnrwnSB^H
32
31
6319
823
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”S41.iD5
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4s
37
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843
1 IcD.BD
542224
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3?firi'’02
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e
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185
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SS.IK-
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■tt
1.C91
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23.281
IHBHBSIH!]
W*l»Vt!ra^
Hip
2
2
gnr?a
67
1 S42.C0
S2.814
(e{ih'^^il33
30
27
fgliW
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S34.S25
lefimnss
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l•Fl^i^TiJ^fBHi
40
39
fWtJUl
1.285
1 543.S0
S6D.517
wmwna
W'lqi
3'>
29
tM
705
I£ugsx«st5
R<l<^
167
Em
5745
BBBBIflflllllgSSK^n 1
RW
IcC
149
fas
3.-4Br
S36.0D
1125.532
HB
A?<i
i31
P^:!a
11445
5^5.20
5517.45:<
Wi^
48
47
bed
1.18’
«e.iD
S?53B
H'l-ls
4i
44
faggg
1,041
^40,40
542.055
KyT.Tw^^
lton»nS#l
262
247
Bam
S!7D5
IHK^
fer*v¥*CTaci
R'lTI
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11
mm
351
^26.80
SU852I
msms
liliTlCTiqKlE^
ile$
1.247
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ilSi.
l4i.rtn
ki.i*t*<y=iyi
2
?
Eig
8-
338,80
S3.1D0
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IQSi3l!!!IHi
31
3D
Bnra
655
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S25.452
43
43
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\mm^^
sei5H5
Mff'wyjga
■ijiia
BSEQ3IH
42
3£-
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S37.516
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5.825
1 32B.fD
5234.156
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l=c
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3,573
1 338.0D
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4/7
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■gig?
f4
49
Banw
1.312
S41.6Q
S&4.49S
gggiagHia
mm
{nsrssHH
5s
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1.347
3^.5Q
S59B42
warn
[?pgrar»j4!atii
. ._ 261
243
8316
3^8-50
1301% P.4D
pffBgssa
h|EHHBIHEB
^ehbihhks
ESS
3£t
239.50
315583
IJCC
1.334
mm
34,06-
544220
31.606.825
■gna
2
BWi»l
74
536,50
S2.023
jmm
ES'SZiSSEl
43
40
Btaon
79S
s-se.ao
S37.34&
jaHirSKinaiai
44
44
1.635
541.20
S65.3S5
6fff»?^3SEl
3^'
34
Bgim
833
$50.70
S3S.803
mm
157
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4.526
i-54.4n
1209.854
wesm
1c4
15?
BBESl
3.336
334.40
1111. 3ST
BI!»S^S3i
Eigg
BHiSSSSMi
4?1
460
■iiifeil
8.38-
543.20
S411 019
wm
f4
5D
1.143
545.30
S51.77S
SBnsS9S3i
4S
45
Bram
82-
543.10
539,824
f3BBE533l
mm
l81r}i-aMi
243
BTatiffl
4.565
54B.2D
1224.746
jlBiiga
gSS^ESEE
10
10
mn
31'
544.-40
S13.6QS
bUfilntiHj'l
■dilia
lUBBSERSi
1.2G0
1243
32.10
27.£33
5^3.50
51,183,151
KS
2
">
gBRM
69
IHHHHSSED
SS064
1^
36
iSl
gaga
20
1 542.20
S34.285
Event H7-1
Draft ER
261
Appendix D
7/28/2010
1471
Ccrm>?3lty
B
Bfll
Panted All PufpssK
(Tbyjsands d Aa^}
Hsv^ted
Cn^Hisanas of Aoik)
Yi^d
»Tai5
Pfcs per Unil
{DDl'-sispE-Ton;
Vah;e d pradjdion
'ITTr^Jsands d Dcllars)
V'W
fwsrmr—
Hkiilb
aa
IISSfSClHHMI
WWKB93I
w#
ransisBM
147
n#
445
W!.bW--!4H
■(Jilb
42
jajfflHsssa
I'lebTss’iia
ae
laijiHiSieaaiji
w#
Nnnh EMc'-a
227
i3roiTit<a'|E^
Kas>
!1
WaaBBaeroDPPMJllif nt 6?s^'SULi9 — A~s9e& ^aT” ~^&f «sb IJ^S
IrfWli'KWiSSSI
■SiFEi
HfiTiEJii8(lrIFT4ll
l.?74
?i7[SOnnHi
32
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1
JclJBSSSB'a
■lill^!
7n
|.;fi ,]
S8S
W#
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7/28/2010
1472
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Appendix D
7/28/2010
1473
Appendix E
2010 Technology Use Guide
Event H7-1
Draft ER
264
Appendix E
7/28/2010
1476
Source: www.biotech-gmD.com
•Pesticides registered by the U,5. EPA wtii not cause unreasonaWe adverse effects to man or the environment when used in accordance with label directions.
1477
YOUR ABILITY TO EiHAiCE
YOUR CROPS TOiAY!
It’s time to ReNEW your license
If you haven't renewed your Monsanto
Technology/Stewardship Agreement (MTSA)
in the past nine months, take care of it today!
Signing the MTSA ensures you’ll have access
to current and next-wave technologies. These
innovations will enhance plant drought tolerance,
cold tolerance, nitrogen use efficiency, yield and
much more!
You'll then have the option to complete the process
online or through conventional mail.
Paper MTSA's will continue to be accepted.
1478
Introduction
This 2010 Technology Use Guide (TUG) provides
a concise source of technical information about
Monsanto's current portfolio of technology products
and sets forth requirements and guidelines for
the use of these products. As a user of Monsanto
Technology, it is important that you are familiar
with and foilow certain management practices.
Please read all of the information pertaining to the
technology you will be using, including stewardship
and related information. Growers must read the
Insect Resistance Management (iRM)/Grower
Guide prior to planting for important information
on planting and IRM.
This technical guide is not a pesticide product label.
It is Intended to provide additional information and
to highlight approved uses from the product
labeling. Read and follow all precautions and use
instructions in the iabel booklet and separately
published supplemental labeling for the Roundup®
agricultural herbicide product you are using.
Included in this guide is information on the following:
Stewardship Overview
4
Introducing Genuity”
6
Insect Resistance Management
8
Weed Management
10
Coexistence and Identity Preserved Production
12
Corn Technologies
15
YieldGsrd® and Genuity'” Corn Technologies Product Descriptions
Roundup Ready® Technology in Corn
Cotton Technologies 21
Genuity'” Botigard il*and Bollgard®Cotton
Roundup Ready Technologies in Cotton
Genuity- Roundup Ready 2 Yield® and Roundup Ready Soybeans
31
GenuitY”' Roundup Ready* Alfalfa
35
Genuity- Roundup Ready® Spring Canola
36
Genuity'* Roundup Ready* Winter Canola
39
Genuity'” Roundup Ready* Sugarboets
40
It you have any questions, contact your Authorized Retailer or Monsanto at 1-800-768-6387.
2010 TECHNOLOGY USE GUIDE
A Message About Stewardship - seed and traits
Monsanto Company is committed to enhancing farmer productivity
and profitability through the introduction of new agricultural
biotechnology traits. These new technologies bring enhanced value
and benefits to farmers, and farmers assume new responsibilities
for proper management of these traits. Farmers planting seed with
biotech traits agree to implement good stewardship practices,
including, but not limited to:
Reading, signing and complying with the Monsanto
Technology/Stewardship Agreement (MTSA) and
reading all annual license terms updates before
purchase or use of any seed containing a trait.
Reading and following the directions for use on all
product labels.
Following applicable stewardship practices as
outlined in this TUG.
Reading and following the IRM/Grower Guide prior
to planting-
observing regional planting restrictions mandated
by the U.S. Environmental Protection Agency (EPA).
Compiying with any additional stewardship
requirements, such as grain or feed use agreements
or geographical planting restrictions, that Monsanto
deems appropriate or necessary to implement for
proper stewardship or regulatory compliance.
Following the Weed Resistance Management
Guidelines to minimize the risk of resistance
development.
Complying with the applicable iRM practices for
specific biotech traits as mandated by the EPA and
set forth in this TUG.
Utilizing all seed with biotech traits only for planting
a single crop.
Selling crops or material containing biotech traits
only to grain handlers that confirm their acceptance,
or using those products on farm.
Not moving materia! containing biotech traits across
boundaries into nations where import Is not permitted.
Not selling, promoting and/or distributing within
a state where the product Is not yet registered.
MONSANTO
1480
WHY IS STEWARDSHIP IMPORTANT?
Each component of stewardship offers benefits to farmers:
■ Signhg the MTSA provides farmers access to Monsanto's biotech
trait seed technology.
• Following IRM guidelines guards against insect resistance to
Bacillus thurinyiensis (B.t) technology and therefwe enables
the long-term viability of this technology, and meets EPA
requirements.
• Proper weed management maintains the long-term effectiveness
of glyphosate-based weed control solutions.
• Utilizing biotech seed only for planting a single-commercial
crop helps preserve the effectiveness of biotech traits,
while allowing investment for future biotech innovations
which further Improves farming technology and productivity.
Practicing these stewardship activities will enable biotechnofogy's
positive agricultural contributions to continue.
Farmers’ attitudes and adoption of sound stewardship principles,
coupled with biotechnology benefits, provide for the sustainability
of our land resources, biotechnology and farmirig as a preferred
way of life.
SEED PATENT INFRINGEMENT
if Monsanto reasonably believes that a farmer has planted
saved seed containing a Monsanto biotech trait, Monsanto
will request invoices and records to confirm that fields in
question have been planted with newly purchased seed. If this
Information is not provided within 30 days, Monsanto may
inspect and test ail of the farmer's fields to determine if saved
seed has been planted. Any inspections will be coordinated
with the farmer and performed at a reasonable time to best
accommodate the farmer's schedule.
If you have questions about seed stewardship or become aware of
individuals utilizing biotech traits in a manner other than as noted
above, please cai! 1-800-768-6387. Letters reporting unaccejrfable
or unauthorized use of biotech traits may be sent to:
Monsanto Trait Stewardship
600 N. Lindbergh Boulevard NC3C
St. Louis, MO 63167
For more Information on Monsanto’s practices related to seed
patent infringement, please visit:
www.monsanlo.com/seedpatentprolectlon.
Provide Anonymous or Confidential reports as follows:
"Anonymous" reporting results when a person reports informa-
tion to Monsanto fn such a way that the identity of the person
reporting the information cannot be identified, This kind of
reporting includes telephone calls requesting anonymity and
unsigned letters.
"Confidential" reporting results when a person reports Informa-
tion to Monsanto in such a way that the reporting person’s
identity is known to Monsanto, Every effort will be made to
protect a person's identity, but it is important to understand that
a court may order Monsanto to reveal the Identity of people who
are "known" to have supplied relevant information.
4jVfisef3 e
You’re buying more ihan
iud SG^. Wu-re vstuo loc>ay
a/^d inr«»9licn (Cr tomoirow.
cowivBit, taiowta?, rtsfomwict. |
The Beyond the Seed Program
was launched by the American
Seed Trade Association (ASTA)
to raise awareness and
understanding of the value
that goes beyond the seed.
The future success of U.S. agriculture depends upon quality
seed delivered by an industry commitment to bring innovation
and performance through conlinued Investment. For more
information about seed technology, visit ASTA's Beyond the
Seed Program at vvww.beyondtheseed.org.
2010 TECHNOLOGY USE GUIDE
1481
INTRODUCING GENUITY”
Genuity" Unites the Best Traits"
As a purchaser of Monsanto biotech trait products, your investment
helps fuel the research and development engine that leads to the
discovery and delivery of new technologies for agriculture. Current
and future Genuity" traits are designed to deliver high yield potential,
maximize return on seed investments and consistently deliver future
trait innovations.
CORN
Higher yields come from quality grain. Genuity ■“ VT Triple PRO'
vras the next generation of corn technology available for the
2009 growing season. Genuity ■* VT Triple PRO"' provides dual
modes of action against above-ground pests such as corn
earworm. European and southwestern corn ba^rs, sugarcane
borer, southern cornstalk borer and fall armyworm. Reduced
kernel damage from corn earworm means the potential for
reduced Aflatoxin contamination. Genuity ■“ VT Triple PRO'“ dual
modes-of-action aiso allows for a reduction in refuge acres
required In southern cotton-growing regions while providing
long-term effectiveness and consistency.
GENUITY'” SMARTSTAX'"
Scheduled for launch in 2010, Genuity'
SmartStax'“is the most-advanced,
all-in-one corn traft system that
controls the broadest spectrum of
above- and below-ground insects and
weeds. Genuity'" SmartStax'" provides
control of corn earworm, European
corn borer, southwestern corn borer, sugarcane borer, fall
armyworm, western bean cutworm, black cutworm, western corn
roolworm, nortnern corn rootworm and Mexican corn rootworm.
Genuity'" SmartStax' contains Roundup Ready® 2 Technology
and LibertyLink® herbicide tolerance. Genuity" SmartStax" also
allows for a reduction in refuge acres in the corn belt from 20%
down to 5% for above- and below-grounc) refuge. Genuity"
SmartStax" is also approved for a 20% refuge in the cotton belt.
SOYBEAN
Genuity" Roundup Ready 2 Yield* soybeans are taking yield
to a higher level. They were developed to provide farmers with
the same simple, dependable and flexible weed control and crop
safety they've come to rely on with the first-generation Roundup
Ready® soybean system, but with higher yield potential. This is
possible because of advanced insertion and selection technologies.
COTTON
Genuity" Roundup Ready® Hex and Genuity'" Boilgard 11® offer
the ultimate combination of peace of mind and flexibility.
They contain unrivaled built-in worm control to stop the most
leaf- and boil-feeding worm species, Including bollworms,
budworms. armyworms. ioopers, saltmarsh caterpillars and
cotton leaf perforators. Protecting just one additional boll
per plant can result in significantly higher tint yield. The
convenience and savings from fewer or no sprays for worms
can make a big difference when it comes to the bottom line.
SPECIALTY
Genuity'* Roundup Ready* alfalfa; Bred from an innovative
germptasm pool, it offers outstanding weed control, excellent
crop safety and preservation of forage quality potential.
Genuity" Roundup Ready* canola: Offers excellent control
of broadleaf weeds and grasses, even in tough weather
conditions. Also features excellent crop safety and broad
application flexibility.
Genuity" Roundup Ready'*' suqarbeets: Excellent in-ptant
tolerance to over-the-top applications of labeled Roundup
agricultural herbicides. Offers outstanding weed control,
excellent crop safety and preservation of yield potential.
•Ssn pagss 16 ant! 17 lor srtdilionai tr.iits.
NOTE: Farinefs must read the IRM/Crawer Guide piior lo planting lot InfoTBiation cn {^.anting end Insect Resirfance Maiwqemen!.
MONSANTO
1482
Monsanto's New Generation of Technologies
As Monsanto continues to develop new generations of technologies,
several of our newer technologies are migrating to the Genuity" brand.
These products and their new logos are presented below.
VieUCardh^
|¥lf¥l
^2
- SB
Triple PRO
nii^riai |
SiiMiil
CORN
SOYBEANS
Rcaniupllnii'yRn
||-
BoHranJir
with®
Roundup Reasy'
Cotton
COTTON
Bi^gardir ^4^
Roundup Read/ ftex
DoDgiiati
htdfHn
NBtae Weeds:
SPECIALTY
2010 TECHNOLOGY USE GUID
E
1483
An EFFECTIVE IRM program is a vital part of
responsible product stewardship for insect-
protected biotech products. Monsanto is committed
to implementing an effective IRM program for all of its insect-
protected B.t. technologies in all countries where they are
commercialized, including promoting farmer awareness of these
IRM programs. Monsanto works to develop and implement IRM
programs that strike a balance between available knowledge and
practicality, with farmer acceptance and implementation of the plan
as critical components.
The U.S. EPA requires that Monsanto implement, and farmers regulatory programs have been developed and updated through
who purchase insect-protected products follow, an IRM plan.* broad cooperation with farmer and consultant organizations,
IRM programs for Rf. traits are based upon an assessment of the including the National Corn Growers Association and the National
biology of the major target pests, farmer needs and practices, Cotton Council, extension specialists, academic scientists, and
and appropriate pest management practices. These mandatory regulatory agencies.
Planting Rsluass, PnssnlnaTacliBaiagf
1484
The iRM programs for planting seeds containing at traits contain
several important elements. One key component of an IRM
plan is a refuge. A refuge is simply a portion of the relevant
crop (corn or cotton) that does not contain a e.f. technology
for the control of the insect pests which are controlled by the
planted technoiogy{ies). The lack of exposure to the 8.t. proteins
means that there will be susceptible Insects nearby to male
with any rare resistant insects that may emerge from 6.t.
products. Susceptibility to B.t products is then passed on
to offspring, preserving the long-term effectiveness of
the technology.
Farmers who purchase seeds containing at. traits must plant an
appropriately designed refuge. Refuge size, configuration, and
management is described in detail in the sections on those
products in the 2010 IRM/Grower Guide.
Failure to follow IRM requirements and to plant a proper
refuge may result in the loss of a farmer's access to Monsanto
technologies. Monsanto is committed to the preservation of
B.t technologies. Please do your part to preserve B.t. technologies
by implementing the correct IRM plan on your farm.
MONITORING PROGRAM
The U.S. EPA requires Monsanto to take corrective measures in
response to a finding of IRM non-compliance. Monsanto or an
approved agent of Monsanto must monitor refuge management
practices. The MTSA signed by a farmer requires that upon
request by Monsanto or its approved agent, a farmer must
provide the location of all fields planted with Monsanto
technologies and the locations of ail associated refuge areas
as required, to cooperate fully with any field inspections, and
allow Monsanto to inspect all fields and refuge areas to ensure
an approved insect resistance program has been followed. Ail
ln^>ections will be performed at a reasonable time and arranged
In advance with the farmer so that the farmer can be present
If desired.
IRM GUIDELINES
Farmers must read the current IRM/Grower Guide prior to planting for information on
planting and IRM. If you do not have a copy of the current IRM/Grower Guide, you may
downloaded it at www.mons8nto.com, or you may call 1-0OO-768-6387 to request a copy
by mail.
2010 TECHNOLOGY USE GUIDE
1485
Monsanto considers product stewardship to be a fundamental
component of customer service and responsible business practices.
As leaders in the development and stewardship of Roundup"
agricultural herbicides and other products, Monsanto invests
significantly in research to continuously improve the proper uses
and stewardship of our proprietary herbicide brands.
This research, done In conjunction with academic scientists,
extension specialists and crop consultants, includes an evaluation
of the factors that c^r^ contribute to the development of weed
resistance and how to properly manage weeds to delay the
selection for weed resistance. Visit www.weedtoot.com for
practical, best practices-based information on reducing the risk
for development of giyphosate-resistant weeds. Developed
in cooperation with academic experts, the website provides
options for managing the risk on a field-by-field basis.
Glyphosate is a Group 9 herbicide based on the mode of action
classification system of the Weed Science Society of America.
Any weed population may contain plants naturally resistant to
Group 9 herbicides. The following general recommendations
help manage the risk of weed resistance occurring.
WEED RESISTANCE MANAGEMENT PRACTICES:
' Scout your fields before and after herbicide application
• Start with a clean field, using either a burndown herbicide
application or tillage
• Control weeds early when they are small
’ Add other herbicides (e.g. a selective in-crop and/cH* a residual
herbicide) and cultural practices (e.g. tillage or crop rotation) as
part of your Roundup Ready'* cropping system where appropriate
• Rotation to other Roundup Ready crops will add opportunities for
introduction of oilier modes of action
■ Use the right herbicide product at the right rate and the right time
• Control weed escapes and prevent weeds from setting seeds
• Clean equipment before moving from field to field to minimize
spread of weed seed
• Use new commercial seed that Is as free from weed seed
as possible
Monsanto is committed to the proper use and long-term
effectiveness of its proprietary herbicide brands through a
four-part stewardship program; developing appropriate weed
control recommendations, continuing research to refine and update
recommendations, education on the importance of good weed
management practices and responding to repeated weed control
inquiries through a product performance evaluation program.
GLYPHOSATE-RESiSTANT WEEDS
Monsanto actively investigates and studies weed control
complaints and claims of weed resistance. When giyphosate-
resistant weed biotypes have been confirmed, Monsanto alerts
farmers and develops and provides farmers with recommended
control measures, which may Include additional herbicides,
lank-mixes or cultural practices. Monsanto actively communicates
all of this information to farmers through multiple channels,
including the herbicide label, www.weedsclence.Drg, supplemental
labeling, this TUG. media and written communications,
Monsanto’s website, www.weBdresistancemanagement.com,
and farmer meetings.
Farmers must be aware of, and proactively manage for,
giyphosate-resistant weeds in planning their weed control
program. When a iweed Is known to be resistant to glyphosate,
then a resistant population of that weed is by definition no
longer controlled with labeled rates of glyphosate. Roundup®
agricultural herbicide warranties will not cover the failure to
control giyphosate-resistant weed populations.
Report any incidence of repeated non-performance on a
particular weed to your local Monsanto representative, retailer
or county extension agent.
Moie; Always rsad and ‘cHow alt pesticide label requlrerrerits.
MONSANTO
1486
MONSANTO BRANDS OF SELECTIVE OVER-THE-TOP
HERBICIDE PRODUCTS
Herbicide products sold by Monsanto for use over the top of
Roundup Ready crops for the 2010 crop season are as follows:
Do not add additional surfactants and/or products containing
surfactants to these Roundup agricultural herbicides unless
otherwise directed by the label. Other glyphosate products
labeled for use in Roundup Ready technologies may require
the addition of surfactants, or other additives to optimize
performance, that may Increase the potential for crop Injury.
Monsanto will label and promote only fully tested brands that
do not require surfactants and other additives for over-the-top
applications to Roundup Ready Crops.
GLYPHOSATE ENDANGERED SPECIES INITIATIVE
Roundup WeatherMAX® Roundup PowerMAX®
Read and follow all product labeling before using Roundup
agricultural herbicides over the top of Roundup Ready traits.
To learn more about applicable supplemental labels or fact
sheets, call l-800*76a-63B7,
Tank-mixtures of Roundup agricultural herbicides with insecti-
cides, fungicides, micronutrients or foliar fertilizers are not
recommended as they may result in reduced weed control,
crop injury, reduced pest control or antagonism. Refer to the
Roundup agricultural herbicide product label, supplemental
labeling or fact sheets published separately by Monsanto for
tank-mix recommendations.
Before making applications of glyphosate'based herbicide
products, licensed farmers of crops containing Roundup Ready
technology must access the website www.pre'serve.org to
determine whether any mitigation requirements apply to the
planned application to those crops, and must follow all applicable
requirements. The mitigation measures described on the website
are appropriate for all applications of glyphosate-based
herbicides to all crop lands.
Farmers making only ground applications to crop lar^d with
a use rate of less than 3.5 lbs of glyphosate a.e./A are not
required to access the website. If a farmer does not have web
access, the seed dealer can access the website on behalf of
the farmer to determine the applicable requirements, or the
farmer can call 1-800-332-3111 for assistance.
In certain areas, populations of ryegrass, jolinsongrass, marestal cwreiwn ragweed, gtanl ragweed. Faimer /imaranffiand waterhemp are known to be resistant to
glyphosate. For control recommendations for resistant biotypes of these weeds, refer to www.weedreslst3rKeinanagementcom or cal! 1-800-768-6387. When approved,
supplemental labeling for specific herbicide products can also be viewed www.cdms.net or www.greenbook.net or obtained by calling 1-800-768-6387.
2010 TECHNOLOGY USE GUIDE
1487
/ ‘ T
COEXISTENCE AND IDENTITY PRESERVED PRODUCTION / \
Coexistence in agricultural production systems and sifl)piy
chains is not new. Different agricultural systems have coexisted
successfully for many years around the world. Standards
and best practices were established decades ago and have
continually evolved to deliver high purity seed and grain to
support production, distribution and trade of products from
different agricultural systems. For example, production of sirralar
commodities such as field corn, sweet corn and popcorn has
occurred successfully and in close proximity for many years.
Another example is the successful coexistence of oilseed rape
varieties with tow erucic acid content for food use and high
erucic acid content for industrial uses.
The introduction of biotech crops generated renewed discussion
of coexistence focused on biotech production systems with
conventional cropping systems and organic production. These
discussions have primarily focused on the potential economic
impact of the introduction of biotech products on other systems.
The health and safety of biotech products are not an issue
because their food, feed and environmental safety must be
demonstrated before they enter the agricultural production
system and supply chain.
The coexistence of conventional, organic and biolech crops has
been the subject of several studies and reports. These reports
conclude that coexistence among biotech and non*biolech
crops is not only possible but is occurring. They recommend
that coexistence strategies be developed on a case-bycase basis
considering the diversity of products currently in the market and
under development, the agronomic and biological differences in
the crops themselves end variations in regional farming practices
and Infrastructures. Furthermore, coexistence strategies are
driven by market needs and should be developed using current
science-based Industry standards and management practices.
The strategies must be flexible, facilitating options and choice for
the farmer and the food/feed supply chain, and must be capable
of being modified as changes in markets and products warrant.
Successful coexistence of ail agricultural systems is achievable
and depends on cooperation, flexibility and mutual respect for
each system. Agriculture has a history of innovation and change,
and farmers have always adapted to new approaches or chal-
lenges by utilizing appropriate strategies, farm management
practices and new technologies.
The responsibility for implementing practices to satisfy specific
maritetlng standards or certification lies with that farmer who
is growirrg a crop to satisfy a particular market. Only that farmer
is instructed to employ the practices appropriate to assure the
integrity of his/her crop. This is true whether the goal is high-oi!
corn. whIte/sweet corn or organically produced yellow corn for
animal feed. In each case, the farmer is seeking to produce a
crop that is supported by a market price and consequently that
farmer assumes responsibility for satisfying reasonable market
specifications. That said, the farmer needs to be aware of the
planting intentions of his/her neighbor in order to gauge the
need for management practices.
IDENTITY PRESERVED PRODUCTION
Some farmers may choose to preserve the identity of their crops
to meet specific markets. Examples of Identity Preserved {l.P.)
corn crops include production of seed corn, white, waxy or sweet
com. specialty oil or protein crops, food grade crops and any
other crop that meets specialty needs, including organic and
non-genetically enhanced specifications. Farmers of these crops
assume the responsibility and receive the benefit for ensuring
that their crop meets mutually agreed contract specifications.
Based on historical experience with a broad range of I.R crops,
the industry has developed generally accepted t.P. agricultural
practices. These practices are Intended to manage l.P. production
to meet quality specifications, and are established for a broad
range of l.P. needs. The accepted practice with |,P. crops Is that
each l.P. farmer has the responsibility to Implement any neces-
sary processes. These processes may include sourcing seed
appropriate for l.P. specifications, field management practices
such as adequate Isolation distances, buffers between crops,
border rows, planned differences in maturity between adjacent
fields that might cross-pollinate and harvest and handling
practices designed to prevent mixing and to maintain product
quality. These extra steps associated with I.P. crop production
are generally accompanied by incremental increases in cost
of production and consequently of the goods sold.
MONSANTO
1488
General Instructions for Management
of Pollen Flow and Mechanical Mixing
For all crop hybrids or varieties that they wish to identity
preserve, or otherwise keep separated, farmers should take steps
to prevent mechanical mixing. Farmers should make sure at! seed
storage areas, transportation vehicles and planter boxes are
cleaned thoroughly both prior to and subsequent to the storage,
transportation or planting of the crop. Farmers should also make
sure all combines, harvesters and transportation vehicles used at
harvest are cleaned thoroughly both prior to and subsequent to
their use in connection with the harvest of the grain produced
from the crop. Farmers should also make sure all harvested grain
Is stored in clean storage areas where the Identity of the grain
can be preserved.
Self-pollinated crops, such as soybeans, do not present a risk
of mixing by cross-pollination. If the intent is to use or market
the product of a setf-poliinated crop separately from general
commodity use, farmers should plant fields a sufficient distance
away from other crops to prevent mechanical mixture.
Farmers plar^ting cross-poUlnatsd crops, such as corn or alfalfa,
who desire to preserve the identity of these crops, or to minimize
the potential for these crops to outcross with adjacent fields
of the same crop kind, should use the same generally accepted
practices to manage mixing that are used In any of the currently
grown I.P. crops of similar crop kind.
It Is generally recognized in the industry that a certain amount
of incidental, trace level pollen movement occurs, and it is not
possible to achieve 100% purity of seed or grain in any corn
production system. A number of factors can influence the
occurrence and extent of pollen movement. As stewards of
technology, farmers are expected to consider these factors and
talk with their neighbors about their cropping intentions.
Farmers should take into account the foliowing factors that can
affect the occurrence and extent of cross-pollination to or from
other fields. Information that is more specific to the crop and
region may be available from stats extension offices.
• Cross-pollination is limited. Some plants, such as potatoes, are
incapable of cross-pollinating, while others, like aifalfa, require
cross-poilination to produce seed. Importantly, cross-pollination
only occurs within the same crop kind, like corn to corn.
The amount of pollen produced within the field can vary. The
pollai produced tjy the crop within a given field, known as pollen
load, Is typicaliy high enough to pollinate ail of the plants in the
fteU. TTierefore, most of the pollen that may enter from other
fields foBs on plants that have already been pollinated with pollen
that originated from plants v4thin the field. In crops such as alfalfa,
the hay cutting management schedule significantly limits or
eliminates bloom, and thereby restricts the potential for pollen
^td/or viable seed formation.
The existence and/or degree of overlap in the poliination period
of crops in adjacent fields varies. This wili vary depending on the
maturity of crops, planting dates and the weather. For corn, the
typical pollen shed period lasts from 5 to 10 days for a particular
field. Therefore, viable pollen from neighboring fields must be
present when idlhs are receptive in the recipient field during this
brief perfod to produce any grain with traits introduced by the
out-of-field pollen.
Distance between fields of different varieties or hybrids of the
same crop: The greater the distance between fields the less likely
their pollen will r«nain viable and have an opportunity to mix
and produce an outcross. For wind-pollinated crops, most cross-
pollination occurs within the outermost few rows of the field.
In fact, many whits and waxy corn production contracts ask the
farmer to remove the outer 12 rows {30 ft.> of the field in order
to remove most of the impurities that could result from cross-
pollination with nearby yellow dent corn, Furthermore, research
has also shown that as fields become further separated, the
incidence of wind-modulated cross-pollination drops rapidly.
Essentially, the in-field pollen has an advantage over the pollen
coming from other fields for receptive silks because of Its volume
and proximity to silks.
The distance pollen moves. How far pollen can travel depends on
many environmental factors, including weather during pollination,
especially wind direction and velocity, temperature and humidity.
For bee-pollinated crops, the farmer's choice of pollinator species
and apiary management practice may reduce fieid-to-fleld
pollination potential. Ail these factors will vary from season to
season, and some factors from day to day and from location
to location.
For windijollinated crops, the orientation and width of the
adjacent field in relation to the dominant wind direction. Fields
oriented upwind during pollination will show dramatically lower
cross-pollination for wind-pollinated crops, like corn, compared
to fields located downwind.
2010 TECHNOLOGY USE GUIDE
1489
1490
Advanced breeding and biotechnology have had a major impact on
farming production. From 1971 to 1995, average corn yields were
increasing at a rate of 1.5 bushels per acre, per year. Since the advent
of biotech in 1996, corn yields have increased at a rate of 2,6 bushels
per acre, per year, for a total increase of 32 bushels per acre.*
Excellence Through Stewardship
Monsanto Company is a member of Excellence Through
Stewardship® (ETS). Monsanto products are commercialized
In accordance with ETS Product Launch Stewardship Guidance,
and in compliance with Monsanto's Policy for Commercialization
of Biotechnology-Derived Plant Products in Commodity Crops.
This product has been approved for import into key export
markets with functioning regulatory systems. Any crop or
material produced from this product can only be exported to,
or used, processed or sold in countries where ait necessary
regulatory approvals have been granted. It is a violation of
national and international law to move material containing
biotech traits across boundaries into nations where import
Is not permitted. Growers should talk to their grain handler
or product purchaser to confirm their buying position for this
product. Excellence Through Stewardship® is a registered
trademark of Biotechnology Industry Organization.
t For specific refuge requirements for
B.t com and cotton, see the current
I IRM/Grower Guide, sent with this TUG.
i H you have not received a copy of
I this Guide, it can be downloaded at
i www.mans8nto.com, or cali 1-800-768'6387
I to request a copy be mailed to you.
Haiui filtte, f i iuni ii Jutaliti
Before opening a bag of seed, be sure to read and understand the stewardship requirements, including
applicable refuge requirements for insect resistance management, for the biotechnology traits expressed in
the seed as set forth in the Monsanto Technology Agreement that you sign. By opening and using a bag of seed,
you are reaffirming your obligation to comply wnth those steward^ip requirements.
* USDA Yields were calciileloil using 3 year roltingavsfaces(32Yieldi5 2.6bi.-/3t ’EyearsJ.ZOOe Weldh{njinDo3ne Aq Ser»fce$ forecast in Aoril B. ZOOS Ooarietly Crop Gutloob,
2010 TECHNOLOGY USE GUIDE
1491
CORN TECHNOLOGIES
Genuity’" Trait Products and YieldGard® Corn Technologies Product Descriptions
GENUITY^" SMARTSTAX"
Scheduled to launch In 2010. Genuity'" SmartStax'* is the most
advanced, alHn-one corn trait system that controls the broadest
spectrum of above- and belowground insects and weeds. Genuity-
SmartStax- hybrids will contain B.f. proteins that represent three
separate modes of action for control of lepidopteron, above-
ground insect pests, as well as combined modes of action for
control of coleopteran, below-ground insect pests. Providing
multiple B.t. proteins for control will dramatically decrease the
probability that insects will become resistant to the traits,
resulting in enhanced durability of transgenic insect control via
Q.f. genes. Based on this multiple gene approacti, Genuity”
SmartStax" is approved for reduced refuge in the corn belt from
20% down to 5% for both above- and below-ground pests. The
cotton belt refuge for Genuity SmartStax” is also reduced, from
50% down to 20%.
VITiIpKFM
GENUITY” VT TRIPLE PRO”
{Formerly YieldGard VT Triple PRO”) -Genuity” VT Triple PRO”
is available in selected southern corn* and cotton-growing areas.
It includes broad-spectrum insect control against corn earworm,
European and southwestern corn borers, sugarcane borer,
southern cornstalk borer, fall armyworm, western corn rootworm,
northern corn rootworm and Mexican corn rootworm. 11$
advanced control of ear pests can result in higher grain quality
and higher-yielding crop potential. The dual mcKie-of-action of
Genuity” VT Triple PRO” allows for lower corn borer refuge acres
in southern cotton-growing areas compared to other registered
S.t.-traited products. It includes the same Roundup Ready® 2
Technology as Monsanto's previous product, YieldGard VT Triple.
Seed containing Genuity” VT Triple PRO” technology is treated
with seed-applied insecticide,*
ViEMEanl^
YIELDGARD VT TRIPLE'*
YfeldGard VT Triple technology combines YieldGard Com Borer
and YieldGard VT RDotworm/RR2® technology into a single plant.
YieldGard VT Triple corn hybrids control European and south-
western corn borer, sugarcane borer, southern cornstalk borer,
western corn rootworm, northern corn rootworm and Mexican
corn rootworm. YieldGard VT Triple technology suppresses corn
earworm, fall armyworm and stalk borer. By providing in-piant
protection against the above insect pests, the genetic yield
potential of YieldGard VT Triple corn hybrids is preserved.
YieldGard VT Triple corn hybrids also include Roundup Ready Z
Technology. This trait allows a farmer to experience the benefits
of utilizing Roundup agrlcuitura! herbicides in a weed control
system that provides the broadest weed control spectrum
available, better application flexibility, and superior crop safety.
Seed containing YieldGard VT Triple technology is treated with
seed-applied itjsecticide.*
VTOvitePIlO
GENUITY” VT DOUBLE PRO”
Genuity” VT Double PRO” is a new corn technology scheduled
for launch In 2010. It includes broad-spectrum insect control
against corn earworm. European and southwestern corn borers,
sugarcane borer, southern cornstalk borer and fall armyworm.
The dual mode-of-action of Genuity” VT Double PRO” allows for
lower corn borer refuge acres compared to other registered
fl.t.-lraited products. Seed containing Genuity” VT Double PRO”
technology is treated with seed-applied insecticide.'
‘Asesd-ajipHadInsccIicldccan protect seed.cooU and seedlings Irani insects such as black
cutwoffn, wtrenwirtr, white grubs, seed corn maggots, chinch tug and eatiy ifes beetles.
MONSANTO
1492
VieUEardW^
Mmiwispim/RIMS
YIELDGARD VT R00TW0RM/RR2®
YieldGard VT Rootworm/RR2 technology is the current YietdGard stacked-trait product for contro! of western corn rootworm,
northern corn rootworm and Mexican corn rootworm. Protecting the root of the corn plant from feeding by corn rootworm tarvae
decreases lodging and protects the genetic yield potential of YieldGard VT Rootworm/RR2 corn hybrids. The Roundup Ready 2
Technology allows a farmer to experience the benefits of utilizing Roundup agricultural herbicides in a weed control system that
provides the broadest weed control spectrum, better application flexibility and superior crop safety. Seed containing YieldGard VT
Rootworm/RR2 technology is treated with seed-appiied insecticide.*
YIELDGARD'^ CORN BORER
YieldGard Corn Borer corn hybrids contain an insecticidal
protein from e.t. that protects corn plants from European
corn borer, southwestern corn borer, sugarcane borer and
southern cornstalk borer resulting in full yield potential.
MaHlsmm
iDsectProtecUon
YIELDGARD PLUS
YieldGard Plus corn technology combines YieldGard
Corn Borer and YieldGard Rootworm technology
into a single plan.
YIELDGARD ROOTWORM
YieldGard Rootworm corn hybrids contain an insecticidal
protein from S.t. that protects corn roots from iarval
feeding by western, northern and Mexican corn rootworm.
YIELDOARD'^'CORN BORER WITH
ROUNDUP READY'- CORN 2
YieldGard Corn Borer with Roundup Ready Com 2 offers
farmers all the benefits of both traits combined In one crop.
These hybrids exhibit the same insect protection qualities as
YieldGard Corn Borer and, like Roundup Ready Corn 2, are tolerant
to over-the-top applications of Roundup"- agricultural herbicides.
YIELDGARD PLUS WITH ROUNDUP READY CORN 2
YieldGard Plus with Roundup Ready Corn 2 offers farmers all the
benefits of all three traits combined in one crop. These hybrids
exhibit the same insect protection qualities of YieldGard Corn
Borer and YieldGard Rootworm and, tike Roundup Ready Corn 2,
are tolerant to over-the-top applications of Roundup" agricultural
herbicides. Seed containing YieldGard Pius technology is treated
with seed-applied insecticide.*
YIELDGARD ROOTWORM WITH
ROUNDUP READY CORN 2
YieldGard Rootworm with Roundup Ready Corn 2 offers farmers
all the same insect protection qualities as YieldGard Rootworm
and, like Roundup Ready Corn 2, is tolerant to over-the-top
applications of Roundup agricultural herbicides.
-A seed-app^d hsscticide can protect seed, ranis pntl seedlings tram Insects such as hlack
cutworm. vriroTOi'm, e>hlle qfu&s. seed earn maggots, chinch Pug and early lle.a bealles.
2010 TECHNOLOGY USE GUIDE
1493
CORN TECHNOLOGIES
ROUNDUP READY® Technology in Corn
WEED CONTROL RECOMMENDATIONS
Roundup Ready® Corn 2 (RR2) and corn with Roundup Ready®
2 Technology are equivalent in their tolerance to Roundup
agricultural herbicides. Products with Roundup Ready Technology
contain in-plant tolerance to Roundup agricultural herbicides.
The Roundup Ready® Technology system’s flexibility, broad*
spectrum weed control and proven crop safety offer farmers
weed control programs that allow them to use the system In the
way that provides the greatest benefit. Farmers can select the
program that best fits the way they farm. Options Include the use
of a residual herbicide with
a Roundup* agricultura!
herbicide, tank-mixing other
herbicides with Roundup
agricultural herbicides where
appropriate and a total
postemergence program.
INSTRUCTIONS AND USE RATES*
Use the proper Roundup Ready RATt'oi Bullel®.
Degree®. Degree Xtra®, Harness®, Harness Xtra. Harness
Xlra 5.6L. MicroTech". or lariat* {no post) as defined in
the table below and the individual product labels, either
pre or poslsmergence to the crop."
follow with Roundup WeatherMAX at 16 to 22 oz/A
post seguenlially after preemergence application or
tank-mixed !n-crop witIUhe residual. Applications
should be made before weeds exceed 4" in height
Roundup Ready RATEs***
H«fn«ss 1.5 Pirts
Oagrse 10 Pints
Harness Xtra 1.2 Ovarls
Harness Xt» S.fiL 1.5 Ouails
DagnaXtm 2.0 Oiutts
HlCTO-Iecfi 2.0 Quarts
Lariat 2.0 Quarts
Bullet 2.0 Ouaris
AGRONOMIC PRINCIPLES
Corn yield is very sensitive to early-ssason weed competition.
Weed control systems must provide farmers the opportunity to
control weeds before they become competitive. The Roundup
Ready Technology system provides a mechanism to control
weeds at planting and once they emerge. Farmers are provided
excellent crop safety and full yield potential, with applications
made from planting through 48" of corn height. Drop nozzles
must be used between 30" and 48" of corn height. Failure to
control weeds with the right rate, at the right time and with
the right product, can lead to increased weed competition,
weed escapes and the potential for decreased yields. Use
other approved herbicide products with Roundup agricultural
herbicides if appropriate for the weed spectrum.
ADDITIONAL INFORMATION
Use full labeled rate of residual when application is 14 days or more prior to
planting or when tough grasses are present, e.g., barnysrdgrass, shattercane,
seedling johnsongrass, sandbur.
Use a minimum of 25 pt/A of Harness on woolly cupgrass and v/ild proso millet.
Products containing alrazine will provide improved control of cocklebur, giant
ragweed. Pdimer Amsrartih and mernlnggiory.
Tank-mix products such as 2.4-0. dicamba or Status® herbicide with Roundup
WeatherMAX for control of glyphosate-resistanl marestaii (horseweed), Pelmer
Ammnth and other (fifficull-lo-conlrot weeds.
Use 22 to 32 oz/A of Roundup WeatherMAX* when frornlngglory or perennial weeds
are presenter when broadleaf weeds are 4" in height or taller.
PROGRAM
For use where residual
herbicides are
typically used for
early-season weed
control:
Residual Herbicide
Plus Routtdup
WeatherMAX*
For use where total
postemergence
programs are effective
and sustainable:
Roundup WeatherMAX
Sequential
Apply Roundup WeatherMAX at 16 to 22 oz/A before
weeds exceed 4" in height and loitow with a second
application at 16 to 22 oz/A for an additional flush of
weeds before they exceed 4"in height.
Use 22 to 32 oz/A of Roundup WeatherMAX when morninggtory or perennial
weeds are present
Tank-mix products such as 2.4-D. dicamba or Status herbicide with Rourrdup
Wealhe'MAX lor control of glyphosate-resislant marestaii (horseweed), Palmer
Affwranfftand other dilficoit-to-contfoi weeds.
Maximum Use Rates
For Roundup
WeatherMAX
Products with Roundup Ready 2 Technology In-crop:
• 32 oz/A per single application
• Total: 64 oz/A from emergence ItircH^h 48" height of
corn, drop nozzles must be used from Sff* to 48” owa
Products with Roundup Ready 2 Technology Total Season:
The combined total of pre plant, in-crop and preharvest applications
of Routrdup WeatherMAX can not exceed 5.3 qt/A. The combined total
of in-crop arnl preharvest applications can not exceed 66 oz/A.
•llustm? snollict Bosindups^iitDttijTSI h«Sii;K!s.V»uiti«sl ttlwlcllie IsteTfeJOktel 0rBoi>«liKife3<ly£«aZhU*ol59y“^'W^^I*®U»U«U»“«l!3ilelefniinf spproprijt* uEcnlss. itTOigfiQiifeupPaweiMAl'.spptelisn
ulei irettiesgiress lor BoumtiipyiejiriiiMAXllusinsjiialtiiiie^duallH^eicNlf.ltekiNUidrtHejitstnlsiiKinidiMiiRifeilCtiaeaunduiiEeiirfCatiiirsliow i'lgcstlcliielilie! nsUiemoRis.
*'Aii 3 rlnE tnov 9lS3 1» used ss i rcsttiuel hetblrrlE in ihe eiMriit .7 Cwn 2 Sysion.
—yoonisf apply uiJto IPt la^fesitfiiaMisikicifls laUsieSfals iof coin
MONSANTO
1494
WEED RESISTANCE MANAGEMENT FOR CORN
WITH ROUNDUP READY TECHNOLOGY
Follow ail pesticide label requirements and the guidelines below
to minimize the risk of developing glyphosate-resistanl weed
populations in a Roundup Ready Technology system.
• Start dean with a burndown herbicide or tillage. Early-season
weed control Is criUcal to yield,
• Apply pre-emergence residual herbicides such as Harness Xlra.
Degree Xtra or other residual herbicides at the recommerded rate.
Or apply a pre-emergence residual herbicide at the recommended
rate tank-mixed with Roundup WeatherMAX* at a minimum of
22 02 /A In-crop before weeds exceed 4" in height.
Follow with 3 poslemergencs fn-crop application of Roundup
WeatherMAX at a minimum of 22 oz/A for additional weed
flushes before they exceed 4" In height.
Roundup WeatherMAX may be tank-mixed v/ith other herbicides
fw postemergence weed control.
Report repeated non-performance to Monsanto or your
local retailer.
RECOMMENDATIONS FOR MANAGING GLYPHOSATE-RESISTANT WEEDS IN PRODUCTS
WITH ROUNDUP READY TECHNOLOGY
Glyphosate-Resistant
Marestail (Horseweed)
.instructions; AND USE RATES*.'
Start clean with a burndown program or tillage.
-Tank-mix Roundup agricultural herbicides with 2.4-D. or dicamba, according to the label directions.
In-crop, tarrh-mix 22 ounces per acre of Rormdup WeatherMAX with Clarity® (8 to 16 fluid ounces per acre) or 2,4-0
(0.5 to 1.0 Ib active Ingredient per acre) from corn emergence to the S-leaf stage ol corn growth (approximalety 8" tall).
Or tank-mix 22 ounces per acre of Roundup WeatherMAX with 5 ounces per acre of Status® herbicide when the corn is
4" to 36" ta!l{V2loV10).
Marestail should not exceed 6“ in height at the time of in-crop aptriicalion.
Glyphosate-Resistant
Amaranthus Species
- Palmer Amaranth
-Waterhemp
Start clean with a burndown program or tillage.
Use 3 residual herbicide such as Harness Xlra. Harness Xtra 5.6L, Degree Xtra or other residual herbicide either
preemergence or in-crop for control ol Amaranlhvs species.
In-crop, tank-mix Roundup WeatherMAX with other herbicides such as 2,4-0, dicamba (Ciarity or Banvel®) or Status
herbicide to control emerged weeds. Applications of Status herbicide should be made when the corn is between
4“ and 36“ tail {V2 to VIO). Follow all label directions.
Amaranlhus spedes should not exceed 3“ in height at the lime of in-crop application.
(flyphosate-ResIstant
Ambros/a Species
> Giant Ragweed
‘(^rnmon Ragweed
Glyphosate-Resistant
Johnsongrass
Start clean with a burndown program or tillage.
Use a residual herbicide such as Harness Xtra, Harness Xtra 5.6L Degree Xtra or other residual herbicide cither
preemergence or in-crop for control of Ambrosia species,
In-cfop, tank-nvx Roundup WeatherMAX with other herbiddes such as 2.4-D. dicamba (Clarity or Banvel) or Status
herbicide to control en^rged weeds. Applications of Status herbicide should be made when the corn is between
4" and 36" tali (V2 to VIO). Follow all label directions.
Ambrosia specie should not exceed 3" in height at the time of in-crop application.
Start clean with a burndown program or Ullage.
Use 3 residual herbicide such as Harness Xlra, Harness Xtra 5.6L. Degree Xtra or other residual herbicide containing
atrarine preemergeiKe to reduce the competition from seeding [ohnsongrass prior to the ensergence of corn
In-crop, tank-mix Roundup WeatherMAX with a herbicide such as Accent®. Equip" or Option® for control of emerged
weeds including seedling and rhizome johnsongrass. Follow all label directions of tank-mix partners, especially those
related to weed size.
in certain areas, Italian ryegrass is known to he resistant to glyplwsate For control recommendations, refer to wHW.we8dresistancemanagemeRt.com
or call 1-800-763-6387, When approved, supplemental labeling lor speciFic terbickJe products cm also be viewed on wHW.edms.net or wvnv.greenbook.net.
2010 TECHNOLOGY USE GUIDE
1495
1496
Genuity" Bollgard 11* and Bollgard* Cotton Descriptions
-
H
Eollsstdll
GENUITY"' BOLLGARD W COTTON
Genuity'" Bollgard IP cotton contains two distinct insecticidal
proteins from Bacillus thuringiensis (B.t) that increase the efficacy
and spectrum of control and reduce the chance that resi^ance
will develop to the at. insecticidal proteins, relative to Bollgard'’
cotton. Genuity" Bollgard 11* cotton normally provides excellent,
season-iong control of tobacco budworm. pink bollworm and
cotton bollworm. Genuity'" Bollgard IP cotton provides good
protection against fall armyworm, beet armyworm, cabbage
and soybean loopers and other secondary leaf- or fruit-feeding
caterpillar pests of cotton, Applications of insecticides to
control these Insects are substantially reduced with Genuity"
Bollgard IP cotton.
Bollgard
BOLLGARD' COTTON
Bollgard cotton contains a single insecticidal protein from
B.L that provides good control against three major lepidopteran
insect pests of cotton. Specifically, Bollgard cotton provides
excellent, season-iong control of tobacco budworm and pink
bollworm, and suppression of cotton bollworm. When the
above-mentioned Insect larvae feed on Bollgard cotton plants,
the 8.t. protein protects the plants from damage by reducing
larval survival. Under high infestation, application of insecticides
may be necessary to protect Bollgard cotton.
1 The U.S. Environmental Protection Agency has mandated
' the following terms and conditions:*
i • Bollgard* cotton may be sold through September 30. 2009. After that
date, oil sales of Bollgard cotton are prohibited.
* All Bollgard cotton seed must be planted by midnight of July l, 2010
(the expiration dale of the Bollgard cotton registration). After July i.
2010, planting of Bollgard cotton seed Is prohibited. Any Bollgard cotton
i seed not planted on or before July 1, 2010. must be returned to either
the retailer or to Monsanto. No refunds are to be issued on Bollgard
cotton seeds bought lor planting in 2010 and returned by growers.
• An adequate amount of refuge seed must be purcha^d for planting
an appropriate refuge for Bollgard cotton. Purchase of refuge seed
I with the Bollgard cotton seed is mandatory, and such seed must be
I purchased by growers in advance of their receipt of Bollgard cotton
seed. Any seed purchased for use as a refuge Is nort-refundable,
unless the proportional amount of Bollgard cotton seed that the
refuge seed would have supported is returned at the same time,
• Any order for replacement or additional Bollgard cotton seed for
the 2010 planting season, that does not conform to the requirements
stated above must pe filled with Genuity” Bollgard li* cotton seed
(or other products with current registrations),
• On*farm IRM assessments will be conducted during the planting season.
• In 2010. Bollgard cotton may only be planted In: Alabama, Arkansas,
Florida (North of Florida Route 60), Georgia. Kentucky, Louisiana,
Maryland. Missouri Mississk^pi, North Carolina, South Carolina,
Tennessee. Texas (excluding the ten prohibited Texas panhandle counties
of: Dallam. Sherman. Hansford, Ochiltree, Lipscomb, Hartley, Moore.
Hotchlnsoa Roberts, and Carson) and Virginia.
’It Is a violation of federal law to sell or distribute art unregistered pesticide.
NOTE: Sale or commercial planting of Bollg3rd’’cotton is prohibited In
certain states, inciuding: Artrona, California, Colorado. Kansas. New Mexico
and OMaho.ma.
Sale or planting of Bollgard is prohibited in trte Texas counties of: Carson,
Dallam, Hansford, Hartley, Hutchison, Lipscomb, Moore, Ochiltree, Reverts,
attd Sherman,
Sale or commercial planting ol both Genuity" Bollgard II* and BcHlgard
is prohibited In Hawaii, Puerto Rico, the U.S. Vlrgitr Islands, and In Florida
south ot Route 60 (near Tampa).
The at delta enctotoxrn protein expressed in this cotton targets certain cotton
krsect pests. Routine applications of insecticides to control certain insects are
usually unnecessary when cotton containing the B.t. delta endatoxin protein Is
plw.led. However, II Insecticide applications are necessary to control certain
cotton insect pests, follow all label requirements.
2010 TECHNOLOGY
1497
COTTON TECHNOLOGIES i
Genuity’“ Bollgard il® and Boilgard’^ Cotton
INSECT RESISTANCE MANAGEMENT (IRM)
Lepidopteran cotton pests have demonstrated the ability
to develop resistance to many chemical insecticides. As a pre-
emptive measure, Genuity” Bollgard il* and Bollgard' cotton roust
be managed in ways that will retard insect resistance development.
These practices are designed to ensure that some lepidopteran
populations are not exposed to the S.l. proteins so they can
maintain susceptibility in select populations, in order to achieve
this, refuge cotton that does not contain at. proteins must
be planted.
GENUITY^” BOLLGARD II - DUAL EFFECTIVE DOSE
Resistance management Is critical to the long-term viability
of our technology and the beneiits realized by our farmer
customers. 2010 Is a transition year for Monsanto at. cotton
products as we shift alt U.S. cotton acres toward the two-gene
Insect control product. Genuity” Bollgard il* cotton. The move
to multiple-gene products, including Genuity” Bollgard ir. offers
dual effective modes of action against target insect pests,
increasing the longevity of the technology.
INTEGRATED PEST MANAGEMENT {IPM)
Integrated Pest Management (IPM) Is an effective and environ-
mentally sensitive approach to pest management that relies
on a combination of common-sense practices. iPM programs use
current, comprehensive information on the life cycles of pests
and their interaction with the environment. This information
Is used to manage pasts In a manner that is least harmful
to people, property and the environment
Prevention
Using the best agronomic management practices in conjunction
with the appropriate cotton varieties will yield the greatest benefits.
Use varieties, seeding rates and planting tectmologies
appropriate for each specific geographical area. As much
as possible, manage the crop to avoid plant stress.
• Employ appropriate scouting techniques and treatment decisions
to preserve beneficial insects that can provide additional insect
pest control,
• Manage for appropriate maturity and harvest schedules, destroy
stalks immediately after harvest to avoid regrowth and minimize
seiectirm for resistance in late-season infestations.
• Use soli management practices that encourage destruction
of over-wintering pupae
Monitor and identify
Fields should be carefully monitored for all pests, including cotton
bollworms, to determine the need for remedial insecticide treat-
ments. For target pests, scouting techniques and supplemental
treatment dea'slons should take into account the fact that larvae
must hatch and feed before they can be affected fay the &(.
protein(s) in either Genuity” Bollgard II* or Bollgard ootton. Fields
should be scouted regularly, following periods of heavy or sustained
egg lay. especially during bloom, to determine if significant larval
survival has occurred. Scouting should include a modified whole-
plant inspection, including terminals, squares, blooms, bloom tags
and small bolls. Larvae larger than 1/4 inch (3- to 4-days old) are
generally recognized as survivors that may not be controlled
by Genuity” Bollgard 11® or Bollgard cotton.
Read the IRM/Grcwer Guide prior to planting for infor-
mation on planting and Insect Resistance Management.
If you do not have a copy of this Guide, you may download
it at www.monsanto.com, or call 1-800-768-S387 to
request a copy by mail.
Control
Monsanto recommends the use of appropriate remedial
insecticide treatments to ensure desired levels of control
if any cotton insect pest reaches locally established thresholds
in Genuity” Bollgard 11' or Bollgard cotton.
Although Genuity” Bollgard II" and Bollgard cotton will sustain
less damage from some of the most troublesome lepidopteran
pests, they will not provide protection against non-lepidopteran
species. These insects should be monitored and treated with
insecticides when necessary, using recommended thresholds.
Whenever possible, select insecticides that are ieast harmful
to beneficial insects.
NOTf: Ift 2010, salegr conimercial planlin® of Bollgard* coUoii ts prohibHed in the follDsvInq
dates: Arieona, Calilojnla. Cdorada, Kansas, New Ms«lca and Oklahoma,
InZOtO, sale or pfenting of Boitgard' Is prohlhited in the Texas counties of: Carson. Dallam,
Kanstanf, HarlleY. Hutchison, Lipscomb. Mo-ire, Ochiltree, Rsbarts, and Sherman.
InZOC. sSa or ecmmercial planting of hoSh Genuity' Bollgard il‘ end Bollgard’ is prohibited in
Hawal. Puerto fSco. and the U.S. Virgin Islands, or in Florida soulii of Rouie 60 (near Tampa).
MONSANTO
1498
Roundup Ready® Cotton, Genuity" Bollgard II* with Roundup Ready*
Cotton and Bollgard with Roundup Ready Cotton
ROUNDUP HEADY COTTON
Roundup Ready® cotton varieties contain in-plant tolerarKe
to Roundup* agricultural herbicides, enabling tarmers to
make in-crop applications of Roundup WeatherMAX® or
Roundup PowerMAX* according to label requirements.
GENUITY- BOLLGARD II WITH ROUNDUP READY
COTTON AND BOLLGARD WITH ROUNDUP READY
COTTON
Genuity- Bollgard IP with Roundup Ready* cotton and Bollgard
with Roundup Ready varieties offer farmers the benefits of both
Insect protection and glyphosate tolerance combined In one
crop. These varieties exhibit the same insect protection quaiitles
as Get^uity- Boiigard IP and Bollgard cotton and enable farmers
to make in-crop applications of Roundup WeatherMAX or
Roundup PowerMAX according to label requirements.
MARKET OPTIONS
Gin by-products of cotton containing Monsanto’s biotech trails,
including cottonseed for feed uses, are fuliy approved for export
to Canada, Japan, Mexico and South Korea. Cottonseed containing
Monsanto traits may not be exported for the purpose of
planting without a license from Monsanto,
it Is a violation of national and International law to move
material containing biotech traits across boundaries into
nations where Import Is not permitted.
RECOMMENDED MANAGEMENT PRACTICES
Managing Roundup Ready cotton, Bollgard with Roundup Ready
cotton and Genuity-Boligard II' with Roundup Ready’ cotton
requires that a farmer follow the recommended management
practices associated with cotton containing each individual trait.
Farmers of Bollgard with Roundup Ready cotton and Genuity-
Boligard IP with Roundup Ready’ cotton varieties must follow
the same guidelines for establishing required refuge options,
practicing IRM and managing target and non-target pests as
described for Bollgard and Genuity- Boiigard IP cotton in the
tRM/Grower Guide.
APPLICATION OF ROUNDUP WEATHERMAX"
AND ROUNDUP POWERMAX’
Roundup Ready cotton is geneticelly
improved to provide tolerance to
glyphosate, the active ingredient in
Roundup agricuitura! herbicides.
Roundup Ready cotton can receive
over-the-lop applications of Roundup
agricultural herbicides only through the
four-ieaf stage. With the introduction
of Genuity- Roundup Ready® Flex cotton, there is the potential
for both Roundup Ready cotton and Genuity- Roundup Ready"
Flex cotton to be used on a farmer’s farm. This creates concern
for the crop safety of Roundup Ready cotton. Monsanto
recommends that farmers:
• Maintain accurate records of which technologies have bean planted
and where they have been planted.
• Communicate the field plan with other members of their work
force to ensure proper applications for each technology.
• Clearly mark fields to indicate which technology has been planted.
WEED RESISTANCE MANAGEMENT GUIDELINES
Follow all pesticide label requirements end these guidelines
to minimize the risk of developing glyphosate-resistant weed
populations in a Rcwndup Ready cotton system:
• Scout fields before and after each burndown and I'n-crop application.
• Start clean with a burndown herbicide program or tillage.
• Use the right herticlda product at the right rate arid right time,
• Add soil residual herblcidefs) and cultural practices as part
of a Roundup Ready weed control program.
- In-crop, apply Roundup WeatherMAX at a minimum of 22 oz/A
when weeds are less than 6" in height.
• Tank-mix other approved herbicides with Roundup WeatherMAX
if necessary fw postemergence weed control.
• Clean equipment before moving from field to field to minimize
the spread of weed seed (as well as nematodes, insects and other
cotton pests).
• Should repeated non-performance occur, report to Monsanto
or your local retailer.
nMCzrixcowrir.
Mora-tfivn fWj Po«t.Uf»ct,
2010 TECHNOLOGY USE GUIDE
1499
COTTON TECHNOLOGIES
WEED CONTROL RECOMMENDATIONS
Weed control in cotton Is essentia! to help maximize both fiber
yield and quality potential. Cotton is very sensitive to early-
season weed competition, which can result in unacceptable
stands and/or reduced yield potential. The Roundup Ready’
cotton system provides farmers with the right tools to control
weeds before they become competitive.
% INSmUCTIONS AND USE RATES^
I ADDlTJONAt; INFORMATION c
Preptant Burndown Always start clean by planting mto a weed-free field using
either tillage or a bumdown ai^ication.
Eariy-season weed competition can result in unacceptable
stands and/or reduced yield potential.
in no-til! and reduced-till systems, api^y a (vepfant tHfliid(»iin
application of Roundup WeatherMAX®** si 2 to 44 oz/A h a
tank-mix with dicamba or 2.4-D.
Btis tank-mix is recommended for control and management
of glyphosate-resistant msrestail {Conyza sp.) or other
tough-to-control weeds.
See the dicamba and 2,4-0 product label for rates and time
intervals required between applicaticm and cotton piantii^.
State restrictions may apply.
Burndown application should be made far enough
in advance of planting to control existing weeds.
Residual Herbicides
Apply residual herbicidefs) as part of a Roui^iq) Ready cotton
weed control program. Use the recommended label rale and
timing of the residua! herbicide applied. Refer to individual
product labels for list of residual herto'cides that may be used.
The residuat herbicide(s) may be applied as either a
preemergence (including preplant Incorporated),
postmergence, and/or layby application as allowed
on the iabd of the specific product being used.
Over-The-Top
through
Fourth Leaf
Apply Roundup WeatherMAX over (he top from crop emergence
through the fourth true-lsaf (node) stage (until the fffthtrue
leaf reaches the size of a quarter).
Two applications can be made during this period at a maxirmjm
rate of 22 oz/A per application.
Refer to the "Annual Weeds Rale Table" in the Roundup
WeatherMAX label for rate recommendations for specific
annual weeds.
fn-crop over-the-top applications must be at least 10 days apart
and the cotton must have at least two nodes of incremental
growth between applications. Care should be taken to record
growth stage at first application.
In situations where the potential for weed infestations is high
(including perennial weeds), make the first application eariy
enough to allow a second application before cotton exceeds the
fourth true-leaf staga Over-the-top applications after the fourth
true-leal stage can result In boll loss, delayed maturity, and/or
yield loss.
Selective Equipment
After the fourth true-leat stage through layby. Roundup
WeatherMAX may be applied using precision post-directed
or hooded sprayers which direct the spray to the base of
the cotton plant.
Two post-directed applications can be made during this period
at a maximum rate of 22 oz/A per application.
Place nozzles in a tow horizontal position to permit spray
pattern to overlap In the row while contact ol spray solution
with cotton leaves should be avoided lo the maximum extent
possible. Excessive foliar contact can result in boll loss, delayed
malurity. and/or yield loss.
There must be two nodes of growth and at least 10 days between
applications.
Preharvest
Over-The-Top
Applications
Before harvest and after cotton reaches 20% boil-crack, if
needed, apply up to 44 oz/A of Roundup WeatherMAX,
This treatment is effective in controlling lale-season perennial
weeds and can improve harvest efflciency.
Applications must be made at least 7 days prior to harvest.
Roundup agricultural herbicides are not effective for
preharvest cotton regrowth in Roundup Ready cotton.
Do not apply Roundup agricultural herbicides preharvest
to crops grown tor seed under contract at an authorized cotton
seed company.
Roundup Ready cotton has excellent vegetative tolerance to Roundup WealtierMAX allowing eariy-season over-the-top applications, incompiete
reproductive tolerance requires that opplicatlons alter the 4-leaf (node) stage be property post-directed.
ATTENTiON: Use of Roundup agricultural herbicides in accordance with label directions is eqwcted lo result in normal growth of Roundup Ready cation,
however, various environmental conditions, agronomic practices, and other factors make it impossible to eliminate all risks associated with the product,
even whet? applications are made in conformance with the label specifications. In some cases, these factors can result in bolt loss, delayed maturity,
and/or yield loss.
•Foilcw al! peslicide label fsquircrrsents.
”11 using anollieffiB«r>flupagri{ullufalhe(biC''clc.vou must refer io the IrfiiH bockfet « fiouirfop neartraiMonsumilenieiital bbelfon thal hrar>!l to fleUrminc appropfiofeus# rales. If using
Roundup PDB5fMAX’, appilcattan rales are Ihe same as for Roiardop WealhsrUAX.
1 MONSANTO
1500
RECOMMENDATIONS FOR MANAGING GLYPHOSATE-RESISTANT WEEDS
WEEDS I INSTRUCTIONS AND USE RATESf.
Glyphosate-Resistant Start dean with a burndown heitldde program tiSage.
Marestail (Horseweed) -Tanii-mix Roundup agricidtoral herbicides wHi dicamba or 3.4-0 {consult label for plant bad! timing).
|{ you have dense stands ol marestail, me a preplant residua! herbicide at the recommended rate and
timing, such as diuron {Direx®)or fiumioxazin (Vator*).
Use Roundup WeatherMAX hi-crop, as needed at a minimum of 22 oz/A to control other weeds.
in-crop, it applying post-directed to gl^hosateresistaftf merestaii. Roundup WeatherMAX can be tank-mixed
with other herbicides, such as dturai or MSMA.
Marestail should be less than 6" in height at the time of in-crop application.
Glyphosate-Reslstant
Amaranthus Species
■ Pa/mer Amaranth
- Waterhemp
Start clean with a burndown herbitide program or tifiage.
Apply a preemm'gence residual herbidde such as pendimethaiin (Prowi^) plus fluometuron or fomesafen
{Reflex®) or flimitoxazin (\tetor} for control of Amaranthus species.
in-crop, tank-mix Roundup WeatherMAX at 22 ozM with metoiachlor or other labeled chloracetamide herbicide
before Amaranthas species emerges.
Use Roundup Weath^MAX in-crop, as needed, at a minimum of 22 oz/A to control other weeds.
A post-directed application of Roundup WeatherMAX tank-rmxed with MSMA and a residua! such as diuron
iOirex) or flumioxazin (Valor) should be made to control Amaranthus species 3" or smaller in height and
prevent additional firnhes.
Glyphosate-Reslstant
Ambros/a Species
- Giant Ragweed
• Common Ragweed
Start clean with a burndown herbicide program or tillage.
Apply a preemergence residual herbicide such as pendimethaiin (Prowl) plus fluometuron or fomesafen
(Reflex)lor cor^trti of Ambrosia species.
In-crop, tank-mix Roundup WeatherMAX at 22 ozIA with metolachtof before Ambrosia species emerges.
Use Roundup WeatherMAX in-crop, as needed, at a minimum of 22 oz/A to control other weeds.
A post-directed application of Roundup WeatherMAX tank-mixed with MSMA and a residual such as diuron (Dfrex) or
flumioxazin (Valor) should be made to control Ambrosia species 3" or smaller In height and prevent additional flushes.
Glyphosate-Reslstant Start clean with a burndown herbicide or tillage.
dohnsongrass Preplan! incorporate a residual herbicide such as pendimethaiin or trilluralln for control or suppression of seedling
Johnsongrass.
Apply Roundup WeatherMAX in a tank-mix with herbicides such as SelectMAX®, Assure® il or Poesl Plus for the control of
emerged weeds uicluding seedling and rhizome johnscmgrass. Follow ^1 label directions of tank-mix partners, especially
those related to weed size.
In certain areas. Italian ryegrass Is known to be resistant to glyiAiosale. For contcoi recommendations, refer to www.weedresl5tancemanagement.com
or call I-800-7&8-G387. When approved, supplemental labekng for spedfic herbicide products can also be viewed on www.cdms.net or wwvr.greenbQok.net.
'Fctlow all pssilclde li&e) rvqulremmls.
2010 TECHNOLOGY USE GUIDE
1501
COTTON TECHNOLOGIES
Genuity” Roundup Ready' Flex Cotton and
Genuity” Boilgard 11" with Roundup Ready' Flex Cotton
Roundup Rsaiy Flex
GENUITY’“ ROUNDUP READY' FLEX COTTON
Genuity Roundup Ready* Flex cotton varieties possess Improved
reproductive tolerance to Roundup* agricultural herbicides. This
technology gives farmers the opportunity to make over-the-top
broadcast applications of labeled Roundup agricultural herbicides
from crop emergence up to seven (7) days prior to harvest.
GENUITY'* 60LLGARD IP WITH ROUNDUP READY*
FLEX COTTON
Genuity“ Boilgard II* with Roundup Ready* Flex varieties offer
farmers the benefits of both insect protection and giyphosate
tolerance combined in one crop. These varieties exhibit the
same insect protection qualities as Genuity" Boilgard ir* and are
tolerant to over-the-top applications of Roundup WeatherMAX*
and Roundup PowerMAX®.
MARKET OPTIONS
Genuity'" Roundup Ready*' Flex cotton and Genuity" Boilgard M"
with Roundup Ready Flex cotton have regulatory clearance
In the United States, but do not have import approval In all
export markets. Processed fractions from these products,
including linters, oil, meal, cottonseed and gin trash, must not
be exported without all necessary approvals in the Importing
country. It Is a violation of national and International law to
move material containing biotech traits across boundaries
into nations where import Is not permitted.
RECOMMENDED MANAGEMENT PRACTICES
Managing Genuity" Roundup Ready** Flex cotton and Genuity"
Boilgard II* with Roundup Ready® Flex cotton requires a farmer
to follow the recommended management practices associated
with cotton containing each individual trait. Farmers of Genuity"
Boilgard If" with Roundup Ready*" Flex cotton must follow
the same guidelines for establishing required refuge options,
practicing IRM and managing target and non-target pests as
described for Genuity" Boilgard li’ cotton in the IRM/Grower Guide.
WEED RESISTANCE MANAGEMENT GUIDELINES
Follow all label requirements end the guidelines below to
minimize the risk of developing weed resistance in a Genuity"
Roundup Ready® Flex cotton system:
• Scout fields before and after each burndown and
in-crop application.
• Start clean with a burndown herbicide program or tillage.
• Use the right herbicide product at the right rate and right time.
• Add soil residual hsrblc!de(5) and cultural practices as part of
a Genuity'" Roundup Ready* Flex cotton weed control program.
• In-crop, apply Roundup WeatherMAX at a minimum of 22 oz/A
when weeds are 3" to 6" in height.
• Tank-mix other approved herbicides with Roundup WeatherMAX
If necessary for postemergence weed control.
• Should repeated non-performance occur, report to Monsanto or
your local retailer.
• Clean equipment before moving from field to field to minimize the
spread of weed seed (as well as nematodes, insects and other
cotton pests).
APPLICATION OF ROUNDUP WEATHERMAX’ AND
ROUNDUP POWERMAX'
• May be applied over-the-top and/or in-crop, from crop emergence
up to 7 days prior to harvest.
• A maximum rate of 32 oz/A per application may be applied using
ground application equipment while the maximum is 22 oz/A per
application by air.
• There are no growth or timing restrictions for sequential
applications.
• Four (4) quarts/A is the total in-crop votume allowed from
emergence to 60% open bolls.
• A maximum lota! volume of 44 oz/A may be applied between
layby and 60% open bolls.
• Post-directed equipment may be used to achieve more thorough
spray coverage of weeds or if herbicides not labeled for over-
the-top application will be tank-mixed with Roundup WeatherMAX
or Roundup PowerMAX.
MONSANTO
1502
PREHARVEST APPUCATiONS
• Up to 44 02 /A may be applied after cotton reaches 60% open bolls
and before harvest, If needed.
■ Applications must be made at least 7 days prl(x to harvest
Over-The-Top (example)
22-32 oz/A In any single application
128 oz/A total in-crop application (emergence to preharvest)
T~~E — I — I
Preharvest
44 oz/A
CROP SAFETY OF OVER-THE-TOP GLYPHOSATE
APPLICATIONS
Monsanto has determined that a combination of components in
glyphosate formulations have the potential to cause leaf injury
when applied during later stages of crop growth. Roundup
WeatherMAX and Roundup PowerMAX are the only Roundup
agricultural herbicides labeled and approved for new labeled
uses over the top of Genuity” Roundup Ready* Flex cotton.
Leaf injury may occur if the products are not used according
to the product label, used at higher than recommended rates
or if overlap of spray occurs in the field. Farmers must confirm
that any glyphosate formulation to be used on Genuity”
Roundup Ready* Flex cotton has been labeled for use on
Genuity” Roundup Ready* Flex cotton and should confirm
that it has been tested to demonstrate crop safety.
2010 TECHNOLOGY USE GUIDE
1503
COTTON TECHNOLOGIES
WEED CONTROL RECOMMENDATiONS
Weed controi in cotton is essential to maximize both fiber yield
and quality potential. Cotton is very sensitive to eariy-season
weed competition, which can result in unacceptable stands and/
or reduced yield potential. The Genuity'“ Roundup Ready* Flex
cotton system, with Improved reproductive tolerance to
Roundup® agricultural herbicides, provides farmers with the
right tools to control weeds.
PROGRAM
INSTRUCTIONS AND USE RATES' . . ’ - :
ADDITIONAL INFORMATION "" \ '
Preplant Burnaown
Always start clean by plantino into a weed-free Reid
using either tillage or a burndown
Early-seasfflt weed competition can result in unacceptable stands
andAir reduced yield potential.
In no-iill and reduced-till s^t«ns. ai^iy a prefdant
burndown application of Roundup WeatfterMAX®**
at 22 to 44 07/A in a tar^-mix with dicamba (v Z.4-D.
This tank-mix is recommended for control and management
of glyphosate-resislant maresteil iConyiasp.) or other lough-
to-controi weeds.
See the dicamba and 2.4-6 podud label for rates
and time Intervals required tetween ai^ication
and cotton planting. State reslricticxis may ^ply.
Burn] own apj^ication should be made far enough
in advance of planting to control existing weeds.
Residual Herbicides
Apply approved resMual herbkidets) as part of a
Genuity"" Roundup Ready® Flex cotlwi weed control
program. Use the reccrniir^nded label rale and timing
of the residual herbicide af^lied. Refer to individual
product labels for list of residual herbicides that may
be used.
The readuai herbicidefs} may be applied as either
a preemergence (including preplan! incorporated),
postemergence, and/or layby application as allowed
on the label of the specific product being used.
In-Crop Weed Control
Target the first application of Roundup WeatherMAX
on 1-2 leaf cotton when weeds are small.
Eariy-season weed competition can reduce yield potential
in cotton.
Apply a minifimm of 22 or/A of Roundup WeatherMAX
in-crop.
Select lining of application based on the most difficult
to control weed species in your field.
Ibe need for sequential applications of Roundup
WeatherMAX will depend upon the occurrence of
subsequent weed flukes.
Post-direct or hooded sprayers can be used to achieve
more thorough spray coverage on weeds.
Refer to the "Annual Weeds Rate Table"" in the
Roundup WeatherMAX label booklet for rate
recommendations for specific annual weeds.
Praharvest Ovar-The-Top
Applications
Seloffi harvest and after cotton reaches 60%
open bolls, if needed, apply up to 44 or/A of
Roundup WeatherMAX.
This treatment is effective in cwitrollinq late-season
perennial weeds.
Applications must be made at least 7 days prior to harvest,
Roundup agricultural herbicides are not effective for preharvesl
cotton regrowth in Genuity* Roundup Ready® Flex cotton.
Tollovi all pesticide label reau!re<b(inls.
-'The maximum vofume o' Roundup VieetnerMAX and noun*»PowefMAX» ilal ma-/ be used in a stfigte mscnis 5,3 quarts per acre.
MONSANTO
1504
Roundup ReaSy Flex
RECOMMENDATIONS FOR MANAGING GLYPHOSATE-RESISTANT WEEDS
,s ' I INSTRUCTIONS AND:USERATES'
Giyphosa^e-Resistant
Msrestai! (Horseweed)
Start clean with a iHR'ndown hertficide pn^f^ortifiage.
-Tank-mix Roundup agricultural terWddes with dicamba or 2.4-0 (consult label for plant back timing).
If you have dense stands of rrjaresWf, use a prej^anl residual herbicide at the recommended rate and
timing, such as dioron (Direx*) or fiuirdoxaan (fttor'*).
Use Roundup ¥(68therMA){ in-cn^ as neerfed, at a nwimum of 22 oz/A to control other weeds.
In-crop, if applying post-directed togiyffiwsate-resistant mareslaii, Roundup WeatherMAX can be tank-mixed
with other herbicides, such as {fiivon or MSMA.
Maresiail should not exceed 6” In hdght at Uie time of in-crop application.
Glyptiosate*Resistant
/Imaranfftus Species
- Palmer AmBranth
■ Wateriiemp
Start clean with a burndown heri^icide program or tillage.
Apply a preemergence residual herbitide such as pendmethalm (Prowt®) plus fluometuron or fomesafen
(Reflex®) or Humioxazm (Vafor) f(ff control of Amaranfhos species.
In-crop, tank-mix Roundup WeatherMAX at 22 oz/A with metofachlor or other labeled chloracetamfde herbicide
before Amarsnttius species emerges
Use Roundup WeatherMAX In-crop, as needed, at a minimum of 22 oz/A to control other weeds.
A post-directed application of Roundup WeatherMAX tank-mxed with MSMA and a residual such as diuron
(Oirex) or flumioxazin (Valor) should be mads to control Amaranthus species 3" or smaller in height and
prevent additional flushes.
Glyphosate-Resistant
Ambrosia Species
- Giant Ragweed
• Common Ragweed
Start clean with a burndown herbicide program or tillage.
Apply a preemergence residual herbicide such as pendimethalin (Provd) plus fluometuron or fomesafen (Reflex)
for control of Ambrosia species.
in-crop, tank-mix Roundup WeatherMAX at 22 oz/A with metotacWor before Ambrosia species emerges,
Use Roundup WeatherMAX in-crop, as needed, at a minimum of 22 oz/A to control other weeds.
4 post-directed application of Roundup WeatherMAX lank-mixed with MSMA and a residual such as diuron
(Direx) Of flumioxazin (Valor) should be made to control Ambrosia species 3" or smalier tn height and prevent
additional hushes.
Glyphosate-Resistant
Johnsongrass
Start clean with a burndown herbicide or tillage.
Preplant incwporate a residual herbicide such as pendimethalin or (rifluralin for control or suppression of seedling
johnsongrasi
Apply Rourrdup WeatherMAX in a tank-mix with herbicides such asSeleclMAX', Assure^ li or Poast Plus for the control of
emerged weeds inclulicrg seedling and rhizome johnsongrass. Follow all label directions of tank-mix partners, espectally
those related to weed size.
in certain areas, llalisn ryegrass is Rnavm to be resislanl to gtyphosale. for control recommendations, refer to vfww.wBedr6sistanc6inanBgem6nt.com
or call 1-800-768-6367. When approved, supplemental labeimg for specific herbiade products can also be viewed on wvfw.cdm$.net or www.greBnbook.net.
'ffllicw alt pasliciils iflBel rcfliiiremenit.
2010 TECHNOLOGY USE GUIOI
1505
1506
■ I
GENUITY” ROUNDUP READY 2 YIELD‘ , i
AND ROUNDUP READY® SOYBEANS _ ! .
Genuity'" Roundup Ready 2 Yield® and Roundup Ready® soybean
varieties contain in-plant tolerance to Roundup® agricultural
herbicides. This means you can spray Roundup agricultural
herbicides in-crop from emergence through flowering.
Spray labeled Roundup agricultural herbicides over the top from
emergence (cracking) through flowering (R2 stage soybeans)
for unsurpassed weed control, proven crop safety and maximum
yield potential. R2 stage soybeans end when a pod 5 millimeters
(3/16") long at one of the four uppermost nodes appears on the
main stem along with a fully developed ieaf (R3 stage).
WEED CONTROL RECOMMENDATIONS
Starting ciean with a weed-free field, and making timely post-
emergence in-crop applications, is critical to obtaining excellent
weed control and maximum yield potential. The Roundup Ready
soybean system provides the flexibility to use the herbicide tools
necessary to control weeds at planting and in-crop. Failure to
control weeds with the right rate, at the right time and with the
right product, can lead to increased weed competition and the
potential for decreased yield.
PROGRAM INSTRUCTIONS AND USE RATES* ^
Preplant Burndown To start dean in no-lill systems, apply a burndown application
of Roundup WealherMAX®** at 22 to 44 oz/A before Ranting.
See the label for appropriate rates by weed species. For control
and management of glyphosate-reslstant marestail {Ccnyza sp.)
or other diflicull*to-conlrol weeds present at burndown, apply
22 oz/A of Roundup Weather MAX in a tank-mix with I to 2 pt/A
2,4'D, Make applications 7 to 30 days before planting and before
mamstail reaches 6" in height
Residual Herbicide Use the recommended label rale oi a soil-applied residual
Plus Roundup herbicide applied preemergence to soybeans as defined in
WeattierMAX the individual product's labeling. The residual product may be
tank-mixed with Roundup WeatherMAX at burndown. Refer to
individual product labels (or list of residual herbicides that
may be used.
Follow vrith 22 oz/A Roundup WeatherMAX in-crop when weeds
are 2" to 8“ tall. Refer to the "Annual Weeds Rale Table" in the
Roundup WeatherMAX label for rats recommendations for
specific annual Y/eeds.
Crop rotation following Genuity’ Roundup Ready 2 Yield® and
Roundup Ready soybeans is strongly encouraged. Use of a
residual herbicide is encouraged especially if the cropping
system Is a continuous Roundup Ready system.
Roundup WeatherMAX Apply a minimum of 22 oz/A of Roundup WeatherMAX"
in-crop when weeds are 2" to 8" tall.
Refer to the "Annual Weeds Rate Table" in the Roundup
WeatherMAX label for rale recommendatlims for specific
annual weeds. Choose the rate to contrri the most difficult*
lo-contfoi weed in your field.
A sequential application of this prixtuct may be requred
to control new flushes of weeds in the Roundup Ready
soybean crop.
If a sequential application is necessary, api^y 16 to 22 oz/A of
Roundup WeatherMAX" when weeds are 3" to 6" tali.
AbblTIpNAL INFORMATION
Always start with a weed-free field. In no-till and reduced-till
systems, apply a Roundup WeatherMAX' burndown application
to control existing weeds before planting.
Adding 2,4-D In the burndown can significantly reduce
broadieaf weed pressure at post-emergence timing.
Read the 2,4-0 product label for time Intervals required
between application and soybean planting.
A residual program is encouraged when agronomic conditions
favor the practice.
Reducing Roundup WeatherMAX rale when tank-mixing with
a residual or use of premixes utilizing a reduced rate of
glyphosale (such as Extreme®) is not recommended. If the
in-crop application is delayed and weeds are larger, apply a
higher rale of Roundup WeatherMAX.
In-crop application of Roundup WeatherMAX provides control
of labeled weeds.
For best results, apply 3 to 4 weeks after planting or
when weeds are less than 8" tall.
If initial application is delayed and weeds are larger,
apply a higher labeled rate of Roundup WeatherMAX.
EcIIqm all pesticld; ial)Sl requirsnisnts.
If using another Roundup agricultural tierbiclde, you rrrust rater to the lal^ bookie a-6«nuSy'RotRidt{pl^ady Z Yielil’'soyt>ear\QrRnirnri<fp Ready soybean supplemental la
brand to delermine appropriate use rates. If using RoundupPtnverMAX.aptdkalicn rates are the same as ter Roundup WeattierMAX.
2010 TECHNOLOGY USE GUIDE
1507
GENUITY” ROUNDUP READY 2 YIELD“
AND ROUNDUP READY® SOYBEANS
: PROGRAM "
INSTRUCTIONS AND USE RATES*
ADDITIONAL INfORMATION
Glyphosats-Toierant
Volunteer Corn
Tank-mix Roundup WeatherMAX* wWi 6 to 2 oz/A irf
Select Max' and apply lo 4” lo 36" glyphosale^eratt
volunteer corn.
Choose your Roundup WeatherMAX rale based on the
weed species and size listed in the "Annual Weeds Rale Table"
of the Roundup WeatherMAX Label.
Maximum Use Rates
for Roundup
WeatherMAX
In-Crop:
- 44 oz/A per single application
■ 44 oz/A during flowering
■ 64 oz/A emergence through flowering (R2 stags »}ybsans}
Preharvest:
■ 22 oi/A application
Total Season;
■fte combined total of preplan t, in-crop and preharvest
applications of Roundup WeatherMAX can not exceed
5,3qt/A.The combined total of in-crop and preharvest
api^ications can not exceed 64 oz/A.
*rcllcv4 all pesticiile label re(|u>r«itien!s.
Herbicide products sold by Monsanto for use over the tqj of so^^ns witti Genuity* Roundup Ready 2 Yield' Technology for the 2010 crop
season are as follows:
• Roundup WealherMAX
• Roundup PowerMAX
WEED CONTROL RECOMMENDATIONS
1 KEY WEEDS
I INSTRUCTIONSrAND USERATES? . .
1 ADDITIONAL INFORMATION "J
Weeds that Tend
to Have Multiple
Emergence Events
Where dense stands of weed species such as common
lambsquarters. tall and common weterhemp. Palmer
Amarantfi, redroot pigweed, common ragweed, and giant
ragweed are expected, the following agronomic practices
are recommended:
Weeds such as lambsquarters. waterhemp, pigweed, and giant
ragweed tend lo emerge throughout the season. Sequential
Roundup WeatherMAX applications or the addition of a soil
residual herbicide may be required for control of subsequent
weed flukes.
' Start clean with tillage or burndown In no-till and reduced
til! systems. Include 2.4-D in the burndown.
• Plant soybeans In narrow rows t<20").
' Use a pre-ptant residual herbicide.
' Use the right rate of Roundup WeatherMAX at the right
time (proper weed size).
DlfFicult-to-
Controt Weeds
Black nightshade, veivetleaf. walerhemp. morningglory.
lambsquarters, Florida pusiey. giant ragvreed. Pennsylvania
smartweed. groundcherry, hemp sesbania and spurred
anoda are difficuil-lo-control weeds. Please refer to the
Roundup agricultural herbicide label for specific rates and
weed sizes for control of these weeds.
These weed species require special attention be paid
lo Roundup WeatherMAX rate and application timing
(proper weed size) to obtain excellent weed control.
A sequential application may be required if a new
weed flush occurs, especlaliy in soybeans planted
in wide rows {j20").
Perennial Weeds
An in-crop application of 22 to 44 oz/A of Roundup
WeatherMAX** will provide suppression and/or control of
nutsedge and perennial weeds like Canada thistle, field
bindweed, hemp dogbane, horseneltie, johnsongrass.
milkweed, quackgrass, etc.
for edditional inlormetion on perennial weeds, see the
■'Perennial Weeds Rale Table" in the label booklet for Roundup
WeatherMAX.
for best control, allow perennials to achieve at least
6" or more of growth before spraying.
'Eoiisw ail pasliCias lasei raquirements.
■•If using anoibef Founflup agricultural hcrbicWe.you muslrpler lo the label bookleiof Roond»siB«a<Iy Scfbeanof GenuKv'RcuntfupRMOv'a Yiald* Snybearr suppispenlal label lor that branil
to determina appropriate ussralas. ft using ReumJwsPowtMAX. apfdicalwi f^esarv the sane as fpf Raurtkip WeatbeeMAX.
WEED RESISTANCE MANAGEMENT GUIDELINES
Follow all pesticide label requirements and the guidelines below
to minimize the risk ol developing glyphosale-resistant weed
populations In a Roundup Ready Soybean System:
• Crop rotation is strongly encouraged.
• Scout fields befere and after each burndown atid in-crop application,
MONSANTO
1508
■ Start clean with a hurndown herbicide or tillage.
- Tank-mix with 2.4-D to control Qlyphosate-resistantmafestailOF
other tough-to-control broadleaf weeds.
• Use the recommended labei rate of a soil-applied residual hertJicide
such as INTRRO^ Valor', Valor XLT* or Gangster".
• In-crop, apply Roundup WeatherMAX at a minimum of 22 oz/A
before weeds exceed 8" in height.
If an additiwat flush of weeds occurs, a sequential application of
Round^> WeatherMAX at 22 oz/A may be needed before weeds
exceed 6" !n height.
Refer to individual product labels for a list of recommended
tank-mix partners.
Clean equipment before moving from field to field to minimize
the ^read of v/eed seed.
R^ort repeated non-performance to Monsanto or your local retailer.
RECOMMENDATIONS FOR MANAGING GLYPHOSATE-RESISTANT WEEDS
WEEDS INSTRUCTIONS AND USE RATES*
Giyphosate-Resistant Preplant:
Marestail (Horseweed) Apply a tank-mixture of 22 oz/A Roundup WeatherMAX® with 1 pt/A 2,4-D before marestail exceeds 6" in height,
See the 2.4-D product label for lime intervals required between application and planting.
fn-crop:
It is stmngly encouraged that shcHild be controlled i^ior to planting using recommended preplaot burndown treatments.
In-crop, apply a tank-mbclia-g of 22 oz/A Roundiq) WeatherMAX with oi oz/A FirstRats®. This treatinent should be used as a salvage
treatment only for a mare^ail tofeslaticm that was not cotdroiled preplanL Application should be made between full emergence of
the first trifoliate leaf and 50% flowering stage of soybeans. At the time of treatment, marestail should not exceed 6" in height
Giyphosate-Resistant
Amaranthus Species
■ Palmer Amaranth
- Waterhemp
Preplant:
Apply a tank-mix of 22 oz/A Roundup WeatherMAX with a preemergence residual herbicide such as aiachlor (INTRRO®),
ftumioxazin (Valor®) or another residual herbicide for preemergence control of Amamthus species. 2,4-D may be added to
the tank-mix to help control emerged AmaratUlvjs species and other broadleaf weeds preplant only. Follow label Instructions
regarding application timing relative to soybean planting.
In-crop:
II Is strongly encouraged that a preemergence residual product be used to control Amaranthus species prior to emergence.
If there is emerged Amaranthus in-crop, apply a tank-mixture of 22 oz/A Roundup WeatherMAX with a postemergence product
with activity on AmaranfAussuch as laclofen (Cobra®), fomesafen (Flexstar®) or cloransoiam (FirslRate). Applications
should be made on emerged Amaranthus that does not exceed 3" in height. Read and follow all product label instruction!
It is likely that visual soybean injury will occur with these tank-mixtures.
Giyphosate-Resistant
Affibrosra Species
* Giant Ragweed
- Common Ragweed
Giyphosate-Resistant
Johnsongrass
Preplant:
Apply a tank-mix of 22 oz/A Roundup WeatherMAX with a preemergence residua) herbicide such as cloransulam (FirstRate)
or cloransulam + llumioxazin (Canslsr®) or anolher residual herbicide for preemergence controi of Anrbros/a species, 2.4-D
may be added to the tank-mix to help control emerged Ambrosia species and other broadleaf weeds preplant only. FoDovr label
instructions regarding application timing relative to soybean planting.
In-crop:
it is strongly encouraged that a preemergence residual product be used to control Ambrosia species prior to emergence,
if there is emerged Ambrosia in-crop, apply a tank-mixture of 22 oz/A Roundup WeatherMAX witti a postemergence product
with activity on AmOros/asuch as laclofen (Cobra) or fomesafen (Flexstar). Applications should be made on emerged
Ambrosia that does not exceed 3” in height. Read and follow all product label instructions. It is likely that visual soybean
injury v/ill occur with these lank-mixtures.
Start clean with a tnirndown herbicide or tillage.
Preplant Incorporate a residual Iwrbicide such as pendimethalin or trifluraiin for control or suppression of seedling
johnsongras!
Apply Roundup WeatherMAX in a tank-mfx wth herWeides such as SelectMAX®, Assure® II or Poast Plus for the control of
emerged weeds including seedRng aral rhizome johnsongrasi Follow all label directions of tank-mix partners, especially those
related to weed «ze.
in certain areas, Italian ryegrass is known to be resistant toglyplusale. For control rccortunendations. refer to vww.weedreslstancemanagement-com
or call 1-800-768-6387. When approved, suppiementai labeling Iw spedfk: herKcide products can also be viewed on www.cdms.net or www.grBenbook.net.
Tollow all pcsficifi* late! roquiremenls.
2010 TECHNOLOGY USE GUIDE 1
1510
GENUITY™ROUNDUP READY® ALFALFA
'TENTION: Pursuant to a Court Order tssued on May 2
muity”' Roundup Ready® alfalfa seed CAN NOT be comm
Id or planted ut,li' lurther administrative regulatory actii
mpleted. For more information, and ttie latest updates on (■
)undup Ready-"’ alfalfa; go to.Www.roundupreadyalfalfa.co
gGniilfcu
Genuity’“ Roundup Ready® alfalfa varieties have in-plant tolerance to Roundup® agricultural
herbicides, enabling farmers to apply labeled Roundup agricultural herbicides up to 5 days
before cutting for unsurpassed weed control, excellent crop safety and preservation of
forage quality potential.
Hay and Forage Management Practices
Genuity" Roundup Ready* alfalfa must be managed for Wgh
quality tiay/forage production, including timely cutting to
promote high forage quality {i.e. before bloom) and to
prevent seed development. In geographies where conventional
alfalfa seed production is intermingled with forage production
and the agronomic conditions (climate and water/irrigation
availability) are such that forage alfalfa is allowed to stand and
flower late In the season. Genuity" Roundup Ready*’ alfalfa must
be harvested at or before 10% bioom to minimize potential
pollen flow from hay to common or conventional alfalfa seed
production. Farmers who are unwilling to or who can not make
this commitment to stewardship should not continue to grow
Genuity"' Roundup Ready” alfalfa.
Genultv" Roundup Ready” alfalfa varieties have excellent
tolerance to over-the-top applications of labeled Roundup
agricultural herbicides An in-crop weed control program using
Roundup WeatherMAX® or Roundup PowerMAX'wlll provide
excellent weed control in most situations. A residual herbicide
labeled for use In alfalfa may also be applied postemergence in
alfalfa. Contact a Monsanto Representative, local crop advisor or
extension specialist to determine the best option for your situation.
stand Takeout and Volunteer Management
Crop rotations can be divided into two main groups, alfalfa
rotated to; 1} grass crops (e.g. corn and cereal crops): and
2) broadleaf crops. More herbicide alternatives exist for manage-
ment of volunteer alfalfa in grass crops. The recommended steps
for controlling volunteer Genuity" Roundup Ready® alfalfa are;
• Diligent Stand Takeout * Plan for Succks
• Start Clean * Timely Execution
DILIGENT STAND TAKEOUT
Use appropriate, commercially available herbicide treatments
aione for reduced tillage systems or in combination with tillage
to teriTHnate the Genuity'* Roundup Ready® alfalfa stand. Refer to
your regional technical bulletin for specific stand takeout recom-
mendations. NOTE; Roundup® agricultural herbicides are not
effective for terminating Genuity” Roundup Ready* alfalfa stands.
START CLEAN
If necessary, utilize tillage and/or additional herbicide
application(s) after stand takeout, and before planting of
the subsequent rotationa! crop to manage any newly
emerged or surviving alfalfa.
PLAN FOR SUCCESS
Rotate the crops with known and available mechanical or
herbiddal methods for managing volunteer alfalfa, keeping
in mind that Roundup agricultural herbicides will not terminate
Genuity” Roundup Ready® alfalfa stands.
‘ Rotations to certain broadleaf crops are not advisable If
the farmer is not willing to implement recommended stand
termination practices.
• In the event that no known mechanical or herbicldat methods
are available to manage volunteer alfalfa in the desired rotational
crop, It is suggested that a crop with established volunteer
alfalfa management practices be introduced into the rotation.
TIMELY EXECUTION
Implement In-crop mechanicai or herbicide treatments for
managing alfalfa volunteers in a timely manner; that is, before
the volunteers become too large to control or begin to compete
with the rotational crop.
2010 TECHNOLOGY USE GUIDE
1511
GENUITY” ROUNDUP. READY® aIfALFA
Planting Requirements
Genuity” Roundup Ready’ alfalfa is not permitted to be planted
in any wildlife feed plots.
Stewardship
Ail Genuity'" Roundup Ready® alfalfa farmers shall sign the
Monsanto Technology/Stewardship Agreement (MTSA) limited-
use license application which provides the terms af>d conditions
for the authorized use of the product. Due to special circum-
stances, alfalfa farmers In the imperial Valley of California will
also sign an imperial Valley Use Agreement (IVUA) with specific
stewardship commitments. The MTSA or IVUA must be completed
before purchase or use of seed.
Both the MTSA or IVUA explicitly prohibit all forms of commercial
seed harvest on the stand. Every alfalfa farmer producing seed
of Genuity"" Roundup Ready* alfalfa must possess an additional,
separate and distinct seed farmer contract to produce Genuity'’
Roundup Ready® alfalfa seed. Genuity" Roundup Ready® alfalfa
seed may not be planted outside of the United States, or for
the production of seed or sprouts.
Any product produced from a Genuity'" Roundup Ready® alfalfa
crop or seed, including hay and hay products, must be labeled
and may only be used, exported to, processed or soid in countries
where regulatory approvals have been granted. It Is a violation
of nattcmal and international laws to move materia! containing
biotech traits across boundaries into nations where Imparl is
not permitted.
Pursuant to a Court Order issued on May 3. 2007, Genuity'"
Roundup Ready® alfalfa farmers must adhere to the requirements
set oiA HI the December 18, 2007 USDA Administrative Order
(http://www^phi5.U5da.gov/brs/pdf/RRA_Ae_final.pdl) until
the USDA completes its regulatory process.
These requirements Include, but are not limited to:
• Pollinators shall not be added to Genuity " Roundup Ready®
alfalfa fields grown only for hay production.
• Farm equipment used in Genuity" Roundup Ready® alfalfa
production shall be properly cleaned after use.
• Genufty'* Roundup Ready® alfalfa shall be handled and clearly
Identified to minimize commingling after harvest.
For additional information visit the USDA website:
http:/Avvyw.aphis.usda.gov/bfotechnologv/alfalfa„h!stery.shtml
For more Information and the latest updates on Genuity'" Roundup
Ready® alfalfa, go to http://www.roundupreadYalfalfa.com
To meet sales reporting requirements, the seed supplier is required to Identify and list all Genuity"* Roundup Ready* alfalfa
field locations. Therefore, all farmers MUST PROVIDE their seed supplier with the GPS coordinates of alt their Genuity"
Roundup Ready* alfalfa fields.
MONSANTO
1512
F genulty jj
RtKiniiupRcadj
WEED RESISTANCE MANAGEMENT GUIDELINES
Foffow all pesticide label requirements and the guideJines below
to minimize the risk of developing glyphosate-resistant weed
populations in a Genuity” Roundup Ready® alfalfa s^ratem:
• Scout fields before and after each herbicide applicatton.
• Use the right herbicide product at the right rale and at
the right time.
To ccmtfoi flushes of weeds in established alfalfa, make
applications of Roundup WeatherMAX® or Roundup
PowerMAX* herbicide at 22 to 44 oz/A before weeds
exceed 6“ in height, up to 5 days before cutting.
Use other approved herbicide products tank-mixed or in
sequence with Roundup agricultural herbicide if appropriate
for the weed spectrum present as part of a Genuity”
Roundiqi Ready® alfalfa weed contrd program.
Report repeated non-performance to Monsanto or your
locai retailer.
WEED CONTROL RECOMMENDATIONS
In established stands, to preserve the quality potential of forage
and hay, applications should he made after weeds have emerged
but before alfalfa re-growth interferes with application
spray coverage of the target weeds.
PROGRAM
F INSTRUCTIONS AND USE RATES* v;
' ADDtTIONAL JNrORMATION
Established Stands
After the first harvest of a nevdy esiabSshed staml. up
fo 44 oz/A of Roundup WeatherMAX®** herbierde
per cutting may be applied up to S days before each
subsequent cutting. The combir^ Ic^al |Kr year tor
al! tn-cfop applications in established stands must not
exceed oz/A {4.i qt/A} of Roundup WeatherMAX.
Applications between cuttings may be applied as a single application or
in multiple applications (e.g. Z applications of 22 oz/A).
Sequential applicab'otrs should be at least 7 days apart.
Weeds Controlled
For specific application rates and instructions for
control of various annual and perennial weeds, refer to
the Roundup iVeatherMAX'* herbicide label booklet.
Some weeds with multiple germmalion times or
suppressed (stunted) weeds may require a secortd
application of Roundup WeatherMAX" herbicide for
complete control. For some perennial weeds, repeated
af^illcations may be required to eliminate crop
competition throughout (he growing season.
In addition to those weeds listed in the Roundup WeatherMAX* label booklets,
this product wifi suppress or control the parasitic weed, dodder {Cuicutaspp.)
m Genuity' Roundup Ready* alfalfa. Repeat applications may be necessary for
complete control.
For tough-to-controi weeds or weeds not controlled by Roundup® agrlculluraf
herbiddes use labeled rates of other approved herbicides, alone or in
tank-mixiures. with Roundup agricultural herbicides.
Maximum Use Rates
ln*Crop:
* 44 oz/A per single application.
• Established Stand Total: 44 oz/A par cutting
up to 5 days before harvest.
Total Per Yean
The combined total per year for ail in-crop applications in established stands
must not exceed 132 oz/A (4.1 qi/A) of Roundup WeatherMAX.
’Rillow bH pesticide label requirements.
’*ir using tinallwr Reunduu egticuliura! herbicide, you must reler Id iht laM baokirt or ser.aralely pubUshedGerHnly'RovnduB Ready* allelfa supptemenlai lobe!
for that brand to determine appropriate use rates, it using Roundup PowerMAX. applicalion rales are the same ailor Rouria<« WeelhsrMAX.
201D TECHNOLOGY USE GUIDE
1513
GENUITY “ ROUNDUP READY® SPRING CANOLA
1 ^^^ . Genuity™ Roundup Ready* spring canola hybrids contain
in-plant tolerance to Roundup agricultural herbicides,
enabling farmers to apply Roundup* agricultural herbicides
over the top of Genuity™ Roundup Ready* spring canola
anytime from emergence through the 6-leaf stage of development.
The introduction of the Roundup Ready' trait into leading spring
canofa hybrids and varieties gives farmers the c^porlunlty for
• Scout fields before and after each burndown and in-crop
application.
unsurpassed weed control, proven crop safety and maximum
profit potential. With Genuity'' Roundup Ready' spring canola,
farmers have the weed management too! necessary to improve
spring canola profitability, while providing a viable rotational crop
to help break pest and disease cycles in cereal-growing areas.
WEED RESISTANCE MANAGEMENT GUIDELINES
Follow all pesticide label requirements and the guidelines below
to minimize the risk of developing glyphosate-resistant weed
populations in e Genuity™ Roundup Ready* spring canola system:
• Start clean with a burndowir herbicide or tillage.
• In-crop, apply Roundup WeatherMAX® herbicide before
weeds exceed 3" In height.
• A sequential application of Roundup WeatherMAX herbicide
may be needed.
• Clean equipment before moving from field to field to minimize
the spread of weed seed.
• Report repeated non-performance to Monsanto or your local
retailer.
WEED CONTROL RECOMMENDATIONS (SPRING-SEEDED)
PROGRAM
• INSTRUCTIONS AND USE RATES* pfe i- .
vADiM'|bN)^;iNroRMMi;bN^J;;||K ■>
1^0'Pass Program-
Fof Annual and
Perennial Weed
Control
For broad-soectrum control of annual and perermial
weeds, use an initial application of 11 oz/A of Roundup
WeatfierMAX'*, in 5 to 10 gal/A wafer volume.
No surfactant is required.
Make a second application of 11 oz/A of Roundup
WeatherMAX** no less than 10 days after Initial
application up to the 6-ieaf stage (probolting).
Do not exceed 11 o:/A per application.
spray when canola is at the 0- to 6-leaf stage of growth. To maximize yield
potential, spray Genuity" Roundup Ready® spring csnoia at the 1- to 3-ledf
stage io eliminate competing weeds. Short-term yellowing may occur with
later applications, with little effect on crop growth, maturity, or yield.
Wait a minimum of 10 days between applications. Two applications
of Roundly WeatherMAX wiii:
‘ Control late flushes of annual weeds such as foxtail, pigweed,
and wild mustard.
* Provide season-long suppression o! Canada thistle, quackgrass, and
perennial sowthistle.
• Provide belter yields by eliminating competition from both annuals
and hard-to-control perennials.
Single Application-
For Annua! Weed
Control
For broad-spectrum control of annual and
easy-to'control perennial weeds, make a single
application of 16 oz/A of Roundup WeafherMAX.**
For best resets, spray Genuity" Roundup Ready® spring canola at the Z- to
3-leaf stage. Can be applied up to 6-leaf stage; yellowing may occur
with later ajHilica lion with little effect on crop growth, maturity, or yield.
No additional over-the-top applications can be made.
Maximum Use
Rate For Roundup
WeatherMAX
Two over-the-top aKilicalicms: Do not exceed
11 oz/A per application.
Single over-the-top applications: Do not exceed 16
oz/A. No additional applicaDon can be made.
'Foltotv all pesticide iebel rsqi
jirem«fvl5.
1514
CENUITY’ ROUNDUP READY" WINTER CANOLA
Genuity'" Roundup Ready® winter canola varieties have
been developed for seeding in the fall and harvesting the
following spring/summer.
Genuity ■“ Roundup Ready^ winter canola varieties contain In-pfant
tolerance to Roundup’’ agricultural herbicides, enabiing farmers
to apply Roundup agricultural herbicides over the top of Genuity’'
Roundup Ready® winter canola from crop emergence to the
pre-bolting stage. The introduction of the Roundup Ready trail
into winter canola varieties gives farmers the opfrortunlly of
unsurpassed weed control, crop safety and maximum yield
potential. Genuity" Roundup Ready* winter canda offers farmers
an Important optidi as a rotational crop in traditional monoculture
winter wheat production areas. Introducing crop rotation is an
important factor In reducing pest cycles, including weed and
disease problems.
WEED RESISTANCE MANAGEMENT GUtOELiNES
Fdiow the same guidelines as stated for spring canola.
WEED CONTROL RECOMMENDATIONS (WINTER-SEEDED)
PROGRAM
Sequential Applications
" iNSTRUCTIONS AND USE h.AltS*
Tfse two-pass program gives the latest Hexibililv in
controlling ate emerging weeos. Fty oroao-spectniin weeo
control, apply 11 to 22 oz/A of Roundup WeatherMAX**
herbicide to Meaf or larger Genuity" Roundup Ready* winler
canola in the fall. Use 5 to k) gailons/A water volume. Oo not
add surfactants.
Apply a second application of Roundup WeatherMAX" at II (o
21 oz/A at a minimum interval of 60 days after Ihe lirsl
application and before bolting hi (he spring.
Do not exceed 22 oz/A per application.
^ ADDITIONAL INFORMATION , • ^
Spray when Genuity' Roundup Ready® winter canola is at the 2-3
leaf stage of growth. Early applications can eliminate competing
weeds and improve yield potential.
Two applications of Roundup WeatherMAX will provide control of
early emerging annual weeds and winter emerging weeds such as
downy brome. cheat and jointed goatgrass.
Single Application
For broad-spectrum control of annual and easy-to-control
perennial weeds, make a single application o( 16 to 22 oz/A
of Roundup WeatherMAX'*, preferably in Ihe fall.
for best results, spray Genuity* Roundup Ready® winler canola
at the 2-3 leaf stage and when weeds are small and actively
growing. Applications must be made prior to bolting. Use the
higher rale in the range when weed densities are high, when
weeds have over wintered or when vxeeds become targe and
well established.
Maximum Use Rate for
Roundup WeatherMAX
Any single over-the-top api^ication of Roundup
WeatherMAX" should not exceed 22 oz/A. No more Itian
two over-the-top applications may be made from crop
emergence to canopy closure prior to bitting in ihe spring.
Applications of greater than 16 fluid ounces/A prior to the 6-leaf
stage may result in temporary yellowing and/or growth reduction.
'roliow all pc:tici<!c labs) rcquirsmsnU.
”lf using anoiner Rounduo brand herbicide, you musl refer to (he lebel booklet w 0«nu«y'’“ Roundup Ready* winter canoteTUpolemenle! label fsr (hat brand to Oetermlna
apprapriale use rates. H using Roundup PowerMAX, application rates are the same as lor BounSop WealherMAX.
GRAZING
It is recommended that Genuity" Roundup Ready* winter canoia
not be grazed. While Genuity" Roundup Ready® winter canola
may provide farmers additional opportunity as a forage for
grazing livestock, at the present time insufficient information
exists to allow safe and proper grazing recommendations.
Preliminary data suggest that excessive grazing can significantly
reduce yield, and that careful nitrate management is critical
in managing Genuity" Roundup Ready® winter canola as a forage
to limit the risk of livestock nitrate poisoning. State universities
are assessing the potential and the instructions for grazing
Gwiuity" Roundup Ready® winter canola and they will provide
grazing management guidelines when their research is completed.
201Q TECHNOLOGY USE GUIDE
1515
Genuity™ Roundup Ready* sugarbeet varieties have
in-plant tolerance to Roundup" agricultural herbicides,
enabling farmers to apply labeled Roundup agricultural
HQiinoup itesoy
herbicides from planting through 30 days prior to
harvest for unsurpassed weed control, excellent crop safety and
preservation of yield potential.
MANAGEMENT PRACTICES
Suqarbeets are extremely sensitive to weed competition for tight,
nutrients and soil moisture. Research on sugarbeet weed cofjtrol
suggests that sugarbeets need to be kept weed-free for the first
eight weeks of growth to protect yield potential. Therefore,
weeds must be controlled when they are small and before they
compete with Genuity" Roundup Ready® sugarbeets (exceed crop
height), that is from less than 2" up to 4" in height, to preserve
sugarbeet yield potential. More than one In-crop herbicide
application will be required to control weed infestations to
protect yield potential as Roundup agricultural herbicides have
no soli residual activity. Bolting sugarbeets must be rogued
or lopped in Genuity" Roundup Ready® sugarbeet fields.
Genuity" Roundup Ready® sugarbeet varieties have excellent
tolerance to over-the~top applications of labeled Roundup
agricultural herbicides. A postemergence weed control program
using Roundup WeatherMAX* or Roundup PowerMAX* will
provide excellent weed control in most situations. A residual
herbicide labeled for use in sugarbeets may also be applied
preemergence, prepiant or postemergence In Genuity" Roundup
Ready* sugarbeets. Contact a Monsanto Representative, local
crop advisor CM- extension specialist to determine the best option
for your situation.
WEED RESISTANCE MANAGEMENT FOR GENUITY"
ROUNDUP READY® SUGARBEETS
Follow all pesticide label requirements and the guidelines below
to minimize the risk of developing giyphosate-reststant weed
populations in a Genuity" Roundup Ready® sugarbeet system:
• Start clean with tillage and foliow-up with a burndown
herbicide, such as Roundup WealherMAX, if needed
prior to planting.
• Early-season weed control is critical to protect sugarbeet
yield potential. Apply the lirst in-crop application of Roundup
WeathsrMAX at a minimum of 22 oz/A while weeds are less
than 2" in height.
• Follow with additional pestemergence in-crop application of
Roundup WeatherMAX at a minimum of 22 oz/A for additional
weed flushes before weeds exceed A" in height.
• Add spray grade ammonium sulfate at a rate of 17 lbs/100 gallons
of spray solution with Roundup® agricultural herbicides to
maximize product performance.
• Use mechanical weed control/cultivation and/or residual
herbicides where appropriate in your Genuity" Roundup Ready*
sugarbeets.
• Use additional herbicide modes of action/residual herbicides
and/or mechanical weed control In other Roundup Ready crops you
rotate with Genuity" Roundup Ready* sugarbeets.
• Report repeated non-performance of Roundup agricultural
herbicides to Monsanto or your local retailer.
AGRONOMIC PRINCIPLES IN SUGARBEETS
Sugarbeets are very sensitive to early-season weed competition.
It is important to select the appropriate herbicide product,
application rate and timing to minimize weed competition to
protect yields. The Genuity" Roundup Ready* sugarbeet system
provides a mechanism to control weeds at planting and once
Genuity" Roundup Ready* sugarbeets emerge. Failure to control
weeds with the right rate, at the right time and with the right
product, can lead to increased weed competition, weed escapes
and the potential for decreased yields. Tank-mixtures of Roundup
agricultural herbicides with fungicides, insecticides, micronutri-
ents Of foliar fertilizers are not recommended as they may result
in crop injury and reduced pest control or antagonism.
PLANTING REQUIREMENTS
Genuity" Roundup Ready* sugarbeets are not permitted to be
[Wanted in any wildlife feed plots.
STEWARDSHIP
All Genuity" Roundup Ready'* sugarbeet Farmers shall sign the
Monsanto Technology/Stewardship Agreement (MTSA) limited-
use license application which provides the terms and conditions
for the authorized use of the product The MTSA must be signed
and approved prior to purchase or use of seed.
1516
WEED CONTROL RECOMMENDATIONS
PROGRAM
INSTRUCTIONS AND USE RATES*
ADDITIONAL INrORMATION
Preplant Burndown
After preplant tillage or bedding operation have been corseted, a
preplant burntJown application of RoufHlt^Vie3ili«i4AX***at22lo
44 Qz/A may he appKed to control weeds that haw ^m^ed^ter
tillage and prior to planting.
Always utilize tillage to start with a weed-free field.
See the label for appropriate rales by weed species aid weed size.
Over-Hie-Top
Applications up to
eight-leaf Genuity"
Roundup Ready®
Sugarbeets
Up to two applications of Roundup agriculture terbicktes may be made
prior to the 6-leaf stage of Genuity* Roundup Ready® sugarberfs.
The first application of 22 to 32 oz/A of RomdupttealhwfiAX**
should be made when weeds are less than!" kih^ht to |^(rfect
yield potential.
Maks an additional application of 22 to 32 oz/A Roundup WeatherMAX
before weeds exceed 4" in height.
Maximum in-crop Roundup WeatherMAX iM'lor to B-leaf stage must not
exceed 56 oz/A.
Sugarbeets are sensitive to weed competitiim and can
toss yield rapidly if weeds are not controlled early. More than one
in-cfop Roundup WeatherMAX application will be required to
contool weed infestations to protect yield potentiai as Roundup
agriculturdl herbicides have no soil residual activity.
Add ammonium sulfate at a rate of 17 lbs/100 gallons of spray
solutkm with Roundup agricultural herbicides to maximize
product performance. Tank-mixtures of Roundup agricultural
herbicides with fungicides. Insecticides, micronutrients or foliar
fertilizers are not recommended.
Sequential applications should be at least 10 days apart
Qver-The-Top
Applications to
greater than
eight-leaf Genuity"
Roundup Ready®
Sugarbeets
Up to two additional applications of 22 oz/A of Roundup
WeatherMAX can be made after the eight-leaf stage up to
30 days prior to harvest.
Maximum in-cro'p Roundup WeatherMAX from 8-leaf stage up
until 30 days prior to harvest must not exceed 44 oz/A.
Add ammonium sulfate at a rate of f? Ibs/iOO gallons
of spray sofution with Roundup agricultural herbicides to
maximize product performance. Tank-mixtures of Roundup
agricullurai herbicides with fungicides, insecticides,
mlcronutfiefits or foliar fertilizers are not recommended.
Sequential applications should be at least
10 days apart.
Maximum
Use Rates
In-Crop:
' Two applications of Roundup WeatherMAX prior [o the 8-leaf stage
of Genuity" Roundup Ready® sugarbeets
- 32 oz/A per single application up to the B-leaf stage.
• Combined maximum of 56 oz/A in-crop prior to the 8-Jeaf stage
• Two applications of Roundup WeatherMAX after the B-leaf stage
up to 30 days prior to harvest
- 22 oz/A per single application after the 6-ieaf stage.
• Combined maximum of 44 oz/A in-crop after the 8-leaf stage
until 30 days prior to harvest
Total Par Yean
The combined total per year for all Roundup WeatherMAX
apfRications including pre-plant must not exceed 5.3 qt/A.
Total in-crop application must not exceed 3 qt/A.
Add ammonium sulfate at a rate of 17 Ibs/IGO gallons of spray
solution with Roundup agricultural herbicides to maximize
product perlormartce. Tank-mixtures of Roundup agricultural
herbicides with fungicides, insecticides, micronutrients or foliar
fertilizers are not recommended.
‘Follow all petllcitlB label requliements.
“If using another fioondup agricuUural herbicide, you irusl teiet to ttis label booktel or s^iaralely published Oenuily' Roundup fieady^ sugarbeets supplemenlai label tor
ihal brand lodelectnins apprsprlale use rales. II using Roundup PewerUAX appkealion rates are the same as (or Roundup WeatherMAX.
2010 TECHNOLOGY USE GUIDE
1517
This guide was printed using Utopia !i XG Cover
and Text which contains 30% post-consumer waste.
Savings derived from using 30% post-consumer
fiber in lieu of 100% virgin fibers;
• Saves the equivalent of 585 mature trees
• Reduces solid waste by 35,308 pounds
• Reduces waste water by 213,390 gallons
• Reduces greenhouse gas emissions by 199,989.75 pounds
i ba; ol seed, be sure to read, understand and KcepI the
■■'i *
A-
UBEFtTY
UNICtSr
Roundup Ready* Alfalfa seed Is currently not for sale or distribution. The movement and use of Roundup Ready* Alfalfa foraqe Is subject to » USDA administrative Order available at
http;//www.aphls.usda.qav/brs/pdl/RRA_A8_finaI.pdf.
This sttwardahlp stelement applies to all products listed herein eecept Genuity"* VT Double PfiO"", Genuity"* VT Triple PR0’“ and Genuity”* SmariSlax"*. See restrictions related
to Geniaty"* Double pho"', Genufty"* \rr Triple pho" ana eanuliy"* anartstax’” below
Monsanto Company Is amemberof Escellence Throuib Stewardship* lETSJ. Motis^ilo products ate commercialized in accordance with ETS Pfoduct launch Stawardstiiii Outdance,
and In compliance with Monsanto's PoBcy lor CommerctaKzatton oi Diotechnology-Derived Plant Products in Commodity Crops, This product has faewi approved lor import into key export
maikeb with funclionlnq requlatcrv systems, fisxy crop or material produced from this oroduct can only be ejporled to, or used, processed or sold in countries where all necessary reqaiatary
approvals have been granled. It is a violation of national and inlernatlona! law to mtsve material cofjtaining biotech trails across boundaries into nations where import is not permitted.
Growers should talk to their grain hardier or product purchaser to confirm their buying position for inis product, Excellence Through Stewardship’’ Is a reglstBreo tradsmarii ol Biotechnoiagy
Indusirv Organizsifon.
IMPORTANT: Grain Marketing and Seed Availability: Genuity’” VT Doubfe PRO’” has rsceivsct !he necessary approvals in the Utsiled States, however, as of October 22, 2009. approvals
have not been received in certain major corn export markets. Genuity" VT D«ible PRO”* will not be launched and seed will net be avaUabls until alter Import approvals are received In
appropriate major cern exporl markets, fi.f. praduets, Including Genuity" VT Double PRO'“ may not yet be registered in all states. Check with your Morisanto represenlailvG for the
registratforxstatus In your stale,
IMPORTANT: Grain Marketing and Seed Availability. Genuity" VT Triple PRO" ha: received IhenscBssay approvals In the United States however, as o! October 22, 2009, approvsihas
not been received In all tnajor corn export markets. Monsanto arxtfcipates that ail such approvals will be in piKe for the 2010 growing season, II all sporovsls are t>ot iix place, Genuity'" VT
Triple PRO" seed will only be available as part of a commercial demonstration program that includes grain marketing stewardship requirements, it is a violation of nsiiona! and iriernaiional
law to move material ccntainir.g biotech traits across brxinflafies into nations where import is no! permiUsd. Consult with your seed represenlalive lor current regulatory and stewardship
iniormation status,
IMPORTANT: Gralrr Marketing and Seed Availability: Genslty™ SmartSta*'” has rcceivfd the necessary approvals in the United Stales, however, as oi October 22, 2009. approvals have
no! Deers recelvM in certain mulor corn expurt marXels. Oemilty'” smartstax'" will not be launched and seed wd! not be available unill afler import approvals arc received Insporoprlafe
major corn export markets. B.i. praduets, Inetudlng Genuity”* Smartstax”* may not yet be registered in all stales. Chock with your Monsanio representative for the registration slalus
In ynur State-
Cottonseed containing Monsanto traits may not be exported lor the purpose of plwiting without a license from Monsanto.
Individual fosuUa may vary, and poriormanco may vary iram Iccation lotacalionandfrom year In year. This result may not be an indicator of results you may obtain as local growing, siail
ant) weather corxlitions may vary. Growers should evaluate data from multiple localiore and years whenever possible.
Growers may utilize the natural refuge option for varieties cwtaiftlnglheBollgard II* trait In the fellovdng states: AL. AS, Fl.GA.KS, KY.LA.MD.MS.MO.NC, OK, SC, TN. VA. and
most of Texas (excludifig the Texas counties of Brewster, Crarre, Crockett, Culberson, El Paso, Hudspeth, Jelt Davis. Loving, Poeos, Presidio, Reeves, Terrell, Val Verde. Ward and Wir*ler).
The natural refuge option does nrS apply fo Boligart M cotton grown In areas where pink bollworm is a pest, irwluding CA. A2. n.m, and the above listed Texas counties. It also remains the case
that Bfiilqafd’ and Batigard II cotton cannot be pianled south ofHlghway60in Florida, and that Bollgardcotlon canrxsl be planted in csrlsinnftier counties in the Texas panhandle. Refer to the
TeclinologyUse Guide arri IRM/Grower Guide for additional information regarding Bi^lgard II, Sollgard, natural refuge and EPA-mandaled geogr®hical reslriclions on Ifse planting of B.t. cofton,
ALBfAYS fEAO AND FOLLOW PESTICIDE LABEL DIRECTIONS. Soulidup Ready* crops contain genes that conler tolerance to glyphosaie, the active mqiedien! In Roundup* brand
agricultural herbicides, floundup’ brand aqricuilural herbicides will k!l crops tha! are not tolerant to glyphosaie. Degree* and Harness’ are not registered In all states- Degree’ and Harness*
may hesubjecl to use resUiclions In some states. Bjllei’, Degree Xtra’. Harness’, INTRRO*. Lailal’, and Micro-Tech" are feslrictecl use pesticides and are not registerets itx aft stales. The
dislribiriion. sals, or use of an unregistered peslicitis is a violation of letlsral and/nr state law arid is strictly p-ohiblted. Check with your local Mensanto dealer or represeriative lor the product
registration status in your slate.
Task mixtuTBs: The applicable labeling for earii product must be in the possession ci the user at the lime of application. Follow applicsblo use instructians.iicluaingappScalton rates,
precautionsand restrictions of each product used in the tank miilure, Monsanio has not lestedali tank mix product lormuiations lor compatibikly or petforroance other ihanspecificanv
listod by brand name, Al-vayspradafarminethecompalihilityol lank mixtures by mixing small proportional quanhtiesin advance.
Eolgard*. BoDgard ll», Bullel', Degree*. Degree Xtra* Genuity". Genuity and Oesign". Geniily icons. Harness*. IbfTRfiO*. lariat*. Micro-Tech", flespec! the Reluge and Cotton Design*
Roundup*, Roundup PowbcMAX*, Roundup Ready*, Roundup Ready 2 Technology and Design", Roundup Beady 2 Yield*. Roundup Ready RATE". Roundup WaatherMAX', Roundup
WsiitlieiMAX and Design*, Smartstax", Smartstax and Design", Siarl Clean, Slay CleaiL". Transorb and Design’, Vistive”, Visiive anil Design’, VT Double PRO". VT Triple pro", Ylsidoard’,
YieidGardCorrx Sorer and Design*, VieltiCardRus and Design*. YieldSardBootwoim and Design®. YietdGard VT*. VieidGaid VT and Design* YieldGard VT R50lworiTi/RR2'. VIeldGard VT
Triple’, and Monsanio and Vine Design* are trademarks of Monsanto Technology LLC. Ignite' and libertyLInk* and the Water Droplet Design* are regisiered trademarks of Bayer, Herculsx
Is a trademark of Desw AgroScisnees LLC, Select Max* and Valor' are registereci trademarks ol Valent US. A. Corporation. Respect the Refuge* and Respect the Refuge and Corn Design’
are regislEfed fiademsrks oINslionalCr-rn Growers A.ssocUtlo.n, All other trademarks are tns property oi their respective owners. ©2009 Monsanto Cwx'parxy. D92a2Apgdi 9A-BY-09-3a81
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